Auto Insurance Take-All-Comers Requirements Consultation Summary | Financial Services Regulatory Authority of Ontario

Thank you to those who provided feedback on FSRA’s Take-All-Comers Consultation. This consultation is now closed, and all comments and submissions have been posted.

FSRA is committed to strengthening consumer protection related to auto insurance by ensuring availability, enforcing regulatory oversight and reducing regulatory burden. The Take-All-Comers Consultation received comments and submissions from consumers and members of the auto insurance industry, including brokers, insurance companies and trade associations, who brought forth valuable insight about current practices and recommendations to further protect Ontario’s auto insurance consumers.

FSRA’s administration of the regulatory regime includes the Take-All-Comers requirements, which was created to ensure that consumers have access to insurance by establishing certain “rules” that must be followed:

Insurers must offer a quote to all auto insurance consumers that meet their approved underwriting rules.
When consumers shop for auto insurance, insurers are required to offer the lowest rate available for each consumer’s circumstances.
Before an insurance policy expires, insurers are required to offer their customer a renewal if that customer continues to meet that insurer’s underwriting rules.

What FSRA heard:

FSRA heard from 25 brokers, five insurers, two industry groups, nine consumers, and one other stakeholder. Many brokers stated in their submissions that the existing process used by insurers for providing quotes and approving applications is often cumbersome, frustrating, and/or unfair. Examples of such practices include mandating unnecessary paperwork or using delay tactics in providing quotes or approving applications with the intent of discouraging or even in some cases making it practically impossible for customers from doing business with that insurer. Comments from consumers generally expressed frustration over rates and availability of coverage, and the lack of transparency around rates. Insurers and industry groups submitted comments regarding their processes around Take-All-Comers requirements, and a number of commentors made extensive recommendations addressing the regulatory framework for rate approval and Take-All-Comers.

The following instances of contraventions to the Take-All-Comers requirements have been noted in the submissions from brokers:

Withdrawing underwriting authority of brokers and agents
Failing to respond to requests for quotes from qualifying customers in a timely manner
Refusing to quote or renew for reasons not listed in the insurer’s approved underwriting rules
Failing to offer a renewal to qualifying customers including those who have missed a single payment
Requiring the completion of written applications from customers on a frequent basis and for reasons that cannot be characterized as exceptional and warranted by the risk presented

The following general themes were also identified under this consultation:

Lack of insurer regulatory oversight, monitoring/enforcement, or accountability
Ineffective and unnecessary regulation
Required legislative and regulatory changes, including amendments to Ontario Regulation 7/00 - Unfair Deceptive Acts or Practices (UDAP)
Support for Treating Customers Fairly framework rather than the current Take-All-Comers requirements

Next steps:

FSRA is currently conducting a review of the Take-All-Comers requirements and has partnered with the Registered Insurance Brokers of Ontario to explore issues with the way customers are treated. As part of the review, FSRA will be undertaking examinations of selected insurers chosen to ensure a representative sample of Ontario’s auto insurance market.

FSRA will review opportunities to address the concerns raised to ensure customers are treated fairly and access to affordable insurance is not impaired by misconduct in the auto insurance marketplace.

Disclaimer: After a full review of the submissions to the Take-All-Comers consultation, all names, company names and sensitive information from the original comments and questions have been removed.

