ID
2025-010
ID
2025-010
Type
Priorities / Budget
Sector
Cross Sector
Status
Public comment closed
Date
Comment Due Date
Thank you for providing your feedback on FSRA’s consultation on FSRA’s proposed 2026-2027 Statement of Priorities.
The request for submissions is now closed.
We appreciate the comments and questions received to date and look forward to sharing with you the final Guidance. Stay up to date on Guidance releases on our newsroom. Follow us on LinkedIn and subscribe to our mailing list for quick updates.
FSRA is launching public consultations on its proposed 2026-27 Statement of Priorities and five-year Strategic Framework.
Through this process, stakeholders will have the opportunity to shape the future direction of financial services regulation in Ontario.
Highlights from the proposed Strategic Framework, and 2026-2027 Statement of Priorities:
Transform our capabilities:
Modernize internal systems and strengthen technology and data capabilities in supervision to improve transparency, efficiency and timeliness of oversight.
Embrace and embed Principles-Based Regulation:
Advance FSRA’s approach to regulation and strengthen supervisory effectiveness.
Promote proactive and collaborative partnerships:
Support government priorities and make a meaningful impact through engagement and collaboration with stakeholders and the public.
The Statement of Priorities and Strategic Framework, along with FSRA’s Budget, will form the core of our Annual Business Plan, which will then be submitted to the Minister of Finance for approval.
The consultation period will close on January 14, 2026, at 11:59 p.m. EST. FSRA invites stakeholders to review the proposed 2026-27 priorities and Strategic Framework and submit feedback.
FSRA is developing a financial plan that will help guide its work and support its strategic goals. This plan will be aligned with FSRA’s Strategic Framework and Strategic Priorities to ensure the organization remains effective and financially sustainable.
While the Statement of Priorities (SOP) is being posted now for public consultation, the draft financial plan (Budget) will be added when it is fully developed. This will give stakeholders time to review and share their feedback before it is finalized.
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| Sector | Comment | Date posted Sort ascending |
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[2025-010] Giuseppina Marra - Fédération des caisses Desjardins du Québec
Bonjour, Veuillez trouver ci-joints les commentaires du Mouvement Desjardins en lien avec la présente consultation. Nous vous remercions sincèrement pour l'occasion offerte de partager nos commentaires. Bonne fin de journée! Sarah Bouhenni Adjointe administrative Affaires réglementaires FCDQ |
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[2025-010] Nicholas Nestico - Libro Credit Union |
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| Auto Insurance | [2025-010] Rhona DesRoches - FAIR Association of Victims for Accident Insurance Reform
FAIR Association of Victims for Accident Insurance Reform579A Lakeshore Rd. E., Box 39522, Mississauga, ON, L5G 4S6 http://www.fairassociation.ca/ [email protected] FAIR submission to FSRA proposed Strategic Framework, and 2026-2027 Statement of Priorities ID 2025-010 Submitted online to FSRA portal January 14, 2026 FAIR (Fair Association of Victims for Accident Insurance Reform) is a grassroots not-for-profit organization of injured car crash survivors and their supporters. We are the end-users of the auto insurance product and we rely on the Regulator to ensure the insurance product has value and that coverage, as promised by Ontario insurers, is available to us at a vulnerable point in our lives. In this document FSRA clearly identifies that they must provide stability and build trust as a regulator. But the idea or prioritization of implementing “improvements to stakeholder and consumer experiences, such as enhancements to accessibility and digital-first communications” misses the need to ensure the quality of Ontario’s auto insurance. People need to know that a contract with an insurer means they have benefits they can count on, and that the Regulator is taking an interest in whether consumers are getting what they paid for. FSRA’s statutory objects under 3 (1) (b) to contribute to public confidence in the regulated sectors and (f) to promote transparency and disclosure of information by the regulated sectors appear to not be in the scope of the FSRA’s intent as expressed in this statement. There remains a decided slant to promote the interests of insurers over the needs of consumers. 3 (1) (g) to deter deceptive or fraudulent conduct, practices and activities by the regulated sectors can only be achieved through deeper insurer transparency and through FSRA sharing that data regarding the types of complaints consumers are bringing to the Regulator and the outcome of those complaints with the public. Consumers have a legitimate interest in insurer behavior regarding insurer claims denials and outcomes. How can a consumer possibly competently choose an insurer or have confidence in the auto insurance sector without such knowledge? How can a Regulator oversee an industry without such knowledge being gathered and considered and if FSRA is gathering this information – why isn’t it being shared with the public? The interest of insurers definitely takes priority in this proposal and we have yet to see what FSRA has gleaned from the Licence Appeal Tribunal (LAT) data that the Auditor General recommended be examined by FSRA as a tool to protect the public interest. The 2022 AG report “found that although FSRA receives this information from the LAT quarterly, it does little with it to better understand the types of cases that are appearing before the LAT, and if regulatory changes or other actions would reduce the number of LAT hearings on automobile insurance matters.” Has that issue been addressed, and if so, where is that data so consumers can access it? Isn’t that the sort of transparency consumers really need? Where is the oversight for Insurer Medical Examination (IME) clinics that fail to provide quality medical opinion evidence? Where is the accountability for American companies who own those clinics that routinely and predictably deny claims through their providers who are only regulated by their Ontario Colleges who continue to fail Ontario patients/claimants? This failure to regulate is undermining the confidence FSRA purports to prioritize. There does not appear to be genuine interest or intent to protect consumers in the document and that is truly concerning given the auto insurance reforms coming into force in July 2026. More than ever, consumers need the Regulator to put their interests before insurer profits. It is not enough to inform the public about optional benefits to avert what is likely an insurance crisis point and chaos for consumers. As long as insurers’ behavior and claims handling practices remain cloaked in mystery, consumers will remain at risk of buying sham coverage. We think Ontarians deserve better than this document proposes to deliver. Thank you for the opportunity to express our concerns about FSRA direction and priorities in the coming years. FAIR Association of Victims for Accident Insurance Reform |
