Cross Sector
Public comment closed
Comment Due Date

Thank you for providing your feedback on FSRA’s Proposed 2022-23 Statement of Priorities and Financial Plan.

We appreciate the comments and questions received to date. Your feedback helped to inform our final Statement of Priorities.

The request for submissions is now closed. 

Learn more about this consultation

Stakeholder engagement through public consultation is an essential part of FSRA’s commitment to transparency and accountability. In addition to targeted consultations with FSRA’s Stakeholder Advisory Committees and Consumer Advisory Panel, FSRA also invited the general public and all stakeholders to review and provide feedback on the proposed 2022-23 Statement of Priorities and Budget

The draft priorities outline cross-sector and sector-specific initiatives focused on improving regulatory efficiency and effectiveness to better serve the public interest. The Financial Plan reflects FSRA’s proposed expenses, strategic investments and sources of funding, to achieve its mandate and stated priorities.

The Statement of Priorities and Budget will form the core of FSRA’s Annual Business Plan to be submitted to the Minister of Finance for approval by February 28, 2022.

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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
Property and Casualty and General Insurance
[2021-016] Grant Kelly - PACICC
Please find the attached letter from PACICC.
Mortgage Brokering
[2021-016] Paul Taylor - Mortgage Professionals Canada
Good morning, Huston,

Thank you for the opportunity to respond a couple of days past deadline to FSRA’s statement of priorities consultation. Please see attached a short letter of support for your current undertakings and one request for consideration of an industry clarification which MPC believes would better align industry practises with consumer and regulatory desired outcomes.

Please don’t hesitate to have one of your team reach out should you have any questions.

I hope you have a great week ahead.
Credit Unions and Caisses Populaires
[2021-016] Nick Best - CCUA

[2021-016] Peter Hohman, MBA, FCIP, ICD.D President & CEO
I attaching the Insurance Institute of Canada’s response to your request for feedback on the 2022-23 Statement of priorities.
Thank you for the opportunity to provide feedback.
Best Regards,
Margaret Wasserman

Margaret Wasserman, Hons. BSc, CIP
Senior Director
[2021-016] Terri Botosan - HUB Financial
Good afternoon
Please find attached HUB Financial comments pertaining to above mentioned Consultation.
Unfortunately, I was no successful in uploading the attached into the portal.
Please redirect this response to the correct area.
Thank you,

Risk & Insurance | Employee Benefits | Retirement & Private Wealth
Ready for tomorrow.

Kim Moffatt
Director, Insurance Compliance
Credit Unions and Caisses Populaires
[2021-016] José Gallant - Alterna Savings

Life and Health Insurance
[2021-016] Brenda Molnar - CAILBA

Auto Insurance
[2021-016] Rhona DesRoches - FAIR Association of Victims for Accident Insurance Reform
FAIR Association of Victims for Accident Insurance Reform
579A Lakeshore Rd. E., Box 39522, Mississauga, ON, L5G 4S6
[email protected]

October 29, 2021
FAIR submission to: FSRA Proposed FY2021-2022 Statement of Priorities

FAIR (Fair Association of Victims for Accident Insurance Reform) is a grassroots not-for-profit organization of Ontario’s MVA (Motor Vehicle Accident) survivors who have struggled with access to recovery resources under the current auto insurance system.

Thank you for the opportunity to comment on the FSRA Proposed FY2021-2022 Statement of Priorities. Our comments will be directed toward auto insurance issues and Section 4 of the Proposed Statement of Priorities.

We can appreciate the effort that the FSRA has already invested to strengthen the Consumer Office and the language in this Statement reflects a desire to make good on the promise of a better and more consumer focused agenda going forward.

Ontario’s auto insurance consumers are just now coming to realize that while they were hunkered down during the height of the Covid pandemic auto insurers were pocketing a record profit in excess of $3.6 billion in 2020. We see no indication in this statement that the Regulator, who is entrusted with protecting the public’s interest, is planning on holding insurers to account when it comes to the cost of premiums. By FSRA’s own press release [1] auto insurers paid over $600 million in claims and there were only 46,000 new claimants last year – a significant drop in costs and record breaking profits [2] should result in a premium adjustment for consumers and not a declaration of a fraud war on claimant access to rehabilitation providers. We are mindful that Ontario’s auto insurers have expressed a desire to be in complete control of claimant healthcare delivery. We agree that fraud exists in all sectors but putting undue pressure on rehab providers will force many of the most experienced to leave what is now the lowest paying rehabilitation resource sector – auto insurance.

