FSRA Consumer Advisory Panel

Meeting 4 – November 12, 2024
Meeting Notes

Panel members

Laura Tamblyn Watts, Chair
Harvey Naglie, Vice-Chair
Chris M Robinson
Ellen Bessner
Julie Kuzmic
Leeann Corbeil
Lucy Becker
Ninette Ibanez
Peter D’Iorio
Terri Williams Kinghorn
Zahir Dharsee

Regrets:

Todd White
Udia Umoette

FSRA staff / presenters

Glen Padassery, EVP, Policy / EVP, Auto Insurance 
Jordan Solway, EVP, Legal and Enforcement 
Meghan Kilty, Chief Public Affairs Officer 
Stuart Wilkinson, Chief Consumer Officer 
Chris Zolis, Head, Forensic Analysis and Investigations, Legal 
Daniel Padro, Head, Core Regulatory Policy 
David Bartucci, Head, Pension Plan Operations & Regulatory Effectiveness 
Jelena Pejic, Head, Licensing and Risk Assessment 
Joel Gorlick, Head, Cross-Sectoral Policy 
Michelle Dodokin, Head, Auto Insurance Supervision
Sylvie Charest, Head, Pension Strategic Initiatives
Elissa Sinha, Director, Litigation & Enforcement & Deputy General Counsel  
Stephanie Appave, Director, Innovation 
Rhea Tubigan, Director, Planning and Stakeholder Relations, Pensions 
Victoria Lesau, Director, Policy – Credit Union, Insurance Prudential and Pensions 
Andrea Foy, Senior Manager, Licensing & Title Protection Policy 
Carley Bellissimo, Senior Manager, Corporate Communications
David Ha, Senior Manager, Regulatory & Credentialing Oversight 
Jesse Heath-Rawlings, Senior Manager, Pension Policy 
Rocca D’Angela, Senior Manager, Mortgage Brokers
Jisha Sarwar, Senior Policy & Technical Lead
Kirubel Abebe, Senior Policy and Technical Lead 
Karima Shajani, Senior Pensions Stakeholder Engagement Consultant
Sarah Wilson, Senior Advisor, Communications 
Diana Green, Senior Policy Analyst, Consumer Office 
Nathalia Morato, Market Intelligence Consultant, Policy
Nicole Sherwin, Communications Officer, Public Affairs
Dillon Byrd, Project Assistant, Policy

Ministry observer

Marlo Spence Lair – Director, Capital Markets & Agency Relations Branch, Ministry of Finance

Summary:

  • A Panel member presented a summary of a presentation provided at the Council on Licensure, Enforcement and Regulation (CLEAR) conference on consumer engagement in the regulatory space.
  • Panel members provided updates on their working groups’ activities, and participation in consultations with the Ministry of Finance (MOF).
  • Panel members provided feedback on FSRA’s Financial Planner / Financial Advisor (FP / FA) Framework review.
  • FSRA provided the Panel with a foundational briefing on its Pensions function.
  • FSRA updated the Panel on its call for new Panel members as well as its call for Chair and Vice-Chair candidates for the 2025-2026 term.

Item 1: Welcome and introductory

Item 2: CLEAR presentation – Practical and successful approaches to consumer engagement in regulation

  • A Panel member presented an overview of a recent presentation on approaches to consumer engagement in regulation that was presented at CLEAR’s 2024 Annual Educational Conference.
    • They talked about various ways regulators can interact with consumers (e.g., passive feedback, interactive participation, and collaborative co-creation), and examples of best practices.
    • Many regulators appoint a consumer representative on the board of directors, which is not as effective as a structured consumer advisory panel. FSRA is at the forefront of regulators when it comes to proactively engaging consumers, through the Consumer Advisory Panel and the creation of the Consumer Office.

