Life and Health Insurance
Public comment closed
Comment Due Date

The Financial Services Regulatory Authority of Ontario (FSRA) continues to focus on increasing protection for life and health insurance consumers.

FSRA is now consulting on proposed guidance on licensing information that life agents must report under the Insurance Act (Act). It also outlines insurers’ related obligations to ensure agent suitability, even if they delegate oversight functions to third parties. The proposed guidance provides FSRA’s Interpretation of legal requirements under the Act and its Approach to monitoring and enforcing compliance with these requirements.

FSRA collects licensing information to assess if an agent is suitable and qualified to continue conducting insurance business. FSRA also uses this information to determine where to focus its compliance review efforts. This aligns with our risk-based approach to supervision.

This consultation is now closed.

Useful links:

Thank you for your feedback on FSRA’s proposed guidance on Life Agent Reporting Requirements and Related Insurer Obligations. Your feedback helped inform our final guidance, which we have now posted. A summary of stakeholder feedback is now available.


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.

Use left and right arrows to navigate between tabs.
Sector Comment Date posted Sort ascending
Life and Health Insurance
[2021-015] Harold Geller and MBC Law Professional Corporation

Life and Health Insurance
[2021-015] Susan Allemang - Independent Financial Brokers of Canada
Attached is the comment letter from Independent Financial Brokers of Canada (IFB)
Life and Health Insurance
[2021-015] Callum James - Oliver Publishing Inc.
Please accept the following comment letter on behalf of Oliver Publishing Inc.
Life and Health Insurance
[2021-015] Michael Scott - Advocis
Dear Sirs/Mesdames,

On behalf of Advocis, The Financial Advisors Association of Canada, please find attached a response to FSRA's consultation on life agent reporting and insurer oversight obligations guidance.

Best Regards,
Michael Scott
Associate Director, Legal and Regulatory Affairs
Life and Health Insurance
[2021-015] Justin Glinski - Canadian Life and Health Insurance Association
Attached please find CLHIA's comments on FSRA's consultation on life agent reporting and insurer oversight obligations guidance

