Summary of feedback from the 2025-26 Statement of Priorities and Financial Plan consultation

• CADRI
• IBC
• OMIA
• IFB

One stakeholder encouraged a more ambitious service standard for FSRA of 75% of licensing applications completed within 10 business days, as well as more efficiency for the remaining 25%. Another stakeholder recommended more detailed service standard reporting to support transparency, as well as implementing changes to modernize the licensing suitability questions.

One stakeholder suggested that FSRA should improve the efficiency of its agent licensing process and emphasized the importance of establishing consistent timelines for licence applications.

One stakeholder expressed support for initiatives that will improve licensing processes and lead to improved application processing times.

Stakeholders expressed support for the modernization of FSRA’s processes and systems, specifically noting the legacy licensing systems, while balancing the costs of the initiatives and the impact that may have on the regulated sectors.

FSRA is actively modernizing its processes and systems, with plans for a new licensing system in development. In the interim, FSRA continues to operate with legacy systems and through an internal review will implement changes aimed at minimizing service disruptions for stakeholders affected.

• CAP

The stakeholder recommended improved standards across all FSRA regulated sectors through a uniform disclosure framework.

Transparent decision-making and enhanced consumer education and knowledge are part of FSRA’s current strategic framework. FSRA will work with the CAP and other stakeholders to identify and act on opportunities to improve disclosure and transparency while taking into account differences in specific regulated sectors.

• CAP
• OMIA
• CCUA

One stakeholder advocated for sector-specific guidance to clarify expected consumer outcomes, as well as clear performance measures and other tools to help track changes in consumer outcomes and enforce adherence to standards set through principles-based regulation.

One stakeholder encouraged FSRA to consider the cost of acquiring consumer experience data, and identified particular concerns related to broadening the definition of what should be tracked related to consumer complaints. The stakeholder also encouraged FSRA to differentiate between short-term and long-term topics when considering consumer outcomes and using a consumer lens in its guidance and rules.

FSRA has made a commitment to undertake a review of its performance measures and targets in the 2025-2028 Annual Business Plan (see page 40).

FSRA will consult with stakeholders about any new data requests or requirements related to its FY2025-26 commitment to use consumer experience data from stakeholders and other sources, such as FSRA research, to inform is supervisory activities.

• CAP

The stakeholder recommended the establishment of a centralized, standardized complaints mechanism with published service level standards.

FSRA’s complaints framework guidance identifies principles and leading practices in complaints resolution for consideration by the public and regulated entities. FSRA will continue identifying opportunities for application of the complaints framework in 2025-26 and will seek continued engagement with the CAP’s Complaints Working Group to explore its recommendations further.

• CAP
• IFB
• CCUA

Stakeholders generally expressed support for continued attention to protection of vulnerable consumers in FSRA’s work and advocated for additional activities, such as guidance to regulated entities about treatment of vulnerable consumers and expanding partnerships with organizations that serve vulnerable communities.

FSRA welcomes continued interest from industry stakeholders and consumer advocates in work to strengthen protection of vulnerable consumers. FSRA is considering input in response to its 2024 consultation on this topic and will publish its final position in 2025, including overall strategic objectives and specific activities it will undertake targeting consumers at higher risk of mistreatment and harm.

• CAP
• Studio AM

Stakeholders expressed support for continued and increased efforts to improve financial literacy and consumer awareness in FSRA’s regulated sectors.

FSRA has made commitments related to the continued effort to improve financial literacy, consumer awareness and its consumer education framework in the 2025-2028 Annual Business Plan (see page 59).

In addition to its consumer awareness and education activities, FSRA will continue to operate its proceeds of enforcement program. The program uses money collected from sanctions against regulated entities to fund consumer education and research initiatives.

• Bob Copeland

The stakeholder expressed concern regarding bad actors and their ability to exploit AI by investing in advanced programs to outpace defences, and suggested that licensees and businesses should collaborate and form a committee to tackle common AI-related problems while preserving competitive advantages.

FSRA acknowledges the concern and highlights that AI is a subject that it is monitoring closely.

• OMIA
• IBC

One stakeholder recommended increasing adjuster mobility and harmonizing licences to allow adjusters to move between provinces, particularly in response to catastrophic events. The stakeholder highlighted that lack of harmonization has been a long-term concern.

