Registrar proposes to revoke Carnance Inc. and Sandy Hum a second time, alleging the $20,000 letter of credit their 2025 consent order required was never provided

The Registrar under the MVDA has proposed, for the second time since May 2025, to revoke the registrations of Carnance Inc., a dealer on Toro Road in Toronto, and Sandy Hum, its director and person in charge. The new notice of proposal is signed and dated September 15, 2026, and OMVIC’s enforcement table lists it with an issue date of September 16. Its first allegation is that the pair never provided the $20,000 letter of credit they agreed to in settling the first proposal. Everything in the notice is the Registrar’s allegation. The Licence Appeal Tribunal has not decided any of it, and on September 30, 2026 the table listed both rows as Active.

According to the notice, Carnance was first registered on or about August 10, 2020, Hum was first registered as a salesperson on or about November 19, 2018, and he has been the dealer’s director and person in charge since February 17, 2023 (paras. 1 to 3).

The first proposal, and how it was settled

The notice attaches the earlier record. On May 26, 2025, Deputy Registrar Thaya Gengatharan proposed to revoke both registrations after a September 2024 inspection (Schedule A). The new notice summarises what that proposal alleged: warranty payments not sent to the warranty provider on time in three sales, encumbrances in previous owners’ names not discharged on two vehicles sold to consumers, retaining the services of a salesperson who was not registered in that capacity, contrary to s. 4(3) of the MVDA, and missing purchase records on three vehicles (para. 6).

Carnance and Hum appealed on June 3, 2025. By July they had settled, and on August 5, 2025 Licence Appeal Tribunal Vice-Chair Geneviève Painchaud released a consent order, Carnance Inc. and Sandy Hum v. Registrar, Motor Vehicle Dealers Act, 2002, 2025 ONLAT MVDA 17186 and 17187 (Schedule B, [1] to [9]). The May 2025 proposal was not to be carried out, and both registrations continued on conditions. The notice quotes the central one (para. 9):

Within 120 calendar days of the Consent Order, the Appellants shall provide an irrevocable Letter of Credit in the amount of $20,000 in favour of the Motor Vehicle Dealers Compensation Fund

The letter of credit was to stay in place for two years from the end of registration or the dealer’s last retail transaction, whichever came first. The same schedule required Hum to pass the Key Elements course with at least 80 per cent within 90 days, and set a term on discharging encumbrances on vehicles the dealer sells.

The new notice says: “To date, Carnance and Hum have not provided the required Letter of Credit” (para. 10). The Registrar treats that as a breach of a condition of registration, which is its own ground for disentitlement under s. 6(1)(f) of the MVDA (paras. 11 and 61).

The HST records

The notice alleges a run of requests for HST records that were never met (paras. 12 to 24):

• A remote inspection on or about December 4, 2025 asked for the dealer’s most recent HST remittance records. The notice says Hum did not provide them.
• On or about March 19, 2026, the inspector asked for HST records for every quarter of 2025, with Notices of Assessment and Netfile confirmations, by March 23. Hum asked for an extension and was reminded the records had first been requested in December. They were not provided by the deadline.
• During the March 2026 inspection, the inspector told Hum that all outstanding HST filings, including those for 2023 and 2024, had to be filed with the Canada Revenue Agency, and reminded him that during the 2024 inspection he had said his accountant was working on the 2023 filing.
• On or about April 10, 2026, Hum wrote that Carnance was working with a third accounting firm, that the firm had told him Carnance would be entitled to an approximate refund of $82,000, and that the filing should be done within “7 business days”. He wrote the same day that the financial statements and HST materials were expected the following week.
• “To date,” the notice says, the documents have not been provided.

Each failure to produce is alleged as a breach of s. 15(4) and (5) of the MVDA. Section 15(4) lets an inspector require a person to produce a document or record, and the person “shall produce” it. The notice also relies on the dealer’s financial position under s. 6(1)(d)(i) (para. 60).

Six wholesale sales

The rest of the notice is about vehicles Carnance sold to one registered dealer, which it calls “GV”. A sale between two registered dealers is governed by s. 5 of the Code of Ethics, which lists what the selling dealer’s contract must disclose. In each case the notice says Hum signed the wholesale bill of sale for Carnance, and it alleges the following (paras. 25 to 57):

• A 2024 Mercedes Benz, which the notice calls a GCL, bought on or about February 7, 2026 on a bill of sale disclosing daily rental use and out-of-province registration, and sold to GV three days later without the daily rental disclosure.
• A 2024 Volkswagen Taos sold to GV on or about January 8, 2025 without disclosing daily rental use the records showed.
• A 2021 BMW X1 sold to GV on or about January 20, 2026 without disclosing that the estimated cost to repair its accident damage was $13,726.48.
• A 2021 Kia Seltos bought on or about December 24, 2025 on a bill of sale disclosing accident repairs of $22,427.12, a cancelled manufacturer’s warranty and painted or replaced body panels, and sold to GV six days later without those disclosures.
• A 2022 Mitsubishi RVR that Hum bought on or about November 27, 2025 on behalf of another dealer, Vault Motors, signing as purchaser, on a bill of sale disclosing accident damage over $3,000 and daily rental use. GV bought it from Carnance on or about December 4, 2025 without those disclosures. The notice adds that Hum has never been registered as a salesperson with Vault Motors, and it does not say how the car passed from Vault Motors to Carnance.
• A 2019 GMC 1500 bought on or about October 21, 2025 on a bill of sale disclosing accident repairs of $29,394.22, an unknown total distance, a cancelled warranty and structural damage or repair. Paragraph 55, under the GMC heading, says GV bought “the 2021 KIA Seltos” from Carnance on October 22, 2025, and paragraph 57 alleges the GMC’s facts were not disclosed. The notice does not reconcile the two.

Daily rental use, repair costs over $3,000, a cancelled manufacturer’s warranty, an unknown total distance and structural damage are each items on the s. 5 list (paragraphs 5, 16, 17, 3 and 8). The notice treats this conduct as Hum’s past conduct, disentitling him under s. 6(1)(a)(ii) and the dealer under s. 6(1)(d)(iii) (paras. 58 and 59).

A settlement condition as a ground

Carnance’s is not the only recent settlement built around a letter of credit to the Compensation Fund. In July 2026 the Patvivi Inc. and Patrick Nwandu consent order set one at $50,000, due within 90 days of the terms being signed. Carnance’s was $20,000 with 120 days. On the Registrar’s account, a condition of that kind that is not met becomes a ground for revocation under s. 6(1)(f), separate from the conduct that led to the condition in the first place.

The notice gave Carnance and Hum 15 days after service to ask the Tribunal for a hearing under s. 9(2). Without a request, s. 9(4) lets the Registrar carry out the proposal. With one, the Tribunal decides whether to carry it out, substitute its own opinion or attach new conditions (s. 9(5)).