ID
2024-002

Type
Policy
Sector
Cross Sector
Status
Open
Date
Comment Due Date

The Financial Services Regulatory Authority of Ontario (FSRA) wants to hear from you about its proposed approach to strengthen the protection of vulnerable consumers in its regulated sectors. This will include consulting on the definition of Vulnerable Consumers ensuring a shared understanding amongst FSRA, its regulated entities, its stakeholders and the public. Consumers are those who purchase or benefit from products and services delivered by the sectors that FSRA regulates, including pension plan beneficiaries and credit union members.

FSRA’s Proposed Approach to Strengthen the Protection of Vulnerable Consumers focuses on two goals:

  1. Promoting inclusive and fair treatment of vulnerable consumers and preventing targeted financial mistreatment.
  2. Improving consumer education, engagement, and awareness building efforts.

FSRA invites consumers, industry and other interested stakeholders to submit feedback until March 8.

Learn more:

Once the consultation concludes, FSRA will publish a consultation summary report and next steps in finalizing and implementing its proposed approach.

FSRA continues to work on behalf of all stakeholders, including consumers, to ensure financial safety, fairness, and choice for everyone.

Learn more at www.fsrao.ca.

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Before we begin, please make sure you do not include any personal or private financial information. If your inquiry does require this information be shared with us, please call us at 1-800-668-0128 or email us at [email protected] for instructions.

By submitting your content, you agree to have your materials posted on our engagement portal, used in reports and other materials prepared by Financial Services Regulatory Authority of Ontario (FSRA) that may be shared with the public. Content is moderated so that all posts are respectful and professional. The Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c.F.31, applies to all online content.

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Sector Comment Date posted Sort ascending
[2024-002] Karin Ots - Aviva Canada Inc

[2024-002] Robin Ford
Thanks for the opportunity to comment. I think the UK Financial Conduct Authority has it about right - https://www.fca.org.uk/firms/treating-vulnerable-consumers-fairly/ensuring-fair-treatment and https://www.fca.org.uk/firms/treating-vulnerable-consumers-fairly. The FCA guidance (and FSRA proposal) relies on indicia of vulnerability. It is crucial to avoid stigmatizing specific groups such as "seniors" (however that is defined) or the "disabled" (ditto) by describing the group as a whole as "vulnerable". That is obviously discriminatory; some might say offensive. See also this video "Stop Stereotyping Seniors" with Rudy Buttignol, President of the Canadian Association of Retired Persons or CARP - https://www.youtube.com/watch?v=6WGpQewUCdM. It appears that FSRA is on track to avoid stereotyping (and to follow in the footsteps of the FCA). Please do not waiver! I add only that without effective enforcement, this guidance will fail and related expectations will be dashed. If the FSRA is serious about this, enforcement should be added to the list of activities in the proposed guidance.
Auto Insurance
[2024-002] Dave Gaylor - Acquired Brain Injury Survivor Solutions (ABISS)

ABISS (Acquired Brain Injury Survivor Solutions) is comprised of a group of people who have experienced the many challenges associated with surviving a brain injury as a result of a trauma. We look to find ways to positively adjust to drastically changed lives while at the same time coping with misunderstanding and at times disregard for how much its affects were felt in the lives of not only ourselves but our families as well.
Please see abiss.ca for more information and specific examples of problems with the automobile insurance sector.
We would suggest the following groups representing vulnerable consumers that FSRA should directly engage with:
Ontario Brain Injury Association obia.ca
Spinal Cord Injury Ontario sciontario.org

Health Service Providers
[2024-002] Kerri Olds-Rhinds - Kore PMT
Good Afternoon FSRAO,
I applaud your approach to highlight, include and make accommodations for vulnerable consumers. My suggestion would be to implement the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). Many of these standards can be applied to vulnerable consumers. I would also recommend a vulnerable consumer department and/or task force who are trained to help vulnerable consumers and that adjusters dealing with vulnerable persons receive in-person or virtual training to best serve this group. Having worked with patients/clients in this category, we find we require additional patience, understanding and resources to help them navigate insurance requirements and procedures. Often they have difficulty reading and understanding documents that are sent to them, or they did not understand the conversation they had with their insurance adjuster. We are happy to work with insurers and do our best to strengthen the relationships they have with our patients to ensure they meet these requirements and procedures. Thank you for looking at how to improve this relationship!
Date posted Sector Question and response
Life and Health Insurance

Question: Does the March 4, 2024, Virtual seminar provides CE credits as well?

FSRA response:

Thank you for submitting your question on the webinar for Consultation on FSRA’s Proposed Approach to Strengthening Protection of Vulnerable Consumers. Here is the link to register if you have not done so yet. To clarify, the webinar is on Thursday, February 8th from 12 to 12:30 p.m. EST. The webinar will share information about FSRA’s proposed approach to strengthen protection of vulnerable consumers and provide and opportunity to ask questions of FSRA’s Chief Consumer Officer, Stuart Wilkinson.  The webinar does not provide continuing education (CE) credits.