FSRA appears to be focusing on insurer profit and the ‘modernization’ of auto insurance and that may be more of a wish than actual support [3] from consumers for the increased use of telematics in vehicles. Now that insurers have been given the go-ahead to penalize their customers who may have less than ideal driving habits, it stands to reason that there may be less participation in these programs given the overall lack of public trust in this industry. We would urge the Regulator to take a closer look at consumer privacy and to set goals regarding how to protect consumers from unfettered access of their personal information by auto insurers in both the use of usage-based insurance (UBI) and in the information gathering during the claims process and the OCF-1 form [4] .

As the Regulator monitoring compliance with the obligations that insurers have to their customers, it is incumbent on FSRA to maintain the quality and standards of the delivery of auto insurance within the parameters of the Insurance Act. To consumers, this means there must be an interest and a stake in the quality of the outcomes of their contractual relationship with insurers when they make a claim. We are aware that a significant number of claimants that are delayed or denied coverage end up on social supports such as taxpayer funded OW and ODSP so the need for timely regulation enforcement matters to all Ontarians. Outcomes matter to us all so the Regulator cannot be just about the financial transaction with insurers but it also needs to be about the process to serve these injured consumers.

What the system today would tells us:
• There is a significant likelyhood that a claimant will end up seriously financially harmed in the broken claims process. An already slow system has been made worse by the Covid pandemic.
• It is far more likely claimants will receive less care and end up on our social nets and living far below the poverty line. This will not improve medical outcomes.
• There are 56,283 (2019 / 2020 StatsCan) lined up at Ontario’s Civil courts. No personal injury car crash case has been heard since the pandemic began. Insurers continue to insist on the use of juries when they know it isn’t possible and there is no downside for them since interest on overdue payments is so low. There is nothing to discourage insurers behaving badly or from their overuse of our courts to beat claims down.
• There are thousands more unpaid and untreated car crash survivors waiting at the Licensed Appeal Tribunal (LAT) Auto Accident Benefits System (AABS) for a hearing so they can access treatments. It takes many months to get a date for a conference, not a hearing, but a case conference, and that wait is often close to a year from the time of request. [5]
• The LAT most recent Decisions reveal that only one in ten claimants is successful at a LAT hearing where most decisions favor auto insurers by denying treatments. Many of the hearings are about the appeal process or ‘reconsideration’ that equate to making a request of the same trier-of-fact to rehear a case they’ve already adjudicated.
• One insurer continues to have high claims denials and the lion’s share of LAT Decisions (40% at last check) despite having only 16% of the market share in Ontario.

The above tells us that Ontario’s auto insurance is a system completely broken down and the only part that still works is the flow of funds from consumers’ pockets into the hands of insurers.

We point this out; not because FSRA necessarily has the power to change all of these things, but it is evident this massive failure to deliver on a promise of coverage made to 10 million drivers can only happen when the Regulator has failed to ensure the product has actual value.

This structural bias to favor auto insurers existed at the Financial Services Commission of Ontario (FSCO) and that undervaluing of consumer importance as a stakeholder in the millions of financial transactions with insurers has led us to this point in a broken system.

It’s evident that this bias exists within FSRA as well, no doubt as an unconscious effort to maintain good relationships with insurers. It’s evident in the FSRA consultations that are not open or actively inclusive to the public and in the case of auto insurance, these consultations are often impossibly short and difficult to understand. Consumers remain unaware of the reports that FSRA puts out because they aren’t told and they aren’t invited into the process. The recent 17 day long FSRA Stakeholder Engagement Survey [6] was an example of selectively shutting out the public. On inquiry we were told that no consumers in the FSRA complaints system were informed of the poll and it was only sent to FSRA News subscribers who were most likely working in the insurance sector. This is a huge miss when those who are purported to be at the center of the consumer protection are completely passed over in order to get a desired outcome. We note that insurance consultations, as listed on the FSRA website, consistently show tighter timelines for responses than other financial sectors.

Thank you for the opportunity to have our voice heard and we look forward to FSRA’s greater consumer focus in 2022-23.

FAIR Association of Victims for Accident Insurance Reform

[1] FSRA identifies supervision focus in the health service provider sector

[3] With 81% of polled Canadians yet to try UBI, brokers have opportunity to educate and sell
[4] Application for Accident Benefits (OCF-1)
[5] Updated LAT Statistics
[6] Online survey: FSRA stakeholder engagement survey

Life and Health Insurance
[2021-016] Brendan Wycks - Canadian Association of Financial Institutions in Insurance (CAFII)
29 October, 2021

Mr. Mark White, CEO; and
Financial Services Regulatory Authority of Ontario
25 Sheppard Avenue West, Suite 100
Toronto, Ontario
M2N 6S6
[email protected]; and

RE: CAFII Feedback on Proposed FY2022-2023 Statement of Priorities

Dear Mr. White:

The Canadian Association of Financial Institutions in Insurance (CAFII) thanks the Financial Services
Regulatory Authority (FSRA) of Ontario for the opportunity to provide comments on FSRA’s Proposed FY2022-2023 Statement of Priorities.