Another stakeholder encouraged FSRA to work with other regulatory bodies in Canada, and the Canadian Insurance Services Regulatory Organizations (“CISRO”), to remove barriers to adjuster mobility across Canada.

FSRA is an active member of CISRO’s Adjuster Licensing Committee, and continues to find ways to address adjuster mobility, especially during natural catastrophe events. In July 2024, FSRA enacted temporary measures to help insurers process the high volume of claims due to rainfall and flooding that impacted Ontario.

• OMIA
• CADRI
• OTLA
• IBC
• Intact

There was widespread agreement among the stakeholders on the need for a consumer-focused approach emphasizing transparency, fair treatment and education to help consumers make informed decisions. 

Key points include:

• Emphasizing the need for long-term stability and transparent pricing, while raising concerns about the high costs of data collection.
• Advocating for fair pricing and favorable consumer outcomes.
• Calling for clearer rules and stronger enforcement to prevent unfair practices, with a focus on consumer education.
• Requesting transparent complaint data to help insurers manage market risks effectively.
• Highlighting the importance of risk-based pricing and a flexible consultative regulatory approach.

FSRA acknowledges the importance of consumer protection and its commitment to enhancing transparency and education. FSRA strives to provide clear accessible information to help consumers make informed decisions about auto insurance products and coverage options. 

FSRA's 2023-2025 Auto Insurance Supervision Plan outlines its approach to ensuring fair treatment of consumers.  It also highlights our commitment to a principles-based, outcomes focused and risk-based approach to supervision.

• OMIA
• CADRI
• OTLA
• IBC
• Intact

Several stakeholders highlighted the need for faster licensing services, including differentiating between new applications and renewals and simplifying adjuster licensing across provinces.

FSRA is actively modernizing its processes and systems, with plans for a new licensing system in development. In the interim, FSRA continues to operate with legacy systems and through an internal review, will implement changes aimed at minimizing service disruptions for stakeholders affected.

• OMIA
• CADRI
• OTLA
• IBC
• Intact

Stakeholders expressed support for FSRA’s efforts to address fraud.

Stakeholders expressed concern regarding the need for robust fraud detection and reporting systems. Stakeholders expressed support for a phased in implementation of fraud detection measures and advocated for collaboration among regulators to enhance their effectiveness.

A stakeholder recommended clearer policies, stronger enforcement action for unfair practices and a fairer claims process to protect vulnerable consumers.
 

FSRA appreciates the support from stakeholders in advancing the Fraud and Abuse Strategy. A key component of this strategy is the Fraud Reporting Service (“FRS”) designed to measure fraud in the industry.

FSRA recognizes the need for a flexible, risk-based approach to fraud reporting that aligns with the size and complexity of individual insurers.

FSRA developed a proposed rule and guidance for the FRS, incorporating feedback from consultations that concluded October 2024, FSRA is in the process of finalizing the rule and guidance.

• OMIA
• CADRI
• OTLA
• IBC
• Intact

Stakeholders expressed strong support for FSRA’s ongoing work on auto insurance reforms.

Stakeholders expressed broad support for FSRA’s Auto Rates and Underwriting Regulation Reform (“ARURR”) Strategy.

There was a widespread agreement on the following:

• A call for quicker approval of rate filings and guidance on auto insurance reforms.
• Support for reforms, with a recommendation to streamline the approval process for most accredited insurers.
• Advocacy for transparent and fair rate filing practices, urging FSRA to simplify the approval process.
• Suggestions to streamline the approval process and include underwriting changes in the accredited program. 

FSRA appreciates the support and recommendations for priorities 4.1, 4.2 and 4.3 which will be considered in ongoing efforts to support government reforms and ensure fair treatment of consumers.

FSRA’s Auto Rates and Underwriting Regulation Reform (“ARURR”) Strategy aims at achieving fair rates and underwriting, promoting market health with effective regulation, and supporting informed consumer decision-making.

The ARURR regime aligns with FSRA’s broader risk-based supervision approach and focuses on achieving positive consumer outcomes as well as simplifying filing processes. In addition, The Fair Consumer Outcomes Principles will offer extra consumer protection.

The Auto Insurance Rating and Underwriting Supervision Interpretation and Approach Guidance has undergone public consultation for the first three chapters, with chapter 4 on insurer filing requirements for accredited and non-accredited insurers to be consulted on in 2025.