All submissions

No.	Company	Individual	Comment
1		Broker	Hello, When I opened up the brokerage, I had contract from 5 insurance company and insurance company was one of them. 4 MONTHS after I got my contract with insurance company, they advised us not to send them business as they are currently doing some restructuring so in few months I had contract with them. Insurance company decided to cancel my contract for no apparent reason. When I questioned them, what was the reason, they didn't have any answers. This behavior to me seems like bully behavior, I had to move all our clients to another carrier and if someone had at fault accident and had forgiveness factor on it, we couldn't really help them. I REALLY WANT THE REGULATORS TO LOOK INTO THIS AND STOP THIS KIND OF BEHAVIOR FROM INSURANCE COMPANY.
2		Broker	The system is broken and nobody wins. This is where we are at currently. Here are the main issues directly and indirectly effecting "all comers". 1) The "all comers" rule has never been enforced. It has not been enforced by FSCO, it has not been enforced by RIBO. Everybody knows this. Let's not pretend otherwise. The regulators are part of the problem. 2) There is so much political downward pressure on insurance rates that insurers can rarely be rate adequate. When insurers submit rate indications for rate file approvals to FSCO/FSRA, and those indications are ignored, then the insurers have to resort to other means. In hard market situations, and sometimes soft market, insurers resort to draconian "secret rules" that go over and above their filed underwriting guidelines in their underwriting manuals. Everybody knows this. 3) Insurers exert pressure on their distribution, whether brokers or agents, to turn away business when they are rate inadequate. This forces brokers and agents to be creative in servicing, or not servicing, segments of clients. This is antithetical of course to what a broker or agent wants to do. We want to insure people. We are incentivized to insure people, it's how we earn a living. We are told by insurers we must send away business because it is not priced right. Send it somewhere else down the line. As markets close up distributors are put between a rock and a hard place. We either write the business and risk losing our jobs or losing insurer contracts, or we send clients away in a creative way so as to ensure we are not offside with "all comers" rule. This has been happening for decades and everybody knows this. 4) Online shopping and digital interaction with clients makes the situation even worse. As clients shop online on websites, including aggregators, they see an assortment of rates. a) Sometime the insurer "secret rules" are built into the underwriting filters on the quote. The good part about this is the client can purchase the quote they see online. The bad part is it is offside of all comers because of the "secret rules" kicking people out. b) If "secret rules" are not being implemented the consumer will see rates and offerings that they can't actually purchase. This is a bait and switch and a terrible experience for consumers. It has come to the point where insurers are now enforcing "secret rules" on unregulated aggregator websites. Insurers are using their considerable muscle as thug racketeers to enforce distributers and aggregators alike to disobey the "all comers" rule. As a broker we all receive these visits, these calls, these threats from insurers..â€¦.and everybody knows it. In conclusion, politicians are putting pressure on regulators to keep insurance rates low. Regulators put pressure on insurers to keep rates low, not allowing them to charge the adequate rate for the product. Insurers put pressure on distributors to send people away. Distributors put pressure on consumers to look elsewhere. Consumers put pressure back on politicians. It's a toxic circle that leaves distributors and consumers especially between a rock and a hard place. Distributors want to sell, consumers want and need to buy. Everyone else is stopping us and it's shameful...â€¦ and everybody knows it. What's needed is systemic overhaul. Until then it is disingenuous to try to enforce an "all comers" rule. Fix the system, don't try to find scapegoats. I find it appalling that a tip line might be setup to try and catch a young broker who is new to the business and put in a difficult situation by a system of regulators and insurers that are causing the problem. The problem is not finding a handful of wrongdoers. Everyone is involved, the whole industry....and everybody knows it.
3		Broker	In my opinion the majority of the insurance providers in Ontario and not applying the take all rules. Insurance company -if a client has a prior non payment . The broker has to complete and send them an unbound application and allow them 10 days to review and approve. They also impact the insured's driving record often no allowing more then a 5 star rating (more premium and loss of accident forgiveness) Insurance company is not quoting at all when we quote on our broker management system. If we do not get a quote for them then we have to print and send an unbound application in the mail (not fax , not scan) in the mail and they require 5 days to approve. They also impact the insured's driving record because of a non payment and the client losses driving record protector) Insurance company is the high risk provider of insurance company as soon as you put in a non payment they no longer quote risk not eligible. They can have claims, convictions etc and numerous ones but once a prior non payment it states risk not eligible . Insurance company will not quote a auto risk unless supporting property The facility market is the only market really open and using the take all. It is unfair that a great client with a no claims history, no convictions etc has to be insured with facility . The majority of the insurance brokers and sending the new business to them. Facility was set up as the last option for the client so that everyone has access and now it is just a non payment market.
