FSRA Consumer Advisory Panel

Meeting 5 – February 21, 2024
Meeting notes

Panel members

Harvey Naglie, Vice-Chair
Laura Tamblyn Watts, Chair
Chris M Robinson
Harold Geller
Julie Kuzmic
Rhona DesRoches
Sharon Altman-Leamen
Tood White
Zahir Dharsee

Regrets:

Krysta Nesbitt
Lucy Becker
Udia Umoette

FSRA staff / presenters

Mark White, Chief Executive Officer  
Glen Padassery, EVP, Policy/ EVP, Auto Insurance 
Jordan Solway, EVP, Legal & Enforcement
Judy Pfeifer, Chief Public Affairs Officer
Stuart Wilkinson, Chief Consumer Officer 
Chris Zolis, Head, Forensic Analysis and Investigations, Enforcement
Daniel Padro, Head, Policy - Core Regulatory 
Erica Hiemstra, Head, Insurance Conduct, Market Conduct
Joel Gorlick, Head, Cross Sectoral, Policy
Chris Georgakopoulos, Director, Auto Policy
Dan Miles, Director, Corporate Communications 
Elissa Sinha, Director, Litigation & Enforcement and Deputy General Counsel
Lucy Kang, Director, Policy - Market Conduct
Stephanie Appave, Director, Innovation 
Victoria Lesau, Director, Policy Credit Union, Insurance Prudential & Pensions
Andrea Wooland, Sr. Manager, Corporate Communications 
Jonas Schwab Pflug, Sr. Manager, Auto Reform, Policy
Michon Trapman, Sr. Manager, Digital Solutions, PA
Robert Prior, Sr. Manager, Life & Health Insurance Agents 
Stephanie Babb, Sr. Manager, Corporate Communications, PA
Tim Miflin, Sr. Manager Insurance Policy
Ashely Legassic, Sr. Media Relations and Digital Officer, PA
Carley Bellissimo, Sr. Advisor, Communications, PA
Diana Green, Sr. Policy Analyst, CO 
Haafiz Alibhai, Sr. Policy and Technical Lead, Policy
Jisha Sarwar, Sr. Policy and Technical Lead, CO
Melissa Grover, Sr. Policy and Technical Lead, Policy
Sarah Wilson, Sr. Advisor, Communications 
Stephen Knight, Sr. Advisor, Communications, PA
Olivia Lee, Administrative Coordinator, Policy 
Dillon Byrd, Project Assistant, Policy
Nicole Sherwin, Public Affairs Coordinator, Public Affairs

Summary

  • FSRA provided the Panel with an update on the planning preparations for the 2023-24 Annual Report, and 2024-25 term planning.
  • FSRA presented to the Panel its Supervisory Framework for Life Insurance Agents
  • FSRA provided the Panel with an overview of enforcement in a principle-based regulatory framework through a case study of ‘take-all-commers’.
  • FSRA walked the Panel through this year’s educational campaigns and their outcomes. 
  • FSRA updated the Panel on its Fraud and Abuse Strategy and Fraud Reporting Service Rule in the auto insurance industry. 
  • FSRA shared with the Panel its plans for an Auto Insurance Rate Comparison Tool.

Item 1: Welcome and introductory

  • The Consumer Office delivered the Land Acknowledgment. 
  • The Chair welcomed all Panel members and provided an overview of the agenda.
  • The Chair encouraged all members to attend the 2024 FSRA Exchange scheduled on March 4, 2024. If members are unable to attend, the event will be recorded and made available to the public.

Item 2: Environmental scan/roundtable

  • The Panel Chair indicated that the Ombudsman for Banking Services and Investments (OBSI) is moving ahead with binding authority. 
  • Ontario Securities Commission (OSC) renewed its service commitments following some consumer input, and they appear to be on track to meet them. 
  • The Panel Chair mentioned GBA Plus (Gender-based Analysis Plus) is used by many government organizations and regulators to inform their work. 
  • A Panel member discussed the findings based on data provided by Ontario Insurance companies in the 2022 Health Care Data Base report. 
  • The Panel asked to be updated on the results of the 2024 assessment of the Credentialing Bodies standards.
  • The Panel Chair will represent Canada in the International Association of Insurance Supervisors’ (IAISs’) annual consultations on consumer subjects. The consultations will inform IAIS’s plan for the next five years. Panel members are encouraged to inform the Chair of any topics they wish to bring to the attention of this forum. 
  • The Consumer Office provided an update on the new panel members selection process.

Item 3: Consumer Office updates  

  • The Consumer Office provided a brief update on actions taken following expressions of interest and follow up items identified in the December 5, 2023 meeting. These include:
    • Building the current meeting agenda in response to the Panel's interests.
    • Making improvements to the Panel's remuneration process.
    • Seeking the Panel’s feedback on topic specific consultations, such as 2024 Cross-Sectoral Survey.  
  • The Panel expressed interest in continuing a version of the Outreach and Partnerships Working Group to create connections with other organizations and enable collaboration and coordination of consumer interest initiatives.

