FSRA Consumer Advisory Panel
December 5, 2023
Harvey Naglie, Vice-Chair
Chris M Robinson
Laura Tamblyn Watts, Chair
FSRA staff / presenters
Mark White, Chief Executive Officer
Glen Padassery, EVP/ Policy, Auto Insurance
Mehrdad Rastan, EVP, Credit Union and Insurance Prudential
Stuart Wilkinson, Chief Consumer Officer
Antoinette Leung, Head, Financial Institutions and MB Conduct
Dan Oprescu, Head, Credit Union and Insurance Prudential
David Maxwell, Head, Regulation and Strategic Initiatives
Dan Miles, Director, Corporate Communications
Daniel Padro, Director, Credit Union and Insurance Prudential
Tim Miflin, Sr. Manager Insurance Policy
Stephanie Appave, Director, Innovation
Andrea Foy, Sr. Manager, Licensing & Title Protection Policy
Andrea Wooland, Sr. Manager, Corporate Communications
Amber McNair, Sr. Manager, Credit Union Policy
Stephanie Babb, Sr. Manager, Corporate Communications, PA
David Ha, Sr. Manager, Regulatory & Credentialing Oversight (A)
Jesse Heath-Rawlings, Sr. Manager, Pension Policy
Robert Prior, Sr. Manager, Life & Health Insurance Agents
Leticia Cooper, Sr. Advisor, Communications
Sarah Wilson, Sr. Advisor, Communications
Jennifer Chan, Sr. Policy Analyst and Technical Lead (A)
Jisha Sarwar, Sr. Policy and Technical Lead, CO
Diana Green, Sr. Policy Analyst, CO
Lumi Simpson, Sr. Policy Analyst
Olivia Lee, Administrative Coordinator, Policy
Leanne Westcott, Executive Assistant
Dillon Byrd, Project Assistant, Policy
Nicole Sherwin, Public Affairs Coordinator, Public Affairs
- The Panel shared its views on the conduct of life and health insurance companies and agents following FSRA’s recent publications on that topic.
- FSRA presented to the Panel about its Risk Based Supervisory Framework for Credit Unions.
- FSRA highlighted its upcoming educational campaign plans for 2024.
- FSRA provided the Panel with an overview of the results following its 2023 stakeholder survey.
- FSRA presented to the Panel about its Financial Planners and Financial Advisors Supervision Plan results in 2023 and Supervision Plans for 2024.
- The Panel presented updates on Panel’s Working Group’s activities specific to the development a registry for Financial Planners and Financial Advisors.
- The Panel discussed the outcomes of the Consumer Advocacy Meetup it held in November 2023.
Item 1: Welcome and introductory
- The Vice-Chair delivered a Land Acknowledgment.
- The Vice-Chair welcomed all Panel members and provided an overview of the agenda.
Item 2: Recent insurance supervision activity: Tiered recruitment model and universal life sales
- A Panel member offered a brief overview and introduction to the regulations governing life and health insurance in Ontario. He highlighted deficiencies and issues within these regulations that potentially expose consumers to exploitation. Several problems were pointed out and confirmed through FSRA's 2019/2020 Market Conduct Summary Report of Life Agent Reporting Form (LARF).
- The Panel suggested FSRA should increase consumer education related to life and health insurance. Clearly describing industry expectations based on principles and outlining specific details for consumers regarding the quality and type of services they should anticipate when dealing with insurers or their representatives would be beneficial in enhancing consumer protection.
- FSRA mentioned that the organization has implemented several measures to enhance consumer protection and ensure industry compliance:
- It is publishing conduct related information on licensed agents and agencies, encouraging compliance by leveraging public opinion.
- It published guidance clarifying the responsibilities of the insurers for their agents and delegates in matters of conduct, training and education (Fair Treatment of Customers in Insurance)
- It strives to provide guidance that includes expectations related to desired outcomes based on the conduct principles.
- FSRA encourages the Panel to make submissions on public consultations, including the current consultation on Life Insurance Agent & MGA Licensing Suitability which launched on November 21, 2023 and will close on February 9, 2024, and provide input on ways to promote consumer protection in life and health insurance.
Item 3: FSRA’s call for members
- FSRA provided a brief update on the publication of the Call for Members, and the deadline for submitting expressions of interest.
Item 4: Credit union and insurance prudential Risk Based Supervisory Framework
- FSRA presented the principles of their Risk Based Supervisory Framework (RBSF), including an overview of the approach to the framework, its implementation, and the desired outcomes.