4		Prefer not to say	Auto insurance companies such as insurance company, insurance company etc are flagrantly avoiding the all comers rule by placing huge restrictions on their brokers by modifying binding authority and work flows in order to avoid taking customer they don't want that will actually fit their filed rules. They are implementing procedures where certain people need to be review before being allowed to bind that don't fit what they want. Things such as non-payments, AB claims, Risks under a certain driving record or monoline customers are being forced to sign applications and submit for renewal BEFORE the company agrees to bind even though the risk fits their filed rules and the companies are taking 10 to 15 days to respond in hopes the customer will get frustrated and leave
5		Broker	I think some clarification is needed for the question for consumers that asks: "â€¢Did it take a long time to get a quote or did you never receive a quote after requesting one? " As a broker I personally find it difficult in the hard market we are experiencing to provide timely quotes to everyone who asks for one. The amount of disruption within the industry has displaced a lot of individuals and has forced even more to shop around bc of increasing rates. As you can appreciate, brokerages are not hiring extra staff to deal with these issues so the added workload makes it difficult to provide a timely quote. There are some markets out there that are requesting prospects to submit unsigned applications for quotes that could take a minimum of 2 weeks to process. Clearly this circumvention of their offerings is a sign that they don't want a particular piece of business thus making it difficult to obtain by having a potential prospect jump through hoops to even just get a price. These companies obviously cannot decline these risk bc they probably fit within their filed rules....but the hoops and obstacles they introduce for prospects to jump through either force the person to go look elsewhere or just doesn't leave them enough time to get an answer. Companies are also getting creative with changing rules and eligibility that has led to enormous increases. One specific example is how Insurance company who provide auto insurance have managed to get a rule passed that makes you ineligible for a multi vehicle discount if you have a minor conviction on your record. How fair is that? How does a conviction factor in on a discount geared towards having multiple vehicles insured with the company. That is unfair! The 2 criteria should not be leveraged against each other. So....my main issue with the all comers rule is relating to the timeliness of a quote. Considering the state of the market, it is getting difficult to meet such a vague statement. Thanks for your time! Broker
6			Auto insurance is mandatory in Ontario, and companies are very concerned about fraud. However, it is my belief that, in part, they are perpetuating the fraud issue by making auto insurance financially crippling. In the same vein, by offering such high limits, of course claims will increase in cost for the accident benefits because why shouldn't they?! It is unfortunate that in the society we are living in, people will take advantage of what is offered, whether it is necessary or not. And those of us who are not crap human begins have to pay to replenish the pot we will likely never use. Good drivers with clean records for several decades be penalized because of the current market. Experience means better rates, but the cost to get experience is the same price as buying the car in the first place. It seems that there have been many questionably ethical decisions made by insurance companies in the last little while. Companies are sending out long form, CSIO applications to insureds that have to be filled out correctly, and within a certain time period. If they are not received by the date, or if there is but one small error, they are denied renewal. Other insurance companies are barring brokers from writing auto business in certain areas because they believe the area to be "unprofitable" and "high risk", yet still offer competitive rates.
7		Broker	Hi As it relates to the Take-All-Comers, the spirit of this rule hasn't been followed for years. Over the last few years FSCO/FSRA has allowed the insurance companies to file rules that basically allow them to seriously restrict who they sell coverage to. I always joke that there is a filed rule to deny insurance for everyone but the joke isn't far from the truth. The filed rules that the insurance companies have been allowed to be put into place have really restricted the marketplace. Case in point, just look at how many policies are flooding into Facility these days. The entire auto system is broken and this one Take-All-Comers rule really isn't the big issue. There are a lot of things that need to be reviewed and fixed. Too many to list in this message. We need to have a simpler system. There are far too many rules/regulations/ underwriting criteria. Many of which don't make any sense.
8		Broker	The quote meets the Companies qualifications - underwriting rules - then Insurance Companies should not be able to say to us Brokers "please place this insured elsewhere, it's not a target market for us" ...but, the quote qualifies, so what's the problem - the quote complies with their underwriting rules.. Why are they allow to do that? the answer is - because they can......
9		Broker	I do not believe that insurers should ask for signed Applications to be submitted before we even know if they will accept the risk. Perhaps an unsigned Application with an appropriate turnaround time from the insurer with a yes or no, so the broker can move on and advise the consumer. A few of the companies are/were making it as difficult as possible for brokers to place business with them. I do feel that these barriers put in place by insurers are loosening up a wee bit.