Item 4: Foundational briefing on life agent supervision

FSRA presented the tools it uses to supervise life agents in Ontario. The tools are data based, leveraging existing technologies, in support of a proactive and risk informed approach to regulation. FSRA developed three tools to inform its supervision efforts:

  1. Examinations looking at an agent’s compliance using a questionnaire, files review, and interviews. The outcomes of examinations are communicated back to the industry for educational purposes and encourage transparency. FSRA works with the industry to make corrections in practices, as needed. 
  2. Life Agent Misconduct Report (LAMR) is used by insurance companies to report misconduct, including suitability reports. 
  3. The Business Practice and Compliance Questionnaire (BPACQ) is currently under development. 
  • The Panel was impressed by the ongoing and future initiatives aimed at supervising life insurance agents and companies. They provided several comments and suggestions, these include:
    • Turning industry best practices into required and enforceable standards. 
    • Requiring MGAs to submit misconduct reports similar to insurance companies.
  • The Panel expressed interest in raising the topic in a broader forum with other stakeholders to understand key consumer issues. 
  • The Panel expressed interest in a deep dive into the topic of life insurance in fall 2024. 
  • FSRA plans to release the life agent supervision report in the first quarter of 2024-25, with its findings made public.

Item 5: Enforcement in Principle-Based Regulation   

  • FSRA presented its approach to Principle-Based Regulation through a case study in the Property and Casualty sector, which lead to clarifications of the ‘Take-All-Comers’ requirements for Auto Insurance.
  • The Panel commented that principle-based regulation requires an inclusive approach. The regulated sectors need to commit to the outcomes and demonstrate to the regulator that the outcomes are achieved.  
  • The Panel remarked that this case study illustrates a lack of consumer awareness regarding the services they should anticipate.

Item 6: Consumer education campaign updates 

  • FSRA provided an update on the consumer education campaign conducted during this fiscal year.
  • The presentation showed static and dynamic visuals included in the campaign. Several visuals targeted specific multi-cultural content for the Chinese, Filipino, and South Asian communities. 
  • The campaigns included publications through paid media, earner media, and several sectors specific publications. The campaigns were rolled out for the following sectors: 
    • Life Insurance
      The campaign is scheduled to run for three months at the beginning of 2024, emphasizing the importance of finding the right fit and using licensed agents. 
    • Private Mortgages
      The campaign was rolled out in fall 2023 and continues through the end of the fiscal year. The campaign emphasized the importance of finding the right fit and making informed decisions. 
    • Pensions
      The campaign was rolled out on Pension Awareness Day through media push, distribution of matte story to Ontario Community Newspapers, social media, and a television interview with FSRA’s EVP of Pensions. The multi-cultural push included cultural media and a video by a Chinese influencer.
    • Financial Planners and Financial Advisors
      A new release will be released with the launch of the campaign in March 2024. The objective will be to drive consumers to the new Check Credentials Tool. 
  • The campaigns were rolled out in multiple stages: initial assessment of materials via light media exposure and focus groups, to be followed by broader dissemination of successful materials in the near future.
  • The Panel encourages FSRA to consider how it can leverage the members to elevate the message or reach broader media outlets. 

Item 7: Fraud and abuse strategy and rule update

  • FSRA presented an update on the development of a Fraud and Reporting Service Rule following an Ontario Budget commitment to understand the nature and extent of fraud in the auto insurance industry. 
  • The Rule aims to define the term ‘Fraud’ by taking a broad view of the term, including topics related to auto policy, sales of insurance products, and internal business processes. Based on the definition, FSRA will utilize technology to gather data from insurance companies, utilizing it to pinpoint root causes and trends for identifying potential actions.
  • FSRA will conduct a public consultation on the draft Rule and the Panel is invited to make an official submission.
  • The Panel expressed interest in holding listening sessions in early summer to gain insights into the topic and be able to provide well-informed input.

Item 8: Rate Comparison Tool 

  • FSRA presented a Rate Comparison Tool planned to be deployed in the summer. The tool will provide consumers with relative information about insurance rates. 
  • The tool aims to simplify the process for consumers to shop around and encourages them to engage with their insurer/agent by asking questions. 
  • The Panel suggested accessibility supports be integrated into the tool from early development and it to be translate to French.   
  • The Panel would like to get the opportunity to be part of the focus group testing the tool. 

Item 9: Closing remarks

  •  A Panel member noted FSRA's progressive approach to consumer protection, positioning it as a leader in Canada within the financial services regulatory space.
  • A Panel member indicated that during her service as a member she was impressed by FSRA’s willingness to listen and respond to the Panel’s interests. 
  • A Panel member expressed her appreciation for FSRA’s preparation of meetings and indicated her availability for future engagements.

Next meeting:

  • Wednesday April 3, 2024, from 9:00am until 12:00pm – Virtual meeting