This Guidance aligns FSRA’s regulatory approach to its statutory objects, vision and mission. It is intended to establish a principles-based, outcomes-focused and risk-based approach to regulating rates and underwriting rules that is informed by actuarial considerations and prioritizes fair consumer outcomes.

• OMIA
• CADRI
• OTLA
• IBC
• Intact

Stakeholders raised the following points on data collection and transparency:

• Support for improved data collection and transparency to strengthen consumer protection.
• A request for FSRA to provide more detailed information on licencing processes and fraud detection measures.
• A call for greater transparency in insurer profits and rates, along with independent reviews of financial information.
• A desire for better access to complaint data and increased transparency around insurer rates and profits.
• Advocacy for evidence-based decision making with an emphasis on transparency to enhance consumer protection.

FSRA values the stakeholders’ recommendations and is aware of concerns regarding the costs of data collection and will consider these factors as it moves forward with the reforms.

FSRA aims to strike a balance between gathering necessary data and minimizing the administrative burden on insurers.

FSRA is committed to improving transparency, especially in terms of complaint data and rate filings, to enhance consumer trust and help insurers address issues more effectively.

• OMIA
• CADRI
• OTLA
• IBC
• Intact

Stakeholders consistently emphasized the importance of FSRA maintaining ongoing consultations with the industry and adopting flexible regulatory approaches that align with market realities.

FSRA is committed to actively seeking stakeholder feedback through its consultative and flexible approach, ensuring that regulatory strategies are responsive to stakeholder input and market realities.

FSRA aims to develop practical and adaptable strategies that balance consumer protection with insurers’ operational needs.

• Desiree Knack - Fit to Function Kinesiology

A stakeholder shared the following concerns: Healthcare providers in the MVA field have not has a raise since 2014, leading many to consider discontinuing their services. Insurers are asking for more work while offering less pay and denying more claims. Consumers pay high insurance premiums but often fail to receive the coverage they need. The ongoing delays are frustrating, and the stakeholder plans to stop providing MVA services in 2025.

The Ontario government’s 2024 Budget includes a commitment to reform auto insurance.

As part of this, FSRA is reviewing the Health Service Provider (“HSP”) rates and fees in the Professional Services Guideline (“PSG”), Attendant Care Hourly Rates Guideline (“ACHRG”) and the Minor Injury Guideline (“MIG”). 

FSRA is also examining the HCAI system to improve efficiency and reduce costs, as well as reviewing the HSP Framework to find more efficient and cost-effective ways to modernize the system.

Consultation papers for these reviews were released and consultations took place from September 27 to November 29, 2024. FSRA is considering stakeholder feedback as it develops its recommendations over winter 2024/2025, which it plans to share with government in March 2025.
 

• OKA

The stakeholder suggested changes to the auto insurance system that would allow Kinesiologists to independently sign off on treatment and assessment plans (OCF-18 Form) for motor vehicle accident victims.

Although Kinesiologists are recognized as regulated health professionals and can create these plans, they are currently required to have another health professional approve them. The stakeholder believed this step is unnecessary, as the task falls withing the Kinesiologist’s scope of practice.

The stakeholder proposed that Kinesiologists should be able to independently sign off on Part 5 of the OCF-18 Form and be listed directly on the form rather than under “other” professions.

To support FSRA’s Statutory Objects, its 2024-2027 Annual Business Plan and the Government’s budget commitment, FSRA is reviewing the health service provider (“HSP”) guidelines and frameworks.

This review is specifically limited to HSP rates and fees set out in the following three SABS Guidelines:

• Professional Services Guideline (“PSG”)
• Attendant Care Hourly Rates Guideline (“ACHRG”)

• Minor Injury Guideline (“MIG”)

   

  The stakeholder’s recommendations are outside the scope of the current review. The feedback will be considered for future FSRA reviews and/or shared with the Ministry of Finance.

• OMIA

The stakeholder highlighted the importance of providing value for policyholders while noting policyholders concerns regarding cost of insurance.

The stakeholder also emphasized the need for FSRA to consider the cost of acquiring consumer experience data (e.g., complaints) and its potential implications on the reporting burden for stakeholders. They noted FSRA must carefully consider the cost to stakeholders of collecting data.

FSRA thanks the stakeholder for their submission and support in reviewing the 2025-26 Statement of Priorities. FSRA will take all comments into consideration.