- Supervision includes all types of interactions with the credit unions, which are considered during the evaluation and assessment of risk, making it an integrated approach to risk rating.
- The purpose of the framework is to achieve successful outcomes; prevent the possibility of a financial loss to depositors, and protection of consumers.
- FSRA stands out as one of the few regulators in Canada using an integrated risk framework.
- The goal of the framework is to create accurate, persistent, and consistent risk ratings.
- Risk ratings are subject to independent panel review consisting of senior level expertise outside of the initial assessment.
- The Panel pointed out the social role credit unions play in addition to their financial and business activities.
Item 5: Public affairs update
Consumer education campaigns
- FSRA highlighted the milestones in its education campaigns plans for early 2024.
Stakeholder survey results
- FSRA presented the 2023 stakeholder survey results. The survey was conducted online including a combination of industry and consumer stakeholders from FSRAs distribution list. The following highlights were presented:
- Positive perspective on FSRA’s leadership team and admired strong executive leadership.
- FSRAs reputation is favorable.
- FSRAs engagement with stakeholders is meaningful, responsive and reactive to feedback.
- FSRAs lacking enforcement powers create difficulties in fulfilling the brands promise of protecting consumers.
- Industry stakeholders have a more positive perspective about FSRA than consumer stakeholders.
- The Panel provided recommendations and comments on the survey for FSRAs consideration in conducting future surveys.
- The Panel proposed exploring collaboration with regulatory authorities as an opportunity to enhance awareness and education among seniors residing in retirement homes about pensions, aligning efforts around Pensions Awareness Day.
- The Panel suggested sending the enforcement press released to local MPP’s which work in the interest of their communities and can further communicate the information to the public.
- The Panel agreed that the most effective way to raise awareness is by mandating disclosure of the regulator on materials regulated entities distribute to their clients.
Item 6: Financial Planner /Financial Advisor (FP/FA) supervision plan
- In 2023 FSRA conducted an on-site examination of all the credentialing bodies to ensure they comply with the Financial Professionals Title Protection Act, Financial Professionals Title Protection Rule and the terms and conditions of FSRA’s approval. Examination focused on four key areas based on the supervision plan. Some of the outcomes of the examinations in the focus areas include:
- Ensuring compliance with legislation
- Protection of consumers through effective, fair, and efficient complaint handling process.
- Ensuring professional conduct in the sector; credential holders aware of obligation to put client’s interest first, and credential bodies have sufficient staffing and resources to ensure integrity of the credentialing program.
- Promoting transparency by publishing the aggregated results of these examinations.
- This year FSRA focused on oversight of credentialing bodies. Next year, the focus will be on ensuring entities whose employees use the Financial Advisor title bring their staff into compliance by obtaining credentials, using proactive web scans.
- The Panel noted its disagreement with the proposed approach for supervision next year. To address consumer protection the standards of title and conduct of the credential holders need to be raised, and addressed, as opposed to seeking out non-compliance in non-credential holders.
- FSRA responded that one of the reasons for the chosen approach is to gather information and evidence that will support future supervisory actions and to raise the standards.
- Additionally, one of the core elements of the Financial Professionals Title Protection Act is to direct consumers to using titled individual to receive better outcomes.
Item 7: FP/FA Working Group update - FP/FA Registry update
- The Working Group had the opportunity to test the FP/FA Registry and was pleased with the different search functionalities, and that the group’s previous inputs have been incorporated into the Registry.
- The Registry will be updated daily by the Credentialing Bodies and monitored by FSRA, who will take appropriate action as needed.
- The Panel recommends the Registry’s landing page be used for consumer education.
- The Panel commended FSRA on the development of the Registry and the planned implementation in an effective way.
Item 8: Consumer advocate meetup debrief / roundtable
- The Panel met with several consumer advocacy groups and organizations in November 2023.
- The Panel and the participants felt the meeting was effective and a start to potential future discussions. Future discussion can lead to sharing of information and knowledge and collaboration on common principles.
- The Panel expressed gratitude to FSRA for the support in hosting the meeting and is impressed with the consistent support it provides to further consumer interests through the Panel.
Item 9: Closing remarks
- The Panel has great interest in engagement on insurance matters. They will collaborate to draft a response to insurance consultations in Ontario.
- The Panels’ top priority is consumer education, identifying channels and approaches reach to consumers in a timely manner.
- Wednesday February 21, 2024, from 9:30am until 1:30pm – Virtual meeting