In this submission, we have restricted our comments to those sections of the consultation document which are germane to CAFII members, i.e. to the sections on Environmental Scan, Cross-Sectoral Priorities, the Life and Health Insurance Sector-Specific Priority, and FSRA’s Proposed FY2022-23 Budget.

Environmental Scan
CAFII agrees with FSRA’s environmental scan observations and, in particular, your views on the implications of COVID-19. We believe that these are times of significant uncertainty for consumers, businesses, and regulators alike. Our members, and the entire life and health insurance sector, are operating in a time of unprecedented change, including environmental, social, and technological change. In today’s environment, insurance can be more important than ever for consumers, by offering them risk protection, peace of mind, and a measure of predictability amid the challenges and doubts that characterize the times.

We also agree with FSRA’s recognition that the pace of technological change is rapid and accelerating, and concur with the statement that

Digital sales of financial services were becoming more prevalent prior to 2022, and the pandemic greatly accelerated this trend. Regulated entities such as insurance companies/intermediaries … had to implement or improve digital sales channels to reach customers. (Page 5)

In connection with that pandemic-accelerated reality, CAFII recently commissioned a Pollara Strategic Insights survey on Canadians’ credit protection insurance (CPI) digitalization preferences, and an executive summary of its results is posted on the Research section (under News & Research) of our website. We were pleased to learn that Canadians feel well-served by our members’ digital CPI offerings. We also noted with interest that while consumers are generally comfortable communicating and transacting digitally with their insurance providers, a sizeable majority is looking forward to being able to interact in-person with branch representatives again, post-pandemic, in addition to having digital options at their disposal.

With respect to consumer issues, we took note of the Proposed Statement of Priorities’ assertion that “FSRA will also continue to monitor the overall value-for-money insurance consumers receive from their products and whether the products consumers are being sold are suitable.” (Page 7)

In that connection, CAFII must emphasize that with respect to CPI -- which operates under powers granted by the federal Bank Act and the related Insurance Business (Banks and Bank Holding Companies) Regulations, in addition to being provincially/territorially regulated – advice cannot be offered in connection with these optional Authorized Insurance Products; and, therefore, they are not offered by licensed individuals at financial institutions (FIs). That being the case, CAFII member customer service representatives are not permitted to assess “suitability” for customers interested in the protection offered by Authorized Insurance Products/CPI; instead, they assess customers’ “eligibility” to be enrolled for coverage under these group insurance products. Also, because the consumer is purchasing/enrolling in optional insurance related to a single and specific borrowing need such as a mortgage, line of credit, or credit card – and that scenario falls within the scope of activity permitted to occur through a non-advisory sales channel – consumers must be provided with sufficient information, which meets provincial/territorial regulations and industry commitments and guidelines, to enable them to make an informed decision.

We support the emphasis that FSRA has placed on monitoring cyber-technology risk and climate change risk. With respect to the latter, while climate change risk assessments have traditionally been focused solely on the P&C insurance sector, there is increasing recognition of the impact that climate change can and will have upon mortality, morbidity, and consequently life and health insurance. For those reasons, CAFII is actively monitoring these issues. We recently held a CAFII webinar on “Climate Science, Our Changing Planet, and Implications for Life Insurance” with co-presenter experts from RGA Reinsurance; and their presentation deck is available on the Research section (under News & Research) of our website.

Cross-Sectoral Priorities Related To “Regulatory Efficiency and Effectiveness”
CAFII agrees with and supports the three cross-sectoral priorities which FSRA has articulated under the heading of “Regulatory Efficiency and Effectiveness.”

With respect to the “Strengthen consumer focus” cross-sectoral priority; CAFII members, as major FI distributors and underwriters of CPI and travel insurance, make considerable investments in systems, processes, oversight, monitoring, employee training, and controls to support highly professional sales practices which are focused on appropriate products and fair treatment of customers.

We also support this priority’s emphasis on the importance of robust complaints handling systems; and the imperative for businesses to be committed to ongoing assessment of shifting consumer expectations. CAFII members are also committed to supporting consumers’ financial education and strengthening their financial literacy.