FSRA, as a risk-based regulator, is dedicated to monitoring and supervising the actions of the sectors we oversee. Consumer experience data, such as complaints, play a crucial role in assessing the conduct of these sectors and safeguarding consumers who utilize their products and services. FSRA carefully triages this data and collaborates closely with sectors to determine appropriate outcomes. We remain committed to working with the sector to develop and support collaborative solutions that promote sustainability and stability, without adding undue burden.

• OMIA

The stakeholder expressed their support for FSRA’s focus on embedding a consumer lens when developing Rules and Guidance.

They also highlighted the importance of continuous stakeholder engagement and differentiating, where warranted, between short-term consumer issues that may arise due to unexpected market or environmental conditions and positive long-term consumer outcomes such as market stability and availability.

FSRA is conscious of the need to balance the obligations set out in its statutory objects to promote the fair treatment of consumers and foster confidence in its regulated sectors. In furtherance of its objects, FSRA will continue to engage with stakeholders to solicit feedback on ongoing initiatives.

• OMIA

Priority 4.2: With several of the O. Reg. 34/10 Statutory Accident Benefits Schedule (“SABS”) coverages becoming optional, a stakeholder emphasized the need for detailed specifications under regulation to allow insurers to make process and programming changes required to deliver for July 1, 2026. They highlighted that in the past, changes in the SABS were challenging to implement.

FSRA has been working with MOF to support the successful implementation of auto reforms.

FSRA is striking an industry working group to help the industry prepare for the changes to SABS optionality.

• OMIA

Priority 4.3: A stakeholder emphasized that FSRA should continue to maintain proportionality in their guidance, allowing insurers to respond appropriately based on their size and complexity.

The stakeholder recommended considering the costs and benefits of the compliance and reporting of the Market Conduct Supervisory Framework.

Priority 5.2: A stakeholder commended FSRA for fostering positive relationships with insurers and considering affordability for consumers. They noted their appreciation for the stability in the financial plan for 2025 and urges FSRA to continue to carefully manage the overall cost of sound regulation.

Additionally, they hope that future guidance will be less complex in facilitating effective implementation

Proportionality is a foundational element of FSRA’s principles-based approach and will continue to inform the development and review of Rules and Guidance.

Supervisory Focus will be on risks that have high impact on consumers and high likelihood of occurring whenever possible. FSRA will leverage existing data collected from reviews, and questionnaires to understand how insurers mitigate and control key risks to achieve fair outcomes for consumers.

• Primerica
• CLHIA
• IFB

With respect to strengthening the market conduct regulation and supervision of intermediaries, including Managing General Agents (“MGAs”) under FSRA’s Life and Health Insurance Priorities, the responses received from stakeholders supported FSRA developing a proposed rule relating to the regulation of L&H MGA.

One stakeholder was of the view that the new obligations should be proportional and scalable to prevent unintended barriers for agents serving underserved communities and dealing in simpler products and services, keeping life insurance and financial guidance affordable and accessible for middle-income Canadians. This stakeholder also emphasized setting clear goals for new standards to prevent unintended consequences.

FSRA thanks the stakeholders for their responses and support in reviewing the 2025-26 Statement of Priorities. FSRA is developing a proposed rule relating to L&H MGAs which it plans to consult on in 2025. FSRA looks forward to engaging with stakeholders and receiving their comments during the planned consultation.

• CLHIA
• IFB
• Desjardins

Two stakeholders shared the view that licensing and registration processes should be streamlined by modernizing systems and processes.

One stakeholder suggested harmonizing licensing with other jurisdictions and collaborating with other life and health insurance regulators in Canada to identify opportunities to harmonize licensing requirements for the many advisors and firms that conduct business in more than one jurisdiction. As far as licence issuance data is concerned, one stakeholder suggested that FSRA present more granular data.

FSRA is actively modernizing its processes and systems, with plans for a new licensing system in development. In the interim, FSRA continues to operate with legacy systems and through an internal review, will implement changes aimed at minimizing service disruptions for stakeholders affected.

FSRA is an active member across national committees/organizations in the insurance sector, including CISRO and CCIR. FSRA collaborates with other jurisdictions to address licensing harmonization where feasible.

• Studio AM
• Primerica

One stakeholder suggested that FSRA could allow more flexible product designs and encourage partnerships between insurers and healthcare providers. The stakeholder commented that alternative underwriting methods based on lifestyle and wellness data could attract new competitors while delivering better consumer outcomes.