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| Auto Insurance | [2025-010] Rich Trus
Public Consultation Feedback – FSRA 2026–27 Statement of PrioritiesSubject: AI-identified systemic risks in IMEs, insurers, and legal practices This submission responds to FSRA’s 2026–27 Proposed Statement of Priorities. It is based on AI-driven analysis of insurance, legal, and Independent Medical Examination (IME) records, which reveals systemic non-compliance, conflicts of interest, and consumer harm that traditional complaint-based oversight does not detect. These findings align directly with FSRA’s focus on data-driven supervision, principles-based regulation, and consumer protection. 1. Accessibility and Evidence Integrity (AODA) AI identified widespread use of image-only IME PDFs that are not searchable, extractable, or screen-reader compatible. These fax-originated documents were never OCR-processed, creating: - Barriers for disabled claimants - Inability to review or analyze evidence - Regulatory blind spots - High risk of manipulation This contradicts AODA and FSRA’s commitment to digital-first, data-driven oversight. 2. Systemic Conflicts of Interest in IMEs AI found structural dependence between insurers and IME providers that compromises medical independence, including: - Reports largely copied and pasted from prior files - “One-hour” exams where physicians were present only minutes - Unregistered examiner working under suspended FSRA provider - IME firms previously advertising “no favourable report = no payment” These create financial incentives to deny or minimize benefits, undermining objectivity, due process, and consumer protection. 3. False Credentials and Unlicensed Practice AI identified IME evaluators who: - Claimed false or expired professional memberships - Listed fabricated or unverifiable credentials - Continued practicing after their COTO registration expired - Claimed to work for a company that surrendered its FSRA licence years earlier Insurers nevertheless relied on these reports, exposing claimants to unlicensed practice, misrepresentation, and regulatory evasion. 4. Outcome-Based Compensation One suspended IME company advertised that insurers did not have to pay if an insurance company disliked a report. An unregistered occupational therapist listed the suspended company as their employer. This outcome-based payment model destroys independence, credibility, and procedural fairness and would not be tolerated in any other regulated profession. 5. Legal and Administrative Errors AI detected repeated failures by legal representatives to properly requisition records or provide correct policy numbers, including a case where a single character error (“l” vs “1”) led a law firm to claim a defendant was uninsured and terminated the client retainer, resulting in the plaintiff not being able to sue for damages. These predictable errors show the need for automated validation tools. 6. Transportation and Delay Tactics AI found recurring patterns where IME transport or scheduling failures—late arrivals, cancellations, or long rescheduling delays—triggered benefit suspensions and missed deadlines. These delays are systemic and are then used to justify benefit denials. 7. Evidence Manipulation Some IME reports listed documents dated after the report was supposedly written, indicating either back-dating or retroactive justification. This undermines evidentiary integrity. 8. Good Character and Professional Integrity AI found that licensed clinicians routinely recommended benefits, while unlicensed or improperly authorized evaluators assessing the same claimants consistently recommended zero benefits. This pattern aligns with financial and insurer incentives, not medical judgment, and raises serious Good Character and fitness-to-practice concerns under Ontario’s regulatory framework. 9. Adjuster Identity Misrepresentation AI identified an insurance adjuster operating under two materially different names. Under Ontario’s Insurance Act, an adjuster may only practice and advertise under the exact name on their licence. Using a different identity: - Prevents public verification - Blocks complaint tracking - Undermines accountability - is not good character This constitutes misrepresentation even if no money is stolen. Why This Matters to FSRA’s 2026–27 Strategy These findings directly support FSRA’s strategic priorities: - Data-driven supervision - Technology-enabled regulation - Principles-based oversight - Consumer protection AI reveals systemic risks invisible to complaint-based regulation. FSRA now has the opportunity to: - Require AODA & OCR-compliant, accessible IME records - Enforce credential and licence verification - Detect conflicts of interest and outcome-based compensation - Identify unlicensed practice and identity misrepresentation - Prevent benefit manipulation I am available to provide FSRA with examples and recommendations of AI tools that ensure that the necessary steps to restore integrity and trust in Ontario’s IME and claims system will happen in 2026/27 Rich Trus |
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| Life and Health Insurance | [2025-010] Zach Morris - Primerica Financial Services Limited (PFSL)
Attached please find our submission in response to your Statement of Priorities Consultation. |
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| Life and Health Insurance | [2025-010] Marsha Gerhart - Advocis |
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| Auto Insurance | [2025-010] Catherine Allman - Canadian Association of Direct Relationship Insurers
In its response attached, CADRI has emphasized the following as priorities for the regulator:• Modernizing systems which support licensing and regulatory supervision, • Improving licensing service level standards to the benefit of customers, • Implementing an even more streamlined process for out-of-province agents, • Expanding the territory model, and • Ensuring that agents and brokers engaged in the point-of-sale Test and Learn Environment are licensed and supervised appropriately. |
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| Cross Sector | [2025-010] Chris Fievoli - Canadian Institute of Actuaries
Hello,Please find attached comments from the Canadian Institute of Actuaries on FSRA's 2026-2027 Statement of Priorities. Please do not hesitate to reach out with any questions or to arrange further discussions. Best regards, Chris Fievoli, FCIA |
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| Cross Sector | [2025-010] Gary Edwards - Golfdale Consulting, Inc.
