When the CMRAO Takes Action
This page is for individual condo managers, including principal condominium managers, and for the management provider businesses that employ them under the Condominium Management Services Act, 2015 (CMSA). Complaints commonly come from condo owners or boards about records, communication, finances or conflicts of interest.
Illustrative example, not an actual CMRAO notice
“Take notice that the registrar proposes to revoke your general licence as a condominium manager, for the reasons set out below. You are entitled to a hearing by the Licence Appeal Tribunal if you mail or deliver a written request for a hearing to the registrar and to the Tribunal within 15 days after service of this notice.”
Like other administrative-authority regimes, the CMSA has two tracks: registrar proposals about your licence go to the Licence Appeal Tribunal, and alleged code of ethics breaches go to the CMRAO’s discipline committee.
Who Investigates and Who Decides
- Regulator
- The CMRAO and its registrar, under the CMSA.
- Complaints
- The registrar can request information from any licensee about a complaint, and the licensee must provide it as soon as practicable (CMSA, s. 57(1)–(3)).
- Registrar’s options
- Mediate; issue a written warning; require a condo manager, or a provider’s principal condominium manager, to take courses; refer the matter to the discipline committee; propose action against a licence; or take other appropriate action (s. 57(4)).
- Inspections and investigations
- Inspectors may inspect without a warrant in some circumstances, and investigators can obtain search warrants (ss. 59–62).
- Who decides
- The Licence Appeal Tribunal for licence proposals (s. 41); the discipline committee, with an appeal to the appeals committee, for code of ethics matters (s. 58). LAT decisions under the CMSA can be appealed to the Divisional Court (Licence Appeal Tribunal Act, 1999, s. 11).
Managers and providers
Providers must notify the registrar within five days when a condo manager starts or stops working for them, and give the reason for any termination; managers must also report changes (CMSA, s. 45). Discipline orders can require a provider to fund education for its managers, or require a manager’s employer to do so (s. 58(4)).
Common Issues in Condo Management Investigations
Records and owner requests
Delays or refusals in providing records to owners, and incomplete corporation records.
Finances and conflicts
Handling of corporation funds, undisclosed relationships with contractors, and procurement practices.
Communication and professionalism
How a manager dealt with owners, residents and the board, including disputes and enforcement of rules.
Licensing and scope
Providing services beyond the class or conditions of your licence, or working without a licence.
Honesty and competence
Misleading the board or owners, and failing to meet the code of ethics’ standards of competence and integrity.
What Can Happen Next
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Discipline committee
If the committee finds a breach of the code of ethics, it may require courses, require a provider to fund education for its managers, impose a fine of up to $25,000 (or any lesser prescribed amount), suspend or postpone those requirements on terms, and award costs (CMSA, s. 58(4)). A party may appeal the final order to the appeals committee, which may overturn, affirm or modify it (s. 58(5)–(6)).
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Notice of Proposal
To refuse, suspend or revoke a licence, or impose conditions you have not agreed to, the registrar must serve a Notice of Proposal with reasons (CMSA, s. 41(1)–(3)).
Deadline
You are entitled to a LAT hearing if you mail or deliver a written request to the registrar and the Tribunal within 15 days after service of the notice (CMSA, s. 41(2), (4)). Registered mail is deemed served on the third day after mailing (s. 73(2)). Without a timely request, the registrar may carry out the proposal (s. 41(7)).
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Immediate suspension
When proposing a suspension or revocation, the registrar can also suspend your licence immediately if that is in the public interest. If you request a hearing, the order expires 15 days after the Tribunal receives your request, unless the hearing has started and the Tribunal extends it (CMSA, s. 43).
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Reapplying
After a refusal or revocation becomes final, you can reapply only after the prescribed time and if there is new evidence or a material change in circumstances (CMSA, s. 44).
Checklist: Responding to the CMRAO
Documents to gather
- The complaint, proposal or referral, and proof of when and how it was served
- The management agreement and your licence class
- Board minutes, correspondence with owners and the board, and records requests and responses
- Financial records and procurement documents, if finances are in issue
- Your provider’s policies and your supervision arrangements
Details to check in the notice
- Is it a complaint request, a discipline referral, or a Notice of Proposal?
- The service date and your 15-day hearing-request window
- Both addresses for your hearing request: the registrar and the Tribunal
- Whether an immediate suspension is in effect
Rules and resources to consult
- Condominium Management Services Act, 2015, ss. 41–45, 57–62 and 73
- The CMSA code of ethics regulation (s. 77) and the CMRAO code of ethics page
- Licence Appeal Tribunal – General Service forms, rules and practice directions
- CMRAO discipline and appeals decisions for comparable cases
Frequently Asked Questions
Can the discipline committee take away my licence?
No. Under the CMSA, the discipline committee can order courses, fines and costs (s. 58(4)). Suspending or revoking a licence happens through a registrar’s proposal and, if you request one, a Licence Appeal Tribunal hearing (s. 41).
The complaint is really about the board’s decisions. Why am I being investigated?
The CMRAO looks at the manager’s own compliance with the CMSA and its code of ethics. Show what the board directed, what advice you gave, and how you documented it.
What happens if I miss the 15-day deadline?
The registrar may carry out the proposal (s. 41(7)). Act immediately if you are close to or past the deadline.
Sources
Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.
- Condominium Management Services Act, 2015, S.O. 2015, c. 28, Sched. 2, ss. 41, 43–45, 57–58, 73 — e-Laws consolidation period beginning January 1, 2023; checked November 10, 2026.
- Licence Appeal Tribunal Act, 1999, s. 11 (CMSA listed) — Checked November 10, 2026.
- CMRAO, “Complaints Process” (for condominium managers) — Checked November 10, 2026.
- CMRAO, “Code of Ethics” — Located November 10, 2026; not reviewed in detail.