One stakeholder emphasized the need to keep life insurance and financial guidance affordable and accessible for middle-income Canadians by avoiding unduly complex regulations and unnecessary barriers and costs.

FSRA welcomes the feedback and comments on the need to ensure customers can access affordable insurance products and regulation helps foster innovation in the market-place. FSRA will take these comments into consideration when developing new regulatory standards and requirements.

• CLHIA

One stakeholder was supportive of FSRA’s initiative on total cost reporting and underlined the need for a clear understanding of the regulatory requirements and accommodating data limitations (e.g., legacy contracts and transfer events). The stakeholder emphasized the need to apply these requirements in a way that fits insurance distribution structures.

FSRA appreciates stakeholder support for the goals and outcomes of FSRA’s proposed Total Cost Reporting Rule, and supports the need to implement requirements in a manner that will allow consumers to more informed investment decisions.

• Studio AM
• CAFII

The stakeholders suggested that expanding consumer education initiatives would further empower individuals to make informed decisions about their insurance needs and requested FSRA to help Ontarians understand the importance of life insurance to a robust financial plan as financial literacy is critically important.

FSRA recognizes the importance of consumer education and agrees that customer-facing materials should be clear and simple so customers can make informed decisions about their insurance needs. 

FSRA appreciates the suggestion to work with industry stakeholder groups to develop future education campaigns and resources.

• Rocket Mortgage
• Primerica

A stakeholder noted referral programs are crucial for:

• connecting consumers with tailored solutions based on the consumers’ needs and financial profiles
• maintaining an efficient competitive market and greater consumer choice

As such, a stakeholder commented that there should be minimal regulatory burden on referral mechanisms be (e.g., maintain existing regulations, do not introduce new restrictions on how referrals can be made).

A stakeholder commented that FSRA needs to ensure that enhanced oversight does not inadvertently hinder beneficial referral practices between life insurance representatives and mortgage brokers, which play a critical role in serving consumer needs.

The stakeholder recommended FSRA provide clear guidance and risk-based approaches will be essential to achieving this balance.

FSRA should:

• Clearly delineating acceptable referral practices to preserve consumer benefits
• Ensure new compliance measures are proportionate and tailored to address specific risks without creating undue burdens on cross-sector collaboration.
   

Changes to referral structure in the mortgage broker sector are not contemplated in 2025-26 Statement of Priorities.

Referrals by non-licensed mortgage professionals to a mortgage brokerage are permitted under O. Reg. 407/07, s. 1 and 2.

While the amount of referral compensation is not prescribed, disclosures on the amount of compensation received or paid by a brokerage must be made to the borrower/investor/lender.

• CCUA
• Desjardins
• Libro Credit Union

Two stakeholders expressed their appreciation for FSRA’s collaboration with the sector and emphasized their commitment to continuing to build a strong relationship with FSRA. They noted that the collaboration between Ontario’s Ministry of Finance, FSRA and the sector has fostered positive relationships with key stakeholders and contributes to creating a stable sector. To enhance transparency and foster collaboration, they also recommended that FSRA provide the sector with more frequent updates on its workplan and regularly publish its initiatives. This approach may enable the sector to be more proactive in the long-term.

Stakeholders suggested that FSRA should promote and encourage collaboration among credit unions, allowing them to create their own structures, such as interprovincial frameworks, for accessing resources and sharing services.

Another stakeholder recommended that in developing guidance for consumer-driven banking, FSRA considers the high costs incurred by credit unions and collaborates with the sector and the Federal Government to help prevent regulatory overlap and excessive burdens, ensuring credit unions can thrive once consumer-driven banking is live.

FSRA thanks the stakeholders for their submission and support in reviewing the 2025-26 Statement of Priorities. FSRA will continue to engage with stakeholders in development of its initiatives.

Pursuant to its statutory objects, FSRA aims to promote and otherwise contribute to the stability to the credit union sector. FSRA will continue to work with the sector to consider and support collaborative solutions that encourage sustainability and stability, while continuing to be within the boundaries of the provincial legislative framework.

• CCUA
• Desjardins

One stakeholder suggested that FSRA could enhance sector competitiveness by simplifying the approval process for new entrants and reducing compliance burdens for smaller entities.

Another stakeholder pointed out that feedback from merging credit unions indicates the current licensing and approval system is cumbersome. They emphasized the need for FSRA to make greater efforts to streamline the mergers and review process.