Item 3: Working group updates

Complaints framework review working group

  • A Panel member gave an overview of the Complaints Framework Review working group meeting. The working group proposed several ways to improve complaint processes:
    • creating a central complaints clearinghouse
    • standardizing complaint management and enforcement across all sectors
    • establishing real-time complaint tracking systems that could aid consumers while providing FSRA with valuable data
    • prescribing expected outcomes where appropriate, for example giving firm deadlines for complaint processing rather than using terms like “reasonable time”
    • banning nondisclosure agreements since they prevent consumers from accessing information related to their case
  • The Panel suggested collecting consumer feedback from complainants directly following the conclusion of the complaint process. This will provide immediate feedback as well as reach consumers, who may not be aware of the services or outcomes they should expect. 

Auto insurance working group

  • A Panel member offered an update on the working group meeting related to auto insurance rating and underwriting, and the key issues they have identified.
  • The working group offered some suggestions, including: 
    • encouraging insurers to be transparent as to the meaning of the quotes and coverage they provide to consumers
    • confirming insurers base their underwriting on individuals’ profiles and follow Ontario’s Human Rights Code
    • eliminating any bias and unfair discrimination in the underwriting and quotation processes
    • providing consumers visibility into information other than price, as lower pricing may not be indicative of good business practices
  • The Panel agreed that FSRA should leverage its access to information to collect and analyze data and put it in the public domain to support consumer insights to the industry. 

Item 4: Ministry of Finance consultation on Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA)

  • A couple of Panel members participated in MOF’s consultation on its review of the MBLAA on October 23, 2024. The MBLAA is reviewed every five years, as required in the legislation.
  • They had an opportunity to share potential ways of strengthening consumer protections through:
    • inclusion of plain language
    • educating consumers during significant life events
    • requiring consumer-facing communications to include information about the regulator
    • increasing transparency by disclosing all fees involved in various scenarios consumers might encounter

Item 5: Financial Planner / Financial Advisor (FP/FA) Framework evaluation 

  • FSRA provided a brief overview of the Financial Professionals Title Protection Framework evaluation, and thanked the Panel Vice-Chair for feedback already given. FSRA is aware of the low consumer awareness of the framework and that consumers generally lack understanding of the difference between a Financial Advisor and Financial Planner. FSRA obtained this insight through its related consumer research conducted by the Consumer Office. FSRA was interested in getting the Panel’s feedback on the following areas:

Enhancing consumer confidence in the framework:

  • The Panel indicated that the overlap between the Canadian Investment Regulatory Organization (CIRO), FP Canada and FSRA is confusing, and further clarification on the different titles and their roles should be provided.
  • The Panel Vice-Chair suggested the Check Credentials Tool could be enhanced to provide information on what credentials mean, what products specific FPs and FAs specialize in, and what service standards consumers should expect. 
  • Additional suggestions the Panel provided include:
    • Require disclosure of fees and other charges at the onset of engagement. 
    • Implement requirements for transparency on fees, such as including them in written documents for individuals who are not registered with CIRO, which has implemented client-focused reforms that include such requirements. 
    • Educate consumers about regulations in a clear, concise and accessible manner to enhance understanding and engagement.
    • Consider providing a “one-stop shop” that includes all regulated individuals in financial services, the regulators that oversee them, and a glossary of terms. 

Industry’s role in educating consumers: 

  • The Panel agreed that the industry must help consumers, and that there is a lot of consumer education information available but it can be difficult for the average consumer to review. 
  • Plain language and simplicity are helpful to consumers.
  • Availability of information in multiple languages is also useful. 

Item 6: FSRA Pensions foundational briefing

  • FSRA provided a foundational briefing on Pensions. The presentation covered FSRA’s role in regulating the pension sector, as well as the sector’s strategy. 

Item 7: Environmental scan / roundtable

Item 8: CAP updates from September

  • The Consumer Office has asked other regulators to reach out to their respective consumer advisory panels about FSRA’s call for new members.
  • FSRA gave an overview of how FSRA responds to the Minister of Finance’s Letter of Direction.

Item 9: Membership update

  • The Consumer Office announced the call for Chair and Vice-Chair nominations, and asked members to inform the Consumer Office if they would like to be nominated or nominate someone for these roles by January 6, 2025. 

Item 10: Closing remarks

Next meeting:

  • February 11, 2024, from 9:00 am until 12:00pm – Virtual Meeting.