On behalf of Golfdale Consulting, attached please find our comments on FSRA’s proposed 2026–2027 Statement of Priorities and Five-Year Strategic Framework, focusing on operationalizing principles-based regulation, strengthening data- and technology-enabled supervision, and improving measurement of public interest outcomes to support effective regulation. |
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| Life and Health Insurance | [2025-010] Margaret Campbell - CLHIA |
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| Financial Planners and Financial Advisors | [2025-010] Josh Binkley - FP Canada
Please see attached file. |
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| Auto Insurance | [2025-010] Matt Di Maio - Ontario Trial Lawyers Association
Please find OTLA's submission attached. |
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| Life and Health Insurance | [2025-010] Keith Martin - Keith Martin
Please find CAFII's submission FY2026-27 Priorities attached. |
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| Health Service Providers | [2025-010] Laurie Davis - Ontario Rehab Alliance
Please see attached submission. |
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| Auto Insurance | [2025-010] Amanda Dean - Insurance Bureau of Canada
Please see the attached submission from IBC for your consideration.Thank you |
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| Health Service Providers | [2025-010] Anthony Grande - Community Rehab Network
Submission in Response to FSRA’s Proposed 2026–27 Statement of Priorities Submitted by: Anthony Grande Consultation: FSRA Proposed 2026–27 Statement of Priorities Date: January 12, 2026 1. Introduction This submission responds to the Financial Services Regulatory Authority of Ontario’s (FSRA’s) proposed 2026–27 Statement of Priorities (SoP). We recognise FSRA’s complex mandate across multiple financial sectors and its stated commitment to protecting consumers, enhancing market integrity, and improving system performance. The purpose of this submission is not to criticise FSRA’s intent or legitimacy, nor to allege wrongdoing or bad faith, but to assess whether the structure, framing, and accountability mechanisms of the SoP are adequate to deliver meaningful public-interest outcomes — particularly in the auto insurance sector and its interface with healthcare services. Our central concern is that while FSRA’s priorities are consistently well-intentioned and active, they are not consistently outcome-driven, closed, or evaluated. As a result, the SoP risks functioning primarily as a planning and signalling instrument rather than as a delivery and accountability instrument. This submission therefore focuses on whether the SoP: • Is oriented toward measurable outcomes rather than internal process. • Includes closure mechanisms for long-standing priorities. • Advances access to care, fairness, and trust for accident victims and system participants; and • Allocates regulatory effort proportionately to demonstrated risk. 2. Structural Accountability Gaps in the Statement of Priorities A review of FSRA’s Statements of Priorities since inception reveals recurring themes, fraud reduction, regulatory modernisation, burden reduction, and auto insurance reform, reiterated year after year without formal closure, outcome reporting, or explicit resolution. This creates three governance risks: 1. Priority inflation: everything remains a priority indefinitely. 2. Accountability dilution: no one is accountable for finishing anything. 3. Stakeholder fatigue: repeated consultations without resolution erode trust. The SoP currently functions primarily as a planning document rather than as a delivery or evaluation document. Without explicit closure mechanisms, performance indicators, or outcome reporting, it is difficult for stakeholders or the public to assess whether priorities are achieving their stated purposes. 3. Structural Gaps in the Current Statement of Priorities 3.1 Lack of Closure and Priority Drift FSRA repeatedly lists high-level priorities — such as reducing regulatory burden, improving consumer protection, combating fraud, and supporting auto insurance reform — without formally indicating when those priorities are achieved, superseded, or abandoned. A regulatory system that cannot clearly state “this objective is complete” or “this approach did not work” risks becoming self-referential rather than public serving. We have undertaken a structured gap analysis comparing successive Statements of Priorities against stated objectives and observable outcomes, and would be pleased to share this analysis if it would assist FSRA in strengthening closure and accountability 3.2 Over-emphasis on Process vs Outcomes The SoP places significant emphasis on: • Modernising internal systems, • Enhancing regulatory capabilities, • Transitioning frameworks, • Strengthening data and analytics. These are valuable means, but they are not ends. The SoP does not clearly articulate: • How long it should take an accident victim to access care, • Whether regulatory burden on providers is rising or falling, • Whether disputes, delays, or denials are decreasing, • Whether trust in the system is improving. Without outcome framing, regulatory success becomes internally defined rather than publicly accountable. 3.3 Fraud Narrative Without Outcome Evidence Fraud reduction remains a consistent priority, yet: • No public data demonstrates the presence of fraud or that fraud has materially declined. • No link is established between fraud initiatives and affordability improvements. • No proportionality assessment is presented. Meanwhile, regulatory intensity remains high for healthcare professionals despite extremely low rates of serious misconduct identified through audits. This risks over-regulation of low-risk actors, misallocation of regulatory resources, unintentional stigmatisation of legitimate professionals, and erosion of trust. 3.4 Absence of Access-to-Care Metrics Access to timely care is one of the most important public-interest outcomes in auto insurance. Yet the SoP does not include priorities or metrics related to: • Time to first treatment, • OCF-18 denial rates • Availability of providers, • Geographic access, • Administrative friction delaying care. This omission is significant because regulatory design directly affects system capacity and access. 