One stakeholder emphasized the need for a harmonized regulatory framework across Canada to ensure consistency and efficiency. They urged FSRA to align its frameworks, such as the Deposit Insurance Reserve Fund and unclaimed deposits, with those of the Office of the Superintendent of Financial Institutions and other provincial regulators.

FSRA is a risk-based regulator, and the level and extent of our supervisory activities always depends on the size, complexity and risk profile of each credit union. The same approach is applied to new entrants.

FSRA has published guidance in this area and applies a risk-based, proportional approach to all merger applications.

FSRA actively reviews jurisdictional frameworks to align its regulatory framework with the best practices in comparable jurisdictions. At the same time, it aims to consider the unique and diverse characteristics of credit unions in Ontario.

• CCUA
• Desjardins
• Libro Credit Union
• Studio AM

Stakeholders noted there is a need to continue recognizing persistent economic challenges with credit unions in relation to FSRA’s regulatory initiatives and policy development. Stakeholders specifically noted credit unions continue to face challenging economic conditions and rising business costs such as higher inflation and interest rates.

Stakeholders also conveyed their anticipation for continued collaboration with FSRA on technological advancements, particularly highlighting the importance of discussions on artificial intelligence (“AI”). As the sector increasingly adopts AI and machine learning to enhance operational efficiency, stakeholders emphasized the need for continued collaboration in these areas. They also expressed their concerns about advanced technology and how this leads to fraud. One stakeholder highlighted that partnerships with fintech firms could lead to the development of innovative financial products and the creation of knowledge-sharing platforms to enhance operational efficiency.

Stakeholders discussed challenges related to Environmental, Social and Governance (“ESG”) issues. One stakeholder specifically suggested that FSRA should maintain a principles-based approach to climate risk as part of ongoing Rule and Guidance changes. Another stakeholder highlighted the need for FSRA to consider the significant resources and extended timelines required to effectively and accurately implement ESG and climate objectives when developing new Guidance. Both stakeholders agreed that FSRA should continue to engage comprehensively with credit unions to understand their perspectives and concerns regarding climate risk as an emerging issue.

FSRA acknowledges that credit unions and their members have been facing multiple challenges in the evolving economic environment post COVID-19 and actively considers unexpected economic stress and the impacts of this on credit union profitability and resilience.

FSRA continues to be consistent with achieving its mission of “public service through dynamic, principles-based and outcomes-focused regulation,” and considers proportionality in the context of complexity, size and risk profile of credit unions.

In terms of fraud prevention, FSRA emphasizes the importance of following principles outlined in FSRA’s IT Risk Management Guidance and Operational Risk and Resilience Guidance. FSRA will continue to work with credit unions on implementation of these two pieces of guidance, which came into effect in early 2024.

FSRA is supportive of credit unions engaging fintech firms, provided appropriate safeguards are in place as per FSRA’s IT Risk Management Guidance and Operational Risk and Resilience Guidance.

FSRA acknowledges the need for a comprehensive approach to risk management and remains attentive to the various factors that impact the sector’s resilience. This includes but is not limited to close monitoring of ESG risks, with a particular focus on climate risk. FSRA recognizes that sizing climate-related risks, including unexpected losses, is challenging as climate scenario analysis is in its nascency. FSRA will continue to engage with the sector to build a better understanding of the climate risks facing credit unions. There are no immediate plans for FSRA to issue a climate-specific Guidance but we will continue to monitor to determine if and when guidance for the sector is required.

• CCUA
• Libro Credit Union

Priority 6.2: A stakeholder requested that FSRA adopt a data-informed approach to lower capital requirements for agricultural sector lending, and that this request is based on the significantly different historical performance of Loss Given Default levels in type of lending compared to some other types.

FSRA continues to work to enhance their use and collection of data to make informed decisions on its capital adequacy framework review. FSRA will work with stakeholders to understand why agricultural loans may warrant lower risk weightings in the calculation of risk weighted assets (resulting in lower capital to support these loans) compared to other commercial loans.

• CCUA
• Libro Credit Union

Both stakeholders recommended a second public consultation for the proposed Unclaimed Deposits Rule and Guidance. One stakeholder specifically highlighted the need to incorporate stakeholder feedback and to support the transition time required by credit unions to comply with the Rule.

After reviewing submissions from the first public consultation on the proposed Unclaimed Deposits Rule and Guidance, FSRA is actively incorporating the feedback. The revised Rule and Guidance was posted for a second public consultation on January 8, 2025.

