Dealerships and leasing companies financing on their own paper have been FINTRAC reporting entities since April 1, 2025, and FINTRAC's stated first-year emphasis on outreach over enforcement ended a quarter ago, on April 1, 2026. The grace period is over. If you're in scope, the practical question isn't "what does the law say?" It's "if the notice letter arrived Monday, what would I have to hand over?"
FINTRAC examinations start with a document request, typically due back within a couple of weeks. The first wave is predictable:
- Your compliance program documents: the written policies and procedures, with the name of your compliance officer.
- Your risk assessment: dated, documented, and covering clients, products, channels and geography.
- Training records: who was trained, on what, when, with evidence.
- A sample of client files: identification records, screening evidence and transaction records for specific deals the examiner selects, not ones you pick.
Item 4 is the trap. The first three can be written in a determined weekend. The fourth can't: it either exists because you captured evidence when each deal happened, or it doesn't exist at all. And remember the obligations started April 1, 2025, not 2026: every in-scope deal you've closed in the past fifteen months is already part of the sample an examiner can pull from.
The test to run on yourself this week: pick three deals from last year at random and try to produce the full file (ID verification with method and date, screening result, and the signed contract) in under ten minutes each. If you can't, that's the gap to close first, not the policy binder.
For the full picture of who's in scope and what the five program elements are, start with our guide to the April 1, 2026 change, or run the free 12-item readiness checklist against your current setup.