3.5 Misalignment Between Stated Collaboration Commitments and Practice The Statement of Priorities commits FSRA to “promote proactive and collaborative partnerships” and to “cultivate relationships with key stakeholders and allow for collaborative problem-solving,” particularly with respect to strengthening trust and regulatory credibility. However, recent practice with respect to healthcare professionals — who are both licensed and essential system participants — appears misaligned with this stated commitment. The Health Service Provider Advisory Committee, which served as a formal engagement mechanism for licensed healthcare professionals, has been disbanded. Over the course of its existence, healthcare representation on the committee declined while insurance representation increased, reducing its effectiveness as a balanced forum for stakeholder input. At present, no replacement engagement structure exists for this licensed stakeholder group. Similarly, during the 2024 FSRA Exchange, none of the questions submitted by healthcare professionals were addressed, including those raising concerns about market conduct, regulatory fairness, and system impacts. This absence of response undermines the stated objective of collaborative problem-solving and contributes to a perception among healthcare professionals that their perspectives are not meaningfully engaged. In addition, FSRA has not conducted direct research with accident victims regarding their lived experience of access, delay, dispute, or care outcomes, despite these being core public-interest concerns. By contrast, surveys have been conducted among populations without direct experience of the accident benefits system, particularly regarding perceptions of fraud. This approach risks over-weighting abstract or indirect views while under-weighting the experiences of those most affected by regulatory design. Together, these patterns suggest a gap between FSRA’s stated commitment to collaboration, trust-building, and stakeholder engagement and the operational reality experienced by healthcare professionals and accident victims. This gap weakens regulatory legitimacy, reduces trust, and limits FSRA’s ability to detect and respond to system harms in a timely and informed manner. 4. The Health Service Provider (HSP) Licensing Framework 4.1 The accountability gap The Health Service Provider (HSP) licensing framework exemplifies the accountability gap described above. Since its introduction, the framework has been the subject of sustained concern from healthcare professional organisations and stakeholders, who have questioned its necessity given existing professional college regulation and raised concerns about its cost and administrative burden. FSRA itself identified the framework as requiring review and explicitly framed the question as one of assessing its value relative to its burden. However, no public closure, redesign, or replacement has been announced, and the framework remains in place. FSRA’s own compliance reporting indicates that: • Most findings relate to administrative or technical non-compliance rather than any substantive misconduct. • Issues are typically addressed through education or warning letters. • Findings of deliberate fraud are very uncommon. This indicates a regime that is intensive in process but limited in demonstrated outcome. 5. Recommendation: Remove the HSP Licensing Regime This submission recommends removal of the HSP licensing framework in its current form, as it does not meet the standards of necessity, proportionality, or demonstrated public-interest benefit required to justify a standalone regulatory regime. 5.1 Not necessary Healthcare professionals delivering accident benefits services are already subject to: • Regulation under the Regulated Health Professions Act. • Ethical, competency, and discipline oversight by their Colleges. • Civil and criminal liability for fraud and misrepresentation. • Contractual obligations and insurer oversight mechanisms. The HSP regime therefore duplicates existing safeguards rather than filling a regulatory gap. 5.2 Not proportionate The regime imposes licensing fees, audits, reporting obligations, and compliance infrastructure on thousands of clinics while producing limited enforcement actions and little evidence of harm prevented. This fails the proportionality test of good regulation. 5.3 Causes net public-interest harm The burden imposed by the regime: • Increases the cost of delivering care, • Diverts time away from patients, • Discourages participation in the accident benefits system, • Reduces access, particularly in smaller and rural communities. The result is reduced system capacity and delayed or fragmented care for injured Ontarians. 5.4 Removal, not reform Given that risks are already regulated elsewhere, the regime is administratively heavy but substantively light, and the burden produces real harm, the appropriate response is removal rather than incremental reform. FSRA should instead rely on: • Professional college regulation for clinical conduct. • Targeted insurer market-conduct oversight focused on high-risk behaviour. • Data-driven anomaly detection rather than blanket licensing. • Proportionate enforcement tied to demonstrated risk. 6. Recommendations to Strengthen the Statement of Priorities FSRA should: 1. Introduce explicit public outcome indicators for each priority (e.g., time to care, dispute resolution time, provider participation, administrative burden). 2. Classify each priority as new, ongoing, completed, superseded, or under review. 3. Commit within a defined timeline to resolve — by removal — the HSP licensing framework. 4. Rebalance narrative framing to reflect high compliance and collaboration among healthcare professionals. 5. Explicitly align priorities with human outcomes rather than internal process milestones. 6. Establish an Insurance Adjuster Code of Conduct and a Healthcare-Accessible Complaint Mechanism Insurance adjusters exercise significant practical influence over the delivery of healthcare to accident victims, including decisions affecting approval, modification, delay, or denial of treatment. These decisions directly shape patient outcomes, recovery timelines, and access to care. However, insurance adjusters are not subject to clinical training, professional ethical obligations, or a healthcare-oriented code of conduct. Nor is there a clear, accessible, and balanced mechanism through which healthcare professionals or patients can raise concerns about adjuster behaviour that affects care delivery. This creates a structural accountability gap in which: • Individuals without clinical or ethical healthcare training effectively influence clinical pathways; • Patients are not in a realistic position to complain about their adjuster without fear of reprisal or disadvantage, nor can they readily change adjusters if concerns arise; • Healthcare professionals, despite having direct visibility into the impacts of adjuster behaviour on care, have no formal, protected channel to raise concerns; and • Regulatory oversight of conduct that materially affects healthcare outcomes remains underdeveloped. This imbalance of power is inconsistent with principles of fair process, proportional accountability, and public-interest regulation. By contrast, healthcare regulation recognises that complaints and concerns — regardless of their provenance — serve an important protective and quality-assurance function. Systems that take concerns seriously, even when they are uncomfortable, are more likely to identify risks early, correct harmful practices, and maintain public trust. Accordingly, this submission recommends that FSRA: • Establish a formal Code of Conduct for insurance adjusters whose decisions affect access to healthcare, including principles of fairness, transparency, proportionality, and respect for clinical autonomy; and • Create a safe, accessible, and non-retaliatory mechanism through which healthcare professionals and patients can raise concerns about adjuster conduct that affects care delivery, with appropriate procedural protections and independent review. Such a framework would not weaken regulatory oversight — it would rebalance it. It would enhance fairness, improve accountability, protect vulnerable patients, and align regulatory practice with the reality that healthcare delivery is not merely a financial transaction but a human service with ethical and public-interest dimensions. 