• CCUA
• Libro Credit Union

Priority 6.3: Both stakeholders expressed their appreciation for FSRA’s advocacy and collaboration with the sector on the DIRF target and timelines. One stakeholder also thanks FSRA for their ongoing work to advocate for credit unions to achieve access to emergency lending assistance and the short-term liquidity facility.

One stakeholder emphasized that ongoing consultation with the sector is crucial for ensuring a fair approach to accurately assessing the DIRF’s adequacy, benefiting both credit unions and deposit holders. Additionally, the stakeholder requested that FSRA consider other areas of regulatory oversight, such as Recovery Planning, to achieve a holistic approach to future assessments of the DIRF.

Another stakeholder expressed confidence in achieving a revised DIRF target without needing to adjust the deposit premium formula. They also suggested that a minimum transition period of five years should be considered.

FSRA will continue to try to ensure that adequate sources of liquidity support will be available to all Ontario credit unions. FSRA will continue to engage with the Bank of Canada, Payments Canada, the Ministry of Finance and other stakeholders to help Ontario credit unions satisfy the eligibility criteria for access to emergency lending assistance.

FSRA will continue to foster consistent collaboration with the sector with respect to the DIRF target to facilitate sector feedback and review. FSRA will continue to enhance the assessment of the adequacy of the DIRF by incorporating additional information and utilizing additional stress testing techniques as appropriate.

FSRA will continue to mitigate the risk of draws on the DIRF by proactively identifying areas of risk at the CU sector level and at individual CUs as part its Risk-Based Supervisory Framework.

FSRA will also continue to support the Ministry of Finance in discussions about any future changes in the deposit insurance premium calculation outlined in O. Reg. 105/22.

• CCUA
• Libro Credit Union

Both stakeholders expressed a desire for greater clarity on the costs associated with new initiatives contemplated by FSRA. One stakeholder specifically highlighted concern about delays and cost overruns related to FSRA’s system modernization efforts. They emphasized the need for FSRA to provide more detailed information about plans and costs, and how these impact regulated entities. Credit unions are seeking additional information on the long-term implications of such delays and cost overruns.

FSRA will continue to proactively manage its costs to ensure they are reasonable and aligned with essential efforts.

FSRA will provide further cost project updates and details on system modernization efforts in the upcoming 2025-28 Annual Business Plan.

• IFB
• CLHIA

Stakeholders expressed general support for proposed key activities for the sector.

One stakeholder noted that insurers are support enhancing confidence and professionalism in the financial sector by ensuring financial planner and advisors have the appropriate qualifications.

FSRA thanks stakeholders for their comments and the support expressed for FSRA’s proposed 2025-2026 Statement of Priorities for the sector.

• Studio AM

Stakeholder noted that clearer disclosure requirements for fee structures and advisory models would empower consumers to make better-informed decisions, while ongoing professional development initiatives would equip advisors to navigate evolving regulatory conditions.

The framework currently establishes continuing education (“CE”) requirements for credential holders to ensure the continued qualification of Financial Planner (“FP”) and Financial Advisor (“FA”) title users.

FSRA will consider this feedback for further consideration.

• Studio AM

Stakeholder recommended FSRA to introduce tiered certification programs to align with global best practices, improving professionalism.

FSRA will consider this feedback for further consideration.

• FP Canada

Stakeholder noted that clarity around standards would allow credentialing bodies and consumers to clearly understand FSRA’s expectations under its principles based regulatory approach.

Stakeholder noted that clarity around standards further provide a baseline understanding for the continued evolution of the Framework, and that it is essential to protecting the public interest and ensuring the Framework is both rigorous and effective.

Stakeholder suggested that FSRA could provide clarity of standards through enhanced guidance, rule amendments, or clarifying Questions and Answers.

FSRA will consider this feedback and continue to engage with all stakeholders. FSRA is committed to a principles-based, outcomes-focused approach to regulation and supervision of the FP/FA sector.

• FP Canada

Stakeholder recommended that FSRA should enhance the reporting of its credentialing body examination process by providing specific reference to results identified, including severity, timeline, and steps to be taken by applicable credentialing bodies to address identified issues.

Stakeholder noted that it recognizes that FSRA will continue to report results anonymously as per its reporting rules and guidance, but this should not be a barrier to reporting the content, remedies and timelines.