[2021-015] Parachute Digital Solutions Inc. - Parachute Digital Solutions Inc.
With regards to the new requirement for each life insurance agent to obtain its own E&O policy, we would like to point out that given the hard market, this change may make it very difficult for some agents to obtain the required E&O insurance. If the concern is about the sharing of limits among agents covered by one policy, we propose to increase the required limit on the policy of the corporate agency.
With regards to the requirement of Agents reporting within 5 business days from the effective date the name of every insurer the agent acts on behalf of, we suggest the timelines be extended to 30 days, as in Quebec. Many insurance agencies operate nationally so it is more efficient from an operational perspective, and reduces the likelihood of late reporting when the time periods for reporting are the same in various provinces.
Life and Health Insurance
[2021-015] Moulay Younes Said Alaoui
i have resigned as direct employee with [name withheld]
Life and Health Insurance
[2021-015] Hilda Wynne
I have been in business since 1975 and will give up my license in July 2022. I remember in the very beginning that there were cases that should not have been approved but because an AGENT didn't tell the truth, cases would go through.
Today, we are insuring much more insurance savvy people, so that is a plus.
I served on the tribunal for FSCO and had the opportunity to witness complaints made by clients, only once were we successful in pulling a license for life.
So yes, I think it is important to hold agents/brokers accountable.
Having said that, I have also witnessed insurers being incompetent or careless when it comes to clients needs, or even issuing policies. This has been a huge issue when insurance companies were bought and people, who were then hired, were unfamiliar with the products from the previous companies. I more than once would have to tell a person what to look for and how to make the changes on existing policies. Certainly didn't get paid for that. This has not improved over the years. So, the question is, who monitors insurers?
Life and Health Insurance
[2021-015] Kimberley Gretton
Reviewed guidelines. Seem straightforward and clear
Financial Planners and Advisors
[2021-015] Debbie Hartzman
After a recent problem with a transfer of representative, it is easy to see how clients can become disadvantaged due to compensation structures that only advantage the sales representative!! When you front load all commission and trailers, a charge back to the new advisor who has never received any compensation is levied if the client wants to access funds prior to the expiry of the fee schedule. To add insult to injury the new servicing agent is deemed to bought this business from the original agent. This means the client is virtually stuck with the originating agent until fees drop off. I fail to see how this is in the best interest of a client. This type of payment scheme would never be acceptable to the MFDA and should not be acceptable to insurance agent!!!
Life and Health Insurance
I just want to say Big thanks for this awesome information’s getting here to learn and also used it for training my team, I really appreciate the good work and the awesome information’s here.
Thanks a lot.
Roland Kolusade. (WFG)
Life and Health Insurance
If I understand correct FSRA is doing their job well.
Life and Health Insurance
[2021-015] Perpetue Nitunga
This might be complicated.
Life and Health Insurance
[2021-015] Mario Porco
Thank you
This is excellent and outstanding.
Life and Health Insurance
[2021-015] Dan Boyd
Compliance not tough on seg. funds. Too many advisors leave mfda to get around Compliance requirements and operate on the margin in the insurance sector. Insurance companies who Want the distribution, don't do enough to stop this practice.
Life and Health Insurance
[2021-015] Sharon Wigle
I believe, strongly, that there should be increased educational requirements for ALL Advisors in the investment field, insurance or otherwise.
Canadians expect a certain level of education for other professions, like the accounting and legal professions; however, those Advisors engaged for the purpose of investing Canadians' hard-earned savings only require a high school education and 60% on an easy exam(s). As a result of these low barriers to entry, several unscrupulous individuals have entered the field with the sole purpose of making as much income as possible, with very little concern for the client. The industry is riddled with Advisors who have absconded with millions of their clients' assets. Setting the educational bar higher should discourage much of this behaviour as there are easier ways to steal money from people rather than putting in years of education and enduring rigorous examinations.
Beyond stealing client money what often falls under the radar are client losses due to uninformed advice. I can't tell you how many cases pass over my desk where I have witnessed poor advice in the form of inadequate investment diversification (often due to sheer laziness on behalf of the Advisor and or costs imposed by their Dealer/ MGA); not naming beneficiaries in a tax-efficient manner; poor tax planning; etc...
Lower educational requirements 25+ years ago was bad enough; however, in an environment of increasingly complex products, it is ridiculous and unacceptable. Canadian investors deserve better and industry regulators need to work harder to restore investor confidence in this industry.
Life and Health Insurance
Have read requirements and full understand
Date posted Sector Question and response
Life and Health Insurance

Question: Hi there, can you confirm whether there are new items in this proposed guidance? All seem to be the same as previously indicated, but I want to be sure I don't miss highlighting a new item. For example, timelines such as the 5 business day requirement to update. Although, I don't believe this is new.

Kind regards,

FSRA response:

Under FSRA’s licensing process, life agents must attest to completing 30 hours of CE courses and provide, on request, details and/or proof of CE courses taken. The Guidance introduces a new requirement for all agents to report the details of CE courses when they apply to renew their licence. They must do so by providing FSRA with the following details in order to submit their renewal application: 

  • course name 
  • course provider 
  • CE hours 
  • date of completion

Agents will be advised of the new requirement in the licence renewal notice email.

  • The requirement to report changes to contact information within 5 business days is an existing requirement under the Insurance Act.  

Question: Is the proposal indicating that the 30 hour CE details will be provided regularly by agents, and not randomly asked for moving forward?

To confirm that CE hours have been completed, agents are required to report the following details[8]:
course name
course provider
CE hours
date of completion

FSRA response:

Yes. All agents must report the details of completed courses on each renewal application. 
FSRA will not routinely require agents to file evidence of CE course completion. This may be requested when an agent has a history of current or prior complaints, enforcement actions or suitability concerns, or when FSRA conducts spot-checks, thematic reviews, or other supervisory examinations.

Question: With respect to the CE requirements and repeating a course, that is in reference to no repeating the course within the two year period, correct?   

CE hours cannot be claimed for:
a course in respect of which course details cannot be supplied;
a course/program the agent registered for but did not attend;
hours spent as an instructor or teaching a course;
repeating a course, unless there is new content; or
hours spent on courses that an agent fails.

FSRA response:

CE hours cannot be claimed for repeating a course within the same two year period. A course repeated in a future two year period is acceptable only if there is new content.