10		Broker	We are a business that has been researching about in house underwriting for quite some time, with the struggle of how do you avoid bad risks but also offer them the quote within regulations. We are still having a hard time finding what that looks like, and when I do ask fellow industry members, or go on webinars, etc. It seems the common answer they are using is "we can't help you with this quote" or they actually refer them to a competing brokerage. We are always offering our best market for the client right now, but as a brokerage who has loss ratios to protect as well, have a hard time finding that communication and honestly feel it is a little unfair that some of these big successful brokerages are refusing to quote some clients.
11		Broker	Hello I have plenty of data to share that requires a telephone conversation , it is related to the take All - Comers Rules that impact consumers directly in a very devastating way, but there is also so much harm done to some Brokerages and their family by insurance companies in violation of that same concept of the All Comers Rules. some insurance companies don't even know what ethics is. New tough laws must be written in order to prevent such horrible behaviors from happening and in order to restore respect to the insurance industry. Regards Broker
12		Broker	I think a few insurers are setting up additional rules to refuse less desirable clients for quotes & binding for some time already. They are violators. FSRA should let insurers to set up its own price. Insurers should be more closely supervised to abide the rules & be penalized for violating the rules. The government should not take a blind eye for such violations just because they are big corporations.
13		Broker	No one will tell the truth unless we have complete anonymity. Frankly, the fact you do not have this in mind already tells me how ridiculous this exercise actually is. Fraud investigation of the fraud.
14		Broker	Awe at Brokerage treat all callers for Auto or property quotes with respect andd professional service regardless who is the caller.We ask same necessary ubdetwritobg questions and treat all caller in same and equal manner and approach.We have never experienced any situation from any of our insurers refusing to insure or quote a new comers.Neither any of our markets delayed or refused to insure any applicant who qualifies for insurance and meet acceptable underwriting rules or criteria..All are treated equally ni exclusions.
15		Broker	I 100% agree with All comers rule. Insurance companies are more often using their filed rules to avoid taking a new piece of business or offering renewal. They do what they have to do, but insurer is filled with rules so numerous and complex, quoting them takes a significant amount of time. The insurer refuse to help or guide brokers along to try and get a close to accurate quote. There are not enough quotes for any staff member to become an expert with all those rules and the remuneration for all the time it takes is very low. So as insurers tighten their belt, I feel the insurer must total refurbish how they do business.
16		Broker	When markets put restrictions on what we can write that are not filed rules. Having unrealistic guidelines for example no losses of any kind in 10 years, must write home insurance with auto same day and the list goes on. We understand that companies need to be profitable but having such restrictions make it hard to be helpful to clients. Markets threaten to pull contracts if brokers don't follow the "unwritten" rules for auto. What needs to happen is that the province needs to cap body shops, rehabilitation centers on what they can charge for MVA treatments.
17		Broker	I was recently appalled by the online social media actions of a insurer where they trolled their comments on their Facebook page and apologized to those who complained that they were sent an application instead of being quoted and were then sent the app back to say it wasn't filled out to the company standards and had therefore been rejected. To some this process happened a number of times before they abandoned their efforts. This sounded VERY frustrating. The company rep would apologize that they had that experience!!!! They would then state some nonsense that their goal is client satisfaction and ask that they message them off the public site for some promise of help. This is absolutely disgusting. The entire purpose of the application being mailed out process they use, is to frustrate the consumer, and provide them with EXACTLY this experience . There used to be a day where we wouldn't allow insurers to intentionally mislead the public. The provincial regulator should have teeth. They should not only have the ability to apply penalties to those who run afoul of the rules but also to penalize those that have avoided the intent of the rules by finding loopholes in the legislation. If you don't do that it will be a perpetual cat and mouse game.
18		Broker	The new filed rules with respect to "vehicle values" and "ages of vehicles" are making it increasingly difficult to places Coverage. Restricting physical damage or increasing Deductibles is logical but companies refusing to insure vehicles over 100K is proving very challenging. I recently struggled to place coverage for a LEXUS!!!!! NOT a Bugati, a Lexus due to a COMP rate group. Risks that should not be with FAC are ending up placed there due to no other avenue even when it is not logical. Hoping the climate improves soon!
