Very interesting. I'm not certain I can answer you. as this is a very specific question in a very specific field, which if you're going to make this your business you should consult with an accountant and lawyer of your own. You don't want to rely on an anonymous lawyer online for this information. When CRA comes knocking, you won't be able to say "Ulysses101 on that website said it was okay".
So, you're looking to be a middleman, to arrange loans with your customers, and match them up with a lending institution? Presumably, you'll be able to charge greater interest and penalties to your customers, but get a decent rate yourself because of your situation.
It sounds good on paper, but I have concerns. What research have you done on the topic?
If this is your basic business plan, it seems legit. There are private mortgage brokers and consultants who do the same thing, but with some security. There are lots of payday loan and short term loan companies out there. But the former only make money when the second or third mortgage defaults and then the company gets the penalties after they force power of sale, and the latter on make money by charging enormous interest rates, just short of usury.
Private individuals make money off of offering private mortgages. I know a couple of real estate lawyers who set up private mortgages for a small fee, and the lender either makes better than the market, or much better if the borrower defaults or remortgages. However, in the event of a housing bubble bursting they are screwed. I'm curious as to your business model.