FSRA proactively publishes aggregate results of its supervisory activities.

FSRA’s approach for publishing aggregate supervision results is intended to promote transparency and enhanced consumer protection by informing the public of any identified trends, best practices and / or opportunities for improvement among approved credentialing bodies. This approach is consistent with the approach for other FSRA-regulated sectors.

Furthermore, FSRA follows up on previous year's findings and recommendations to assess whether the credentialing bodies have taken appropriate steps to address the identified areas for improvement.

• FP Canada
• IFB
• CAP

A stakeholder expressed support for FSRA’s commitment to conduct a review of the Framework.

One stakeholder recommended that FSRA publish its review of the Framework for consultation, allowing stakeholders and approved credentialing bodies to provide input on FSRA’s perspective coming out of this review.

One stakeholder noted that there is still uncertainty on the proposed changes to the Framework as part of the Framework review.

One stakeholder recommended strengthening the Framework by expanding public awareness campaigns, improving credentialing oversight, and strengthening enforcement mechanisms.

FSRA’s 2024-2027 Annual Business Plan (“ABP”) committed to the framework evaluation, which could explore possible future enhancements to the framework.

FSRA will consider this feedback for further consideration.

• York University (Amin Mawani)

Stakeholder expressed concerns about variation in compensation across credentialing bodies, noting it needs transparency, and sales pressures and incentives that can detract some financial advisors from focusing on the client's best interests.

Stakeholder highlighted that FSRA should be making financial consumers aware that self-interest could be clouding some advisors’ judgment.

Stakeholder noted many advisors credentialed by FSRA are compensated and incentivized based on new business brought in from existing or new customers into the advisors’ institution.
Stakeholder noted that sales pressures and sales incentives have largely been neglected by regulators, including FSRA.

Stakeholder suggested FSRA to consider publicizing how various types of financial advisors may be compensated.

FSRA’s role in the FP / FA sector includes oversight and approval of credentialing bodies and credentials.

Credentialing bodies are responsible for administering and granting FP / FA credentials and overseeing the conduct of their respective credential holders.

As stated in FSRA’s Administration of Application Guidance, FSRA expects credentialing bodies to include a requirement in their code of ethics and professional standards for credential holders to put their client’s interests first.

FSRA will consider this feedback as part of its supervision of credentialing bodies to ensure credential holders are being monitored and required to put their clients’ interests first.

Compensation of FPs / FAs, including publicizing how they are compensated, is outside the authority of the title protection framework.

• York University (Amin Mawani)

Stakeholder suggested more research to document the consumer harm faced by inadequate standards for financial planning by credentialing bodies that do not have competency frameworks or enforce their standards as diligently.

Stakeholder suggested FSRA may need more independent research to document the consumer harm faced when advisors do not keep the public's interest foremost in mind.

FSRA will consider this feedback for further consideration.

• York University (Amin Mawani)
• Primerica

Stakeholder noted that by approving multiple credentialing bodies and credentials it might come across to the public all credentials are on an equal footing even though credentialing bodies assess, monitor, enforce and incentivize their members differently.

Stakeholder noted some credentialing bodies have invested in competency framework, involving academic and industry participation in their standard setting and competency framework discussions.

Stakeholder suggested that the framework should maintain flexible credentialing pathways to encourage participation from diverse professionals who serve varying market segments.

The framework establishes standards for organizations to operate as approved credentialing bodies and for the administration of FP and FA credentials.

FSRA adopted a principles-based approach to design and implementation of these standards, offering flexibility for credentialing bodies to meet the required outcomes in a manner that suits their businesses, while allowing FSRA to adapt and respond to the evolving financial services sector.

FSRA intended the title protection framework to be inclusive, including having multiple existing designations approved as FP or FA credentials and licensing entities as credentialing bodies.

By leveraging existing designations and licences, the title protection framework provides market participants with options.

FSRA will consider this feedback as it continues to supervise credentialing bodies.

• Primerica

Stakeholder noted that the framework should be streamlined to prevent unnecessary financial or administrative burden on advisors.

FSRA will consider this feedback for further consideration.

• CLHIA

Stakeholder noted the potential for consumer confusion arising from the fact that life insurance agents who hold a licence in Quebec and Ontario, and who do not hold an approved credential to use the FA title in Ontario, must display different titles on their business cards.

FSRA supports harmonization of title protection across jurisdictions where possible and will consider this feedback for further consideration.