19		Broker	Anyone reading back issues of Canadian Underwriter will understand my position on auto insurance in Ontario. In a few words - it doesn't work, and has failed to since the early '70's. My reason - you can't underwrite the brain of a motorist. That's as uncomplicated as I can make it. Your MVR's and AutoPluses will give you a story that is about as germane to establishing if an applicant is a good risk as wondering how long paint on a house will last. But why, since the '70's? Because up until then, there was an innocence in life generally and in insurance specifically. I know, I grew up in the business with them. I started with an insurer in 1952 (think 7 years after the end of WWII) as a reader of mail and the procurer of new dollars in the mail machine from the post office. Going into Auto, it didn't take long to realize that the main concern at the time was whether you were giving 5/10 and 1 or 10/20 and 5 for liability limits. If there were injuries from an accident, you heard very little of it except for whatever $1,000 of medical payments would buy (mostly first aid) which gave truth to the practice that the bandages were removed, the crutches discarded and you got on with your life. Catching up to recent times, the use of the FA for errant drivers had to be based on the notion that the more money a driver had to pay for insurance the more it would make him a better driver, never mind the financial responsibility factor and his desire to continue driving far exceeding the premium cost. It has been a rather unruly method of attempting to underwrite auto insurance and a failed attempt to apply the same disciplines of risk taking as though the subject of insurance were a building. The latter is as diametrically opposed to the former as it can get. Leaving the FA aside, underwriting regular auto business is an exercise in futility as how do you underwrite what a driver is thinking? A comprehensive study by the University of Western Ontario in understanding the mind of an accident-prone driver established that a man drives as he lives, further complicating an even minimal exactness of auto underwriting. The fact that brokers are invited to give their views on the current status of the subject speaks more volumes than even I could muster and goes to showing that auto insurance continues as a problem. Get Accident Benefits to the H&A handlers, move the first $200,000 of Liability to the government as a utility and accept auto insurance as more pure "automobile insurance" i.e. vehicle insurance. If I fall off my ladder cleaning out my roof gutters, I can't claim for injuries under my house insurance and the same for falling down my basement stairs (at this point I'm probably beyond insurable) but I believe I'm making my point clear. We 're continuing to stack a bunch of coverages under what used to be an uncomplicated matter of insuring an auto. Control P/L with premiums based on the business principle 'if you want it, you pay for it' and let high deductibles be a truer measure of risk. Letting the recklessness of driving being transferred onto someone else with little account is the reason auto insurance has been doomed. Time to make things right. My comments are solely mine and in no way reflect the opinions, considerations and view points of the brokerage.
20		Broker	I have another comment to make. My earlier opinion aside, I believe what could make the delivery of auto insurance a more palatable occurrence is time, time the broker spends in determining the aspects of the risk beyond the usual fundamentals. In most cases of acquiring information, the applicant never sees the desk of the broker. From that standpoint alone, all underwriting can use is the basic trilogy; application, MVR, AutoPlus, and must conclude via coded formulation acceptance or declination. Whether a building or a 2018 Chevvy, principles of contract apply. But because auto insurance has become as routine as ordering a coffee at Tims, the elements that should be used for contracting an auto policy slip by. Auto or otherwise, the client should be in the broker's office. The opportunity now exits for eliciting information as adjunct to what is commonly expected and could boost the underwriting values of the risk. Personal observation forms essential levels of sincerity, factuality and fidelity, as in honor and probity. Now we can say in the remarks section of the application that we have gained witness to the character of the applicant and we can unreservedly offer our recommendation as to the viability of the client, despite the conviction for speeding 3 years ago and a minor accident approaching 6 years. That is the idealist's way of pre-underwriting 30 years ago but, unfortunately, not today. Now, it's strictly information given online for the formulation of a legal contract that is less about the applicant and more of numbers, dates and terms. And in another sense, one has to question the legality of offer and acceptance creating a contract between the insurer and the purchaser on information that is essentially computer generated. So as to the questions under the 3 bullets, we need first to return auto insurance to a pure insurance product, giving it an elevation of respect that will show it to be more than an assembly line product for the convenience of the times.