7. Conclusion FSRA plays a critical role in shaping whether Ontario’s auto insurance system functions as a benefits system for injured people or as a procedural system that quietly excludes those with the least power. The Statement of Priorities can be a powerful accountability instrument — but only if it is structured to deliver, close, and measure. This submission respectfully urges FSRA to: • Introduce outcome-based accountability, • Close long-standing priority loops, • Remove regulatory structures that fail necessity and proportionality tests, and • Re-anchor its work in measurable public-interest outcomes. • Establish an Insurance Adjuster Code of Conduct and a Healthcare Professional -Accessible Complaint Mechanism – similar to Healthcare Colleges • Publicly respond, in full, to the questions submitted by healthcare professionals at the 2024 FSRA Exchange, and treat this as a minimum standard of principled regulation, procedural fairness, and institutional legitimacy. We offer these comments in the spirit of strengthening FSRA’s ability to serve Ontarians fairly, effectively, and transparently. |
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| Credit Unions and Caisses Populaires | [2025-010] Brent Furtney - Canadian Credit Union Association
Please find attached The Canadian Credit Union Associations (CCUA) formal consultation response. We thank FSRA for the opportunity to review and respond to this important consultation. We believe it offers an opportunity to ensure alignment between FSRA and the credit union sector's priorities.Regards. Brent Furtney |
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| Auto Insurance | [2025-010] Andrew Paulley - University of Toronto
Dear FSRAO,My understanding of rate approvals for auto insurance is that included in the rate change application are quotes of pre-determined profiles from across the province for different combinations of age, sex, and vehicle amongst other things. Making these rate profile quotes public, as the AIRB in Alberta does, would strengthen not only consumer knowledge and understanding of firm-level pricing in the industry but also enhance the supervision of underwriting and rates by allowing the public to monitor rates in part themselves. Auto insurance is a game of information, where there is competition between insurers but also between insurers and consumers. Protecting consumers therefore means decreasing the gap between firm and consumer information. Publishing rate profile quotes would go a long way to achieve this. |
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| Life and Health Insurance | [2025-010] Robert - VigilantCS
Hello, Attached please find the VigilantCS comment letter on the FSRA Statement of Priorities (2026/27). Kind regards Rob Kirwin |
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| Financial Planners and Financial Advisors | [2025-010] Nancy Allan - Independent Financial Brokers of Canada |
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| Property and Casualty and General Insurance | [2025-010] John Taylor - Ontario Mutual Insurance Association
Please find attached OMIA's submission with regards to the 2026-2027 Statement of Priorities. |
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| Property and Casualty and General Insurance | [2025-010] Margaret Wasserman - Insurance Institute of Canada
Thank you for the opportunity to provide feedback please note our attached response. |
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| Financial Planners and Financial Advisors | [2025-010] Mario Hadjiyianni - Hadjiyianni Wealth/IPC
Dear FSRAO, Thank you in advanced for reviewing my comments. Did you know that only est. 25-37 % of Canadians use a financial advisor ? What happened to the remaining est. 63-75 % of Canadians ? The short version: FSRAO needs to focus on promoting the industry by airing commercials and infomercials in these key areas listed below. Ultimately to increase financial prosperity and literacy among all Canadians. Extending access to services and reaching more of the public. • Benefits in working with advisors to increase financial prosperity and literacy for Canadian families. May increase number of Canadians pairing up with an advisor • About regulated commissions (fee based & trailing) and how Advisors are regulated, promoted and compensated the same in the financial services industry. All are part of the retail lane of the financial services industry. May reduce stigma caused by special interest groups claims • Advocate to target low-income or Canadian’s in need of financial advice at critical moments and to obtain government funding for former Pro bono publico services performed The long version: After many years in the industry in various capacities, including a financial planner/advisor. Also, having a background in global business, life insurance and personal income taxes. Below are my suggestions for the financial services industry as many Canadian families are under serviced and generally have little to nil contact with financial advisors. There is a need for the FSRAO to perform more in re-building awareness of the value and importance of using a financial advisor. either on the internet, television commercials, events, etc. According to statistics and various surveys, only est. 25-37 % of Canadian work with a financial advisor. Only est. 21 % of Canadians are "extremely optimistic" about retirement, and recently in a post-COVID 19 era (the world-wide supply crunch) more and more Canadians are living with tighter budgets and falling short of financial stability while their financial literacy may lack identification of areas of focus. These are areas were a financial planner/advisor can fille the gap. Helping families make better decisions. 2026 is a critical time for Canada and by making the right decisions at the right time, it can help increase the financial well-being of many families. One person at a time. According to other stats, est. 45 - 50 % of Canadians lack an emergency fund and est. 22-26 % of Canadians have nil ($ 0.00) savings at all. These figures are concerning for the general outlook of the overall economic prosperity of Canada and for the size of the financial services industry. (** what will the future look like in 5, 10, 20 years from now? Will we only service Canadian families with $ 2 million in investible assets. That is comparable to other nations were most citizen lack even a personal banker. **) From personal experience, many Canadians are bombarded with false pretext narratives, miss-leading claims on low-quality and cheaper products, and about the general sense of investing money. According to a 2020 CIRANO report, Canadians working with an advisor have approx. 2.36x (236%) more wealth as a result in making better decisions. Timing is critical. While the others are missing out on critical considerations and points of concentration, they are unaware certain topics in making decisions. Falling short of wealth and loosing opportunity. This is an economic issue, not just a financial services issue. It means, less people have access to education, less households have enough savings to safeguard against emergencies, and an increase in food instability. Below are points I personally would like our industry to focus on as opposed to focusing on other requests to the industry. 