Upcoming Expiry of Transitional General Licences
Transitional General Licences are a time-limited class of licence for condominium managers originally introduced in 2017. Under section 16 of Ontario Reg. 123/17, “a Transitional General Licensee may not apply for a renewal of the licence or reapply for the licence after May 31, 2022.”
Currently, there are 3,899 licensed condominium managers in Ontario (as of March 22, 2022), 242 of whom hold a Transitional General Licence.
Any individual who holds a Transitional General Licence and intends to apply for a General Licence must ensure that the CMRAO receives their General Licence application, including all supporting documentation, no later than May 31, 2022. This allows time for the CMRAO to review the application and issue a decision. General Licence applications can be submitted online through the user account portal on the CMRAO website.
If an individual’s Transitional General Licence expires and the individual does not hold another active licence with the CMRAO, that person will no longer be able to provide condominium management services in Ontario.
If a Transitional General Licensee does not expect to complete the education requirements for a General Licence before their Transitional General Licence expires and they intend to continue providing condominium management services, they may apply for a Limited Licence. However, following are some of the limitations for Limited Licensees:
- Can provide condominium management services only under the supervision of a person who holds a General Licence.
- Can provide condominium management services only under the employment of a licensed condominium management provider business.
- Cannot act as a Principal Condominium Manager for a licensed management provider business.
- Must abide by all conditions of a Limited Licence outlined on the CMRAO website.
Impact on Condominium Management Provider Businesses
In accordance with section 49 of the Condominium Management Services Act, 2015 (CMSA), every condominium management provider business must designate a licensed condominium manager as its Principal Condominium Manager (PCM). In accordance with section 31 of Ontario Regulation 123/17, the PCM must hold either a General Licence or a Transitional General Licence.
It is recommended that provider businesses follow the following steps prior to the CMRAO’s upcoming licence renewal period:
- Review your list of licensees to identify who currently holds a Transitional General Licence
- Appoint a new PCM who holds a General Licence if your current PCM holds a Transitional General Licence
Provider businesses are further reminded that they are responsible for ensuring that all condominium managers under their employment are licensed by the CMRAO.
Impact on Condominium Corporations
Condominium boards may take the following steps to ensure that they do not have a gap in service:
- Contact the management provider business (or manager, if directly employed by the corporation) if their manager holds a Transitional General Licence to discuss whether the manager expects to obtain a General Licence before their Transitional General Licence expires.
- Check the CMRAO’s Public Registry, which lists each manager licensed by the CMRAO, to verify the class of licence their condominium manager holds.
Condominium boards should be aware of the following in the interest of consumer protection:
- Every condominium manager must be licensed by the CMRAO
- Every condominium management provider business must be licensed by the CMRAO and must appoint a Principal Condominium Manager
- Condominium managers with a Limited Licence can provide condominium management services only under the supervision of a person who holds a General Licence and under the employment of a licensed condominium management provider business (they cannot be employed directly by a condominium corporation)
CMRAO staff are available to provide assistance to condominium managers, provider businesses, and condominium boards. Please contact the CMRAO with any questions or requests for additional information.