21		Broker	What reporting and oversight mechanisms are in place to support compliance with the Take-All-Comers rule? - There are currently no reporting or oversight mechanisms in place to support compliance with the Take-All-Comers rule at my brokerage. If I want to place a new business auto policy with insurance company that has 2 Not-At-Fault losses in the past 10 years, their manual states that I should be able to do so. However insurance company has told our firm that they will not accept risks that have more than 1 Not-At-Fault loss in the past 10 years. If I submit the application to our internal underwriting team, it will be rejected and I will be told to re-market the risk. How does your organization address instances of non-compliance with the Take All Comers rule? - My brokerage does not address instances of non-compliance with the Take All Comers rule. I have brought up time and time again that "internal underwriting rules" violate the insurance act, yet it falls on deaf ears. The rationale is that if we produce business that causes a high loss ratio, the insurance companies will cut our contracts. It has gotten to a point where any client from Brampton is now an internal referral, and the referral usually results in a decline. What changes to the Take-All-Comers rule would reduce the risk of consumer harm and/or sector instability? - The Take-All-Comers rule is fine, but the reporting channel and enforcement of it has been non-existent. Insurance companies and brokerages continue to codify ever tightening internal underwriting rules to bypass the Take-All-Comers rule. The solution would be a compliance hotline/inbox jointly staffed by RIBO/FSRA where brokers, agents, underwriters, and the general public can report non-compliance of the Take-All-Comers rule with a 3-4 business day turnaround time. Brokerages and insurance companies who continue to practice non-compliance should also incur fines and license suspensions.
22		Broker	To Whom It May Concern, I'm writing this anonymously because I do not want my real name to be on record. However, I have been a RIBO licensed insurance broker. The status of accessibility to auto insurance in Ontario has gradually worsen every year since I've entered this field; in writing this, I wish to provide feedback to the current state of affairs and highlight some of the practices that brokerages and insurance companies are employing to maneuver around the Take All Comers Rule. 1) When I was at insurance company, they had a practice called "paper app-ing" in which their system will automatically generate a message that says "paper application required". If this happens, the agent is instructed to not provide an instant quote and the client has to go through a 2-3 week process where they must snail mail a completed OAF1 to insurance company. Any mistake in completing the OAF1 will result in insurance company sending the application back by mail and requesting the customer to properly fill it out. This cumbersome process is used to create as much delay as possible so the customer eventually gives up. I have friends at insurance company who tell me that this practice still exists today. 2) My current brokerage has internal underwriting rules dictating what type of risks we can place with our contracted markets, no matter what the filed manual rules are for that insurance company. This is not an exhaustive list but these rules do contradict the filed manual rules of the insurance companies. Some of these rules are set by the brokerage, like the no mono-line auto rule, and some of these rules are set by the insurance companies. Because of these rules, I often violate my fiduciary duty to the public because I am unable to place my client to the company with the lowest premium and best coverage, even when I check the company's manual and the risk falls within the filed risk criteria. To summarize: both brokerages and insurance companies implement cumbersome bureaucratic processes and off the record rules in order to skirt Section 2(1)(8) of Regulation 7/00 Unfair or Deceptive Acts or Practices (“UDAP”). These pervasive and discriminatory practices ensure that insurance companies get to pick and choose the best in class risks and leave everyone else out to dry. Licensed brokers and agents are forced to violate the Insurance Act everyday, leading to the continuous erosion of public trust in the insurance industry and its professionals. Thank you for your time, Concerned Broker
23		Broker	Curious as to why the FSRA is asking these types of questions, when for the past 5 quarters, it has allowed car insurance premiums to rise on average 3-4% every quarter. Should it, instead, be asking how best to apply insurance increases, to who and when?
24		Consumer	I read the article about unfair rules to auto insurance and think something needs to be done about it. I have been quoted an obscene amount for auto insurance because my previous insurance was out of Canada, even though my Canadian license had no record of tickets. My son has been paying for insurance since he was 18 and has not been given a discount in over 5yrs, they just keep saying hes a young male. There is no care to his record. Car insurance is mandatory, people should have regulations that help them achieve car ownership, not be punished. There is no one whos perfect in life, some of the most successful people are where they are because of learning. Car insurance companies have too much power over people's freedom to drive(its not really a freedom) Tax payers should be better taken care of, it needs to change
25		Consumer	To answer your questions 1. I was almost denied insurance by insurance company because of a scratch on my car. They said they would only give me liability insurance and not comprehensive and I need this for my car. They ended up increasing my deductible from $1000 to $2500 instead until I get the scratch fixed! And send them pictures! Before I switch to insurance company I had insurance company who told me they had to cancel because they were not aware I drove for a living and they did not provide business insurance. I was never asked until a questionnaire went out and I answered yes I did drive for a living! When I went with insurance company it took two hours to get a final and very high quote from them!!! Two hours.
26		Consumer	I just can't believe how insurance company (s) continue to gauge customer who have/has a no claims/accidents of automobile coverage. It seems the government can't do anything about and it, as if the insurance company have the government under control in regards to auto insurance coverage for people with good driving records.