1. FSRAO promotion of the industry by delivering commercials and infomercials about benefits of working independent and institutional advisors - may potentially increase the number of Canadians that work with a financial advisor in making critical decisions. Reducing the high level of financial illiteracy rate in Canada. (means to make better informed decisions, robust and complex considerations that incorporates better outcomes.) Finding a long-lasting relationship with an advisor, especially for independent and un-biased advisors. 2. FSRAO promotion of the industry by delivering commercials and infomercials explaining that independent and institutional advisors are operating on a retail level and are not third-parties to the industry when compared to others in the industry - Explaining that retail level trailing commissions and fee-based are regulated and part of product costs. There needs public awareness that product manufactures distribute those costs to all retail lanes, unless otherwise agreed to a fee-based account – And also the term "embedded" is generally miss-leading context (in appropriate) as it plays into one group of competitors message to the public. Trailing commissions are not hidden, they are displayed and the share prices are net of trailing costs. as opposed to gross of trailing cost. By FSRAO promoting the industry, like other industry associations do, this will help build more trust in the public space. Helping to form lasting advisor-client relationships with un-biased recommendations. Many prospects and clients are miss-led by many areas that result in damaging financial loss of opportunity to clients. Causing them to do nothing when the messages are confusing. By airing commercials or infomercials explaining the benefits of working with an advisor and that they are all compensated similar in the “retail lane” through “product manufacturers”. 3. FSRAO promotion of the industry by advocating for the under-serviced population, employers of the under-serviced, and to help identify when a good time is to connect with a financial advisor. - In helping clients, the advisor only has approx. 30-80 minutes to perform in front of the client. Many times, people get motivated after the fact in making financial decisions. By building awareness of critical times to get in contact with an advisor it can help them make better decisions. And, for clients with low-income but require advice in budgeting, debt management, financial planning, personal income taxes it could be beneficial if the FSRAO can advocate with the Federal or Provincial government to provide short-term funding to help cover costs for clients going through severe economic hardships. This means, to pay the retail lane member for the services performed for the low-income client. We do perform a pro bono service for people who may ask for help. But, Pro Bono Publico services only has a limit due to timing and efforts required. If the government can funds a one time cost, we can spend more time with clients to help them progress further. In summary, our industry is well-structured in many areas, but a number of Canadians are left behind from our progression. It may be time for the FSRAO and others to collectively promote and advocate our industry’s expansion to reach more Canadian ! Looking forward for hearing some considerations about expanding awareness to reach more Canadians. Regards, Mario Hadjiyianni |
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[2025-010] Consumer Advisory Panel to The Financial Services Regulatory Authority of Ontario (FSRA) - Consumer Advisory Panel to The Financial Services Regulatory Authority of Ontario (FSRA)
The Consumer Advisory Panel had the opportunity to participate in this consultation. The Panel's official submission provided in the attached document. |
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| Cross Sector | [2025-010] Kamal Smimou - Ontario tech University
Dear I hope that your institution should open the door for more academic collaboration with professors and graduate students to enhance your offerings of various digital financial products including but not limited to new innovative instruments and products. It is time for your institutions to embrace quickly digital financial services & products. Academic and scholarly contribution will certainly offer you opportunities for testing and exploring those rewarding opportunities. Regards, |
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| Mortgage Brokering | [2025-010] Samantha Gale - Canadian Association of Private Lenders
December 10, 2025Financial Services Regulatory Authority of Ontario 25 Sheppard Avenue West, Suite 100 Toronto, ON M2N 6S6 By Online Submission Attention: Consultations – 2026–27 Proposed Statement of Priorities Re: Canadian Association of Private Lenders (CAPL) Comments on FSRA’s 2026–27 Proposed Statement of Priorities The Canadian Association of Private Lenders (CAPL) appreciates the opportunity to comment on the Financial Services Regulatory Authority of Ontario’s (FSRA) 2026–27 Proposed Statement of Priorities (the “SOP”). CAPL represents private mortgage lenders, mortgage investment entities, and related service providers across Canada. Our industry members are a critical source of credit for borrowers who may not be fully served by traditional institutions, including small business owners, self-employed borrowers, new Canadians, and those with non-standard income profiles. We support FSRA’s objectives of financial safety, fairness, and choice for Ontarians and share FSRA’s interest in a modern, agile, principles-based regulatory framework that protects consumers while enabling innovation and access to credit. Balancing Principles-Based and Rules-Based Oversight in the Mortgage Sector CAPL supports FSRA’s stated ambition to “embrace and embed principles-based oversight” and to apply “principles-based, proportional, risk-based, and outcomes-focused regulation.” We agree that a purely prescriptive, rules-heavy regime can become rigid and slow to adapt to innovation. However, in the mortgage sector, and particularly in licensing, supervision, and market conduct, principles-based oversight must be anchored in a clear, predictable rules-based foundation. Without this balance, there is a risk that: Regulated entities are uncertain about FSRA’s expectations, leading to inconsistent compliance approaches. Bad actors exploit ambiguity to engage in misconduct under the guise of “principle-driven judgment.” Smaller firms and new entrants, including many private lenders, face disproportionate burdens interpreting open-ended guidance without the in-house legal and compliance resources of larger institutions. From CAPL’s perspective, an effective framework for mortgage brokers, agents, and private lenders should combine: Clear, enforceable baseline rules for licensing, disclosure, conflicts of interest, suitability, advertising, KYC/AML, and fraud-related controls; and Principles-based guidance that allows for proportional, risk-sensitive implementation and innovation in processes, technology, and business models. We encourage FSRA, in its work under the SOP (including Priority 3 “Advance FSRA’s regulatory approach and strengthen supervisory effectiveness” and Priority 4 “Support government priorities and objectives”), to: a) Explicitly recognize in its Strategic