Consumer Advisory Panel Members in Attendance
Laura Tamblyn Watts
FSRA Management in Attendance
Mark White – CEO
Caroline Blouin – EVP, Pensions
Tim Bzowey – EVP, Auto/Insurance Products
Guy Hubert – EVP, Credit Union and Prudential
Huston Loke – EVP, Market Conduct
Glen Padassery – EVP, Policy and Chief Consumer Officer
Stephen Power – EVP, Corporate Services
Jordan Solway – EVP, Legal and Enforcement
Randy Nanek – Chief Financial Officer
Judy Pfeifer – Chief Public Affairs Officer
David Bartucci – Director, Policy – Pensions
Joel Gorlick – Director, Policy – Market Conduct
Melissa Hogg – Director, Corporate Communications
Marlena Labieniec – Director, Policy – Innovation Office
Daniel Padro – Director, Policy – Credit Union
Taryn Pimento – Director, Policy – Consumer Office
Elissa Sinha – Director, Litigation and Enforcement and Deputy General Counsel
Stuart Wilkinson – Director, Policy – Auto/P&C
Andrew Fung – Head, Pensions – Relationship Management and Prudential Supervision
Wendy Horrobin – Head, Licensing and Risk Assessment Branch
Antoinette Leung – Head, Financial Institutions and Mortgage Brokerage Conduct
Jennifer Rook – Head, Pensions – Pension Operations and Regulatory Effectiveness
Swati Agrawal – Senior Manager, Market Conduct – Licensing and Market Conduct Division
Tim Miflin – Senior Manager, Policy – Financial Planners/Advisors
John Slowakiewicz – Senior Manager, Policy – Strategic Policy
- The Panel and FSRA discussed FSRA priorities and activities, including FSRA’s Proposed FY2021-22 Statement of Priorities.
- FSRA sought the Panel’s advice on FSRA’s approaches to protecting consumers of the regulated sectors. Specific initiatives included Unfair or Deceptive Acts or Practices (UDAP) Rulemaking, case prioritization and enforcement transparency, the FSRA Insurer-MGA Relationship Review, and Non-Qualified Syndicated Mortgage Investments.
- FSRA committed to following up with the Panel to discuss FSRA’s current approaches to engaging the Consumer Advisory Panel and opportunities to further strengthen the model.
Discussion Topics of Focus
Welcome and Meeting Overview
- FSRA welcomed Panel members to the third official Consumer Advisory Panel meeting.
- FSRA expressed its appreciation to the Panel for their time and efforts, including co-hosting with FSRA a recent consumer engagement meeting series on the proposed Financial Professionals Title Protection Framework.
- FSRA provided a brief overview of the agenda for the meeting.
FSRA FY2021-22 Priorities and Budget
- FSRA provided an overview of its Proposed FY2021-22 Statement of Priorities, including cross-sectoral and sector-specific priorities, key deliverables and anticipated outcomes.
- Panel members provided preliminary thoughts and noted that they would review the Statement of Priorities further to provide additional feedback, as relevant.
FSRA Service Standards
- FSRA provided an overview of its Proposed Service Standards, which were posted on September 24, 2020, for a 30-day public consultation.
- FSRA provided a snapshot of the 22 service standards and the process through which it arrived at the proposed standards, including the development of principles and best practices research.
Unfair or Deceptive Acts or Practices (UDAP) Rulemaking
- FSRA provided an overview of FSRA’s two-stage process for transitioning to a UDAP Rule and more principles-based regulatory approach.
- The Panel and FSRA discussed what innovation could look like in the context of the insurance sectors, and the potential benefits and trade-offs for consumers.
- FSRA requested feedback from the Panel on FSRA’s two-stage process, how CAP members should continue to be engaged on this initiative, and whether there are other issues FSRA should consider in the context of this initiative.
- The Panel asked FSRA to carefully consider the privacy-related implications for consumers as the UDAP work progresses. The Panel requested that FSRA return to the Panel with more information on specific consumer issues identified through research.
Case Prioritization and Enforcement Transparency
- FSRA provided an overview of its approach to enforcement in the context of principles-based regulation.
- FSRA discussed the application of its new prioritization rubric to consistently assess and manage cases for compliance action, in line with FSRA priorities.
- FSRA provided an overview of a new approach to enhance transparency for enforcement actions. This new approach includes:
- Providing the public with a better understanding of enforcement proceedings through enhanced web content.
- Posting publicly a range of enforcement actions, including actions taken at the early stages of intervention.
- Increasing awareness of enforcement actions by promoting information through news releases and other mechanisms.
- Panel members suggested that in developing content, FSRA consider multiple audiences (e.g., industry, the public, other stakeholders). Panel members also reflected on the importance of timeliness in effective enforcement.
- FSRA requested feedback from the Panel on:
- what types of information would be most important to consumers and how it should be presented;
- whether particular types of enforcement proceedings and trends would be of interest; and
- whether enhanced transparency could impact consumers’ privacy, attempts to recover losses, or willingness to make complaints.
- Overall, the Panel noted that FSRA’s new approach is timely, and that further efforts are required to strengthen transparency for consumers (e.g., consistent use of plain language in web content).
- Individual members noted that they would provide additional advice to FSRA following the meeting.
- FSRA confirmed that it is working to improve the readability of web content and make more information available to the public.
Insurer-MGA Relationship Review
- FSRA provided an overview of FSRA’s Insurer-Managing General Agents (MGA) Relationship Review, which is anticipated to:
- gain a more in-depth understanding of the Insurer-MGA relationship;
- assess effective governance and risk management of MGAs;
- identify potential gaps in roles and responsibilities between the insurance company, MGAs and independent agents; and
- set expectations to protect consumers.
- FSRA provided an overview of the relationship review approach, including consumer inputs and considerations to date, and discussed next steps.
- Panel members were pleased to hear about FSRA’s efforts to explore this issue.
Non-Qualified Syndicated Mortgage Investments
- FSRA provided an overview of FSRA’s work on Non-Qualified Syndicated Mortgage Investments (NQSMIs), which has two primary objectives:
- Investors receive adequate and timely information to make investment decisions.
- Mortgage brokerages appropriately assess suitability of a NQSMI to an investor.
- FSRA requested that the Panel provide any additional feedback, via email, on whether there is anything else FSRA could be doing to protect investor consumers.
- FSRA noted next steps for the Panel, including plans to engage Panel members in a discussion on how to continue to strengthen FSRA’s consumer engagement efforts.