27		Broker	Insurance company seems to be not wanting to renew policies that should be renewed. Right now I have an issue with them: They will not accept a risk for a car as the driver is 28 yrs old, is insd on his parents policy as a principle driver on one car and clean. They insure the family home and 3 cars currently. Filed rules do not negate them from writing this. They "prefer" not to and say no. I am still working with them on this.
28		Consumer	this industry is so poorly regulated the governments refusal finding insurance should not be this difficult. iv dropped of 20 or more applications for insurance iv only heard back form one company who refused to write the policy the interesting part of this is that it's technically a violation of the compulsory automobile insurance act not that it matters as agents and brokers could never be charged for refusing to provide quotes with the act as theirs not set time line now i know what the price is as you can do your own quotes with FA however FA will not write the policy directly acquiring insurance should not require holding a broker hostage and as stupid as it sounds that basically my only option i live in london however iv contacted brokers from from toronto,windsor,chatham,kitchener, st thomas,cambridge,exeter finding something i'm legally obligated to buy should not be this difficult
29		Broker	1) What reporting and oversight mechanisms are in place to support compliance with the Take-All-Comers rule? -There few oversight mechanisms that support compliance with the Take-All-Comers rule. For example: FSRA in the past year has approved underwriting rules that appear to violate "Non-Renewal Risk Due to Broker Cancellation memo# No. A-4/91] Auto â€“ B Property & Casualty". 2) How does your organization address instances of non-compliance with the Take All Comers rule? -Address the issue directly with the insurer, and let the client know their options 3) What changes to the Take-All-Comers rule would reduce the risk of consumer harm and/or sector instability? -FSRA should abide by its own memos when approving underwriting rules. -FSRA should ensure memos and rules are pushed to the relevant insurance sector instead of leaving them on their web page hoping they will be read. (This could be email, training, etc.) - 'Technical Notes for Underwriting' should be published in every manual, as not many people know they exist. Underwriters have interpreted their approved rules in ways that contravene the Technical Notes for Underwriting. (For example, rebuilt vehicles) -Publicly provide clear direction on how unfiled rules may be used to deter business: If insurers are using unfiled rules to deter business there should be an approved framework. Currently it does not appear insurers have been given direction about how business may be deterred. Having a clear framework for unfiled rules will help the public to be treated within an accepted standard much the same way as the filed underwriting rules. -Some insurers remove their quote from the list of quotes provided in broker's quoting software, and require it to be requoted in their system. Many times when insurers do this, the broker does not have time to requote the same information in the insurer's system. This practice should be prohibited. If an insurer regularly supplies quotes through a quoting vendor then they should not be able to withhold the quote to deter business. -Whistle-blower/Complaint resolution: if an underwriter/broker/agent/industry participant goes to bat to address issues of apparent non-compliance then there should be sufficient discouragement against anyone penalizing that person/entity. The insurance system should encourage actions that seek to clarify how it operates, and hold its actors to the standards that are set. For example, there is a real fear that making constructive comments like the ones above could stunt peoples careers/lose business. That fear should not exist.
30		Consumer	The auto insurance sector requires significant reform, particularly as it pertains to dispute resolution and the independent examination (insurer examination) process. As highlighted by FAIR and other organizations, the system is broken and does not serve the interest of injured Ontarians. The current system leads to costly delays and litigation, delayed treatment for those who have sustained injuries, "dumping" of injured persons onto the OHIP system after limited insurance benefits have expired, and unnecessary disputes stemming from the insurer examination process. All of this does not serve the interest of the two stakeholder groups for which government policy should be directed, namely ratepayers and those legitimately injured as a result of automobile accidents in Ontario. I have attached several documents which highlight the current problems with the dispute resolution system and insurer examinations. The solution will require a rostering of qualified health care professionals with expertise and training in independent examinations, with an emphasis on professional peer review assessments.
31	Desjardins General Insurance Group	Christian Jobidon	Please find attached the comments from Desjardins General Insurance Group to FSRA's Take All Comers rule consultation. Please feel free to contact us if you should have further questions. Thank you.
32	The Wawanesa Mutual Insurance Company	James Bond	Attached is the Wawanesa submission responding to questions posed to licensed entities concerning FSRA's consultation on the Take All Comers Rule.
33	Aviva Canada	Erica Kelsey	Please see attached submission - thank you.
34	Canadian Association of Direct Relationship Insurers	Catherine Allman	Please find attached CADRI's response to FSRA's call for comments on the Take-All-Comers Rule.
35	Insurance Bureau of Canada	Ryan Stein	Good morning, Attached is Insurance Bureau of Canada's response to the consultation on the auto insurance take-all-comers rules. Regards, Ryan
36	AllState	Angie Morris	Please find attached.
37	Intact Insurance Company	Julie Nolette	Please find attached.