Framework and related SOP materials that principles-based oversight in the mortgage sector will be complemented by clear minimum rules in high-risk areas (for example, licensing standards, fraud controls, and consumer disclosure). b) Develop decision-making tools and guidance (as referenced in Priority 3) that translate high-level principles into concrete expectations and examples for mortgage licensees, especially smaller private lenders and brokerages. Mortgage Fraud: Data Trends and Persistent Risks FSRA’s environmental scan correctly highlights technology-enabled fraud and cyber-related risks as growing threats. In the mortgage space, the picture is nuanced. Public data and industry experience indicate that: Some categories of mortgage fraud show signs of moderating. For example, Equifax Canada has reported that certain overall indicators of mortgage fraud have eased. At the same time, Equifax and industry participants emphasize that falsified documents remain “rampant,” with increasingly sophisticated forgeries and synthetic identities enabled by readily accessible digital tools and generative AI. From a private lender perspective, these trends underscore that: Apparent improvements in aggregate fraud metrics do not mean the risk is resolved; rather, fraud techniques are evolving and becoming harder to detect. Fraud risk is increasingly concentrated in specific channels and borrower segments, where controls are uneven or gaps exist between regulated and unregulated participants. Smaller lenders and brokerages may face greater challenges in detecting sophisticated document fraud without shared tools, guidance, or data from regulators and larger institutions. In light of this, CAPL recommends that FSRA: a) Treat mortgage fraud as a continuing, high-priority risk area despite reports of aggregate fraud declines, and continue to invest in analytics, data sharing, and supervisory tools that can detect emerging fraud typologies (including falsified documents and synthetic identities). b) Use a rules-plus-principles approach for fraud-related expectations in the mortgage licensing regime, including: Baseline, prescriptive requirements for identity verification, document verification, and record-keeping; and Principles-based expectations around ongoing monitoring, use of technology, and escalation practices, proportionate to a licensee’s size, complexity, and risk profile. c) Leverage technology-driven initiatives under Priority 2 “Strengthen technology and data capabilities in supervision” to support sector-wide fraud detection, for example by: Promoting or enabling secure, privacy-compliant data sharing about confirmed fraud cases and typologies; and Encouraging the adoption of standardized digital verification tools that can be used across lenders and intermediaries. Technology in Mortgage Origination and Supervision (AI and Digital Tools) Technology is reshaping mortgage origination, servicing, and supervision. Industry members are increasingly using digital tools and artificial intelligence (AI) in: Automated income and document verification Risk assessment and product matching Marketing and borrower engagement (for example, chatbots and “virtual agents”) These tools can improve speed and consistency, but they also introduce: Fair lending and bias risks, where AI models reflect or amplify historical inequities. Opacity around decision-making (“black box” underwriting), limiting borrowers’ ability to understand and challenge adverse decisions. Heightened privacy and data-security risks, given the volume and sensitivity of information processed. New fraud vectors, including AI-generated falsified documents, deepfakes, and synthetic identities. From CAPL’s vantage point, an effective regulatory response should: Encourage responsible innovation by allowing AI-enabled tools in compliance and underwriting, while ensuring that licensees remain accountable for outcomes and consumer protection. Set clear expectations (through a mix of high-level principles and illustrative rules) around governance, testing, documentation, and human oversight of AI systems used in mortgage decision-making. Address AI-enabled fraud explicitly in FSRA’s risk-based supervision frameworks and fraud guidance, aligned with Priority 2 and Priority 3 of the SOP. Conclusion CAPL supports FSRA’s efforts to modernize its regulatory approach and to adopt principles-based, outcomes-focused oversight. In the mortgage sector, we believe that: Principles-based oversight must be grounded in clear, baseline rules, especially for licensing, fraud controls, and consumer protection. Fraud risk remains significant, even where some indicators show improvement, and must be addressed through both prescriptive requirements and flexible, technology-enabled practices. Rapid technological change requires coordinated, forward-looking regulation that does not inadvertently drive activity into unregulated or lightly regulated channels. Yours very truly, Samantha Gale Chief Executive Officer Canadian Association of Private Lenders [email protected] |
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| Auto Insurance | [2025-010] Jaden Bailey - Invicta Works
I am submitting this feedback as a registered social worker supporting clients engaged in auto insurance rehabilitation under the Statutory Accident Benefits Schedule (SABS).I write to advocate for the formal inclusion of registered social workers as recognized health professionals under the SABS framework, specifically as it pertains to the authority to participate in and sign OCF-18 treatment and assessment plans. Currently, social workers are excluded from this role, even though we are regulated professionals governed by the Ontario College of Social Workers and Social Service Workers (OCSWSSW), with clearly defined accountability, ethical standards, and continuing competency obligations. This exclusion often creates unnecessary treatment delays, reduces oversight in client care, and increases administrative burden for claimants who may not have timely access to other regulated providers. This advocacy aligns directly with several of FSRA’s 2026–27 strategic priorities: 1. Transforming Capabilities – Transparency, Efficiency, and Timely Oversight Social workers play a critical role in ensuring that claimants understand treatment plans, consent to recommended services, and access supports promptly. Recognizing social workers under SABS would reduce delays and streamline rehabilitation access, supporting FSRA’s goal of a more efficient, transparent system. 2. Fraud Prevention and Ethical Service Delivery FSRA’s focus on fraud prevention and consumer protection would be strengthened by including social workers in treatment oversight. Social workers verify that services are provided as documented, support informed consent, and identify inconsistencies that may suggest fraudulent practices. This role helps protect clients from exploitation while supporting ethical standards of care. 3. Embracing Principles-Based, Outcomes-Focused Regulation Social workers contribute to outcomes-focused rehabilitation by supporting clients holistically—from return-to-work planning to system navigation. Our practice complements medical and therapeutic services while ensuring client-centred care is delivered equitably and efficiently. 4. Promoting Collaborative Partnerships Social workers operate at the intersection of health, legal, and insurance systems. Recognizing our role under SABS would formalize our contribution and enhance collaboration across sectors, in keeping with FSRA’s third pillar of proactive partnership. Recommendation: That FSRA consult with the Ontario College of Social Workers and Social Service Workers and relevant ministries to consider an amendment to SABS regulations to include registered social workers as health practitioners with the ability to sign OCF-18s. This would improve service access, protect claimants, and enhance system integrity. I appreciate FSRA’s continued commitment to improving Ontario’s financial services and regulatory systems and welcome any opportunity for further discussion or consultation on this matter. |