No.	Individual	Question	FSRA Response
1	Consumer	Where can i find a list of all "Take All Corners" rules?	Take-All-Comers refers to three main requirements under the Insurance Act: Section 237 prohibits insurers from declining to issue, terminating or refusing to renew an auto policy or endorsement on any prohibited grounds set out in the regulations; Section 238 prohibits insurers from declining to issue, terminating or refusing to renew an auto policy or endorsement, except on grounds filed with FSRA; and Section 2(1)(8) of Regulation 7/00 Unfair or Deceptive Acts or Practices (“UDAP”) requires insurers to provide consumers with the lowest rate available when it receives a request for a quotation for automobile insurance, an application for automobile insurance made to an affiliated insurer, or an offer by an affiliated insurer to renew an existing contract of automobile insurance, in accordance with the insurer’s declination grounds and approved rates and risk classification systems.
2	Broker	Not sure but I though I would mention, we have a couple of insurance companies that require an undated, signed application to be submitted for their approval of binding, in some instances this can take 3-6 weeks before the insurance companies let us know if we are able to bind coverage. For some insurer referrals required documentation includes: Fully completed and signed CSIO application, Supporting MVR's & Autoplus (ordered through your brokerage account, not Insurer's account) All endorsements that require a signature must be signed and attached. Once they review the application and documentation, they'll advise of approval to bind policy. These rules have held up clients from being insured right away and made it difficult for brokers. Not sure if this is what you are referring to with the All Comers Rule	Thank you for your input. The issues you have raised in your comments are related to the Take-All-Comers Requirements.
3	Consumer	Is there a means to address current auto insurance issues by insurance professionals, to any standing committee of FSRA ? This issue is of extreme importance that brings in many facets of the auto insurance process and policy, and simply writing comments does not give it any room for serious credibility. XXX-XXX-XXXX	The Financial Services Regulatory Authority of Ontario (FSRA) has established a Consumer Advisory Panel. More information is available at: https://www.fsrao.ca/consumers/consumer-advisory-panel/summary-comments-proposed-terms-reference-new-fsra-consumer-advisory-panel
4	Consumer	I can not get a quote for vehicle insurance. I have had a license and paid insurance for over 20 yrs. I have 1 violation on my on my abstract from 2.6 yrs ago. The violation is now considered a major as it wasn't back then. It comes off my license in sept. Also got cancelled this last mth from Insurance Company for missed payment but my payments were only late, not missed and a third thing is a claim from over 6yrs ago. I have zero demerits. Why can I not get insured?	Based on your risk characteristics , you may not qualify as a result of an insurer's approved Underwriting Rules. As there is a requirement for automobile insurance in the Province, there is an association known as the Facility Association, for policyholders that are unable to obtain insurance in the regular or standard marketplace. However, you are encouraged to continue to shop around.
5	Consumer	Should insurance companies be allowed to block brokers from obtaining quotes for clients that clearly fall within their filed rules, and request a paper application be submitted for a quote and binding approval?	Thank you for your input. When consumers shop for auto insurance, insurers are required to offer the lowest rate available for each consumer’s circumstances. Before an insurance policy expires, insurers are required to offer their customer a renewal if that customer continues to meet that insurer’s eligibility rules. Insurers must accept all of the auto insurance business from consumers that meet their approved underwriting rules. This is a part of “Take-All-Comers Requirements” under the Insurance Act.

Consultation

2020-004: Auto Insurance Take All Comers Rule