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| Financial Planners and Financial Advisors | [2025-010] Dino DiMarco
To:Financial Services Regulatory Authority of Ontario (FSRA) 25 Sheppard Avenue West, Suite 100 Toronto, ON M2N 6S6 Re: Consultation Feedback – Proposed 2026–27 Statement of Priorities and Strategic Framework To Whom It May Concern, Thank you for the opportunity to provide feedback on FSRA’s proposed 2026–27 Statement of Priorities and five-year Strategic Framework. I commend FSRA for continuing to modernize regulatory oversight while prioritizing consumer protection, transparency, and industry collaboration. As a financial professional with over 39 years of experience in banking, lending, and mortgage operations, including residential and commercial lending limits of up to $1 million, training mortgage specialists, and developing a mortgage underwriting micro-credential for Humber College, I have seen firsthand how regulatory clarity and consumer education directly affect financial outcomes. Additionally, through extensive work delivering financial literacy education to newcomers, seniors, Indigenous communities, small business owners, and vulnerable populations across Ontario, I observe daily the challenges consumers face in navigating the financial services marketplace—particularly the mortgage sector. This experience has shaped the recommendations I respectfully submit below. 1. Embed Financial Literacy as a Core Component of Consumer Protection FSRA’s regulatory objectives would be significantly strengthened by explicitly emphasizing consumer understanding and financial literacy across its Strategic Priorities. Many Ontarians struggle to understand mortgage terminology, risk exposure, renewal implications, or prepayment structures—factors that directly influence suitability and long-term financial stability. Vulnerable groups such as newcomers, seniors, and low-income households face even greater barriers. Recommendations: Integrate financial literacy expectations into the Principles-Based Regulation framework. Develop standardized, plain-language educational materials for key mortgage concepts and consumer risks. Expand partnerships with colleges, nonprofits, and community educators to increase access to unbiased financial information. These initiatives would meaningfully strengthen FSRA’s consumer protection outcomes. 2. Strengthen Principles-Based Regulation (PBR) With Sector-Specific Guidance While I fully support FSRA’s commitment to PBR, mortgage sector stakeholders—particularly smaller brokerages—continue to face uncertainty in interpreting regulatory expectations. Recommendations: Provide mortgage-specific examples of appropriate PBR outcomes. Release periodic guidance or case studies illustrating effective supervisory practices. Offer optional training modules for licensees to support compliance consistency. These supports would reduce ambiguity and enhance supervision quality without increasing regulatory burden. 3. Improve Access to Mortgage Market Data and Risk Insights Modernization of FSRA’s technology and data systems is a significant step forward. Making more data accessible to licensees, educators, and the public will improve risk detection and enhance financial confidence. Recommendations: Expand open-data dashboards with mortgage trends, complaints data, and enforcement insights. Present data in plain language to support consumer comprehension. Ensure community-based financial educators can easily access and integrate risk information into curriculum and workshops. Improved data transparency will elevate both consumer and industry decision-making. 4. Deepen Collaborative Partnerships With Underserved Communities FSRA’s Strategic Framework highlights the importance of proactive collaboration. In my work with Indigenous organizations, newcomer agencies, BIAs, and municipal partners, I consistently see the need for stronger financial education and regulated pathways to safe mortgage credit. Recommendations: Prioritize partnerships with organizations serving vulnerable or financially marginalized groups. Establish a Consumer Education Advisory Circle to identify emerging risks and educational gaps. Encourage mortgage brokerages to demonstrate accessible, culturally sensitive consumer support under PBR expectations. These investments would help reduce financial harm and improve equity across Ontario’s financial services environment. 5. Enhance Transparency in FSRA’s Budget and Success Measures I appreciate FSRA’s commitment to publishing the draft budget for consultation. Aligning financial resources with the Strategic Framework is critical for public confidence. Recommendations: Provide a breakdown of capacity-building investments supporting modernization, oversight, and consumer education. Share performance indicators linked to consumer outcomes—not only industry compliance. Clarify how new resources will support supervision of higher-risk or rapidly evolving market segments. This transparency will help stakeholders better understand FSRA’s strategic direction and priorities. 6. Guide Safe Innovation in a Rapidly Changing Mortgage Marketplace As mortgage technology evolves—including AI-driven underwriting, digital brokerages, and alternative lending pathways—FSRA’s modernization efforts are essential to safeguarding consumers. Recommendations: Provide early regulatory guidance for AI and automated decision-support tools in mortgage suitability assessments. Encourage pilot programs that responsibly expand access to credit for newcomers and individuals with thin credit files. Maintain strong consumer safeguards as digital platforms continue to accelerate. Balancing innovation with consumer protection will be crucial to maintaining trust and stability in the mortgage sector. Conclusion FSRA’s proposed Strategic Framework is thoughtful, forward-looking, and appropriately aligned with Ontario’s evolving financial services landscape. By more deeply integrating financial literacy, sector-specific guidance, transparent data, and stronger partnerships with vulnerable communities, FSRA can significantly enhance consumer outcomes—especially within the mortgage brokering sector. I appreciate the opportunity to provide feedback and would welcome continuing to support FSRA’s work, including through participation on the Mortgage Brokering Technical Advisory Committee, where I believe my experience in banking, mortgage operations, financial literacy, and community-based education would offer valuable perspectives. Thank you for your consideration. Sincerely, |
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