With respect to the “Enable innovation” cross-sectoral priority, we strongly support FSRA’s ongoing efforts in this area. The shifting needs of consumers and industry’s efforts to meet them are challenging the regulatory system to keep pace. The deliverables and outcomes specified by FSRA under this cross-sectoral priority are appropriate in our view. In that connection, we continue to advocate for the benefits of “regulatory sandboxes” which can provide a safe, monitored space within which to test innovative products and services while ensuring consumer protection.

In that connection, CAFII is pleased to have had, on October 29, a preparatory dialogue meeting with Glen Padassery, FSRA’s EVP, Policy and Consumer Office, and Marlena Labieniec, Director of FSRA’s Innovation Office; and we will now be collaborating with them on a follow-up virtual event which will provide an opportunity for CAFII members to learn about FSRA’s Innovation Framework and how to tap into it.

With respect to the “Modernize systems and processes” cross-sectoral priority, we encourage FSRA to continue to invest in its core technology and processes to make them as efficient as possible. We believe that technology will continue to have a profound impact upon financial services regulators, just as it is having upon industry. It is critical to FSRA’s effectiveness that it keep up with the pace of innovation through investments in technology.

We recommend, however, that the deliverable related to improving data interfaces and analytics will be most effectively achieved if it is informed by meaningful consultation with industry on this matter. Each regulated business has its own definitions around data and its own approaches to technology, and understanding those nuances before building interfaces will reduce FSRA’s risk of obtaining data that is difficult to aggregate, analyze, and interpret.

That said, CAFII fully supports FSRA’s fundamental principle of taking an evidence-based approach to regulation.

As a concluding comment related to “Regulatory Efficiency and Effectiveness,” CAFII has in the past extended kudos to FSRA for adopting CCIR/CISRO’s Guidance: Conduct of Insurance Business and Fair Treatment of Customers as the document which outlines FSRA’s expectations of industry with respect to FTC, without the need for separate FSRA guidance in this area. CAFII believes that such kudos to FSRA are still deserved, as the Authority continues to “walk the talk.” In taking the approach noted above with respect to FTC guidance, FSRA set a leadership example of supporting national co-ordination and harmonization. In that connection, we note the many references to FTC in the Proposed FY2022-2023 Statement of Priorities; and we encourage continued FSRA emphasis on the fact that such references are consistent with the CCIR/CISRO Guidance, which makes it crystal clear that FSRA’s harmonization approach continues unabated.

Life and Health Insurance Priority
CAFII agrees with and supports FSRA’s life and health insurance sector-specific priority of “Enhance market conduct oversight to protect consumers.”

In that connection, we emphasize again that CAFII members, as major FI distributors and underwriters of CPI and travel insurance, make considerable investments in systems, processes, oversight, monitoring, employee training, and controls to support highly professional sales practices which are focused on appropriate products and fair treatment of customers.

We were pleased to learn that FSRA has joined the International Association of Insurance Supervisors (IAIS). We recognize that international travel is currently restricted due to COVID-19. But that will not always be the case and we believe that FSRA, as the financial services regulator for Canada’s most populous province which is the economic engine of the country, should play a prominent role in the IAIS, which is a major international standards-setting body. We note the many references in the Proposed FY2022-2023 Statement of Priorities to FSRA’s learning from and, as appropriate, aligning with the practices of international bodies (such as the IAIS), and we are fully supportive of that approach.

Proposed FY2022-23 Budget, Financial Outlook, and Sector Fee Assessments
With respect to FSRA’s proposed 2022-2023 Budget, CAFII notes that it calls for a significant overall increase in FSRA’s fee revenue, well above the rate of inflation, even the comparatively high inflation rate in these supply chain-challenged pandemic times. We also note that some regulated sectors, including Life and Health, are facing particularly steep fee increases in 2022-2023. Finally, we note the following funding priority set out in the proposed budget: “Build new team to address critical regulation gap to protect consumer in Life and Health Conduct sector.”

The COVID 19-dominated 2021 year has been a second successive challenging year for the life and health insurance sector, and the sector has continued to make considerable efforts to respond to shifting and heightened consumer needs and regulatory expectations in these difficult times. Heading into 2022, as the industry collectively looks to operationalize a “new normal” with society and the economy emerging from the pandemic, the industry continues to face considerable financial challenges.

In that connection, CAFII asks that FSRA consider the following feedback points and observations with respect to its proposed 2022-23 budget:

• has the life and health insurance sector been fully and effectively consulted, such that there is a high degree of acceptance within the sector that a ‘critical regulation gap’ exists within it, one that needs to be urgently addressed?;

• if the FSRA-determined critical regulation gap in the life and health insurance sector exists almost exclusively within the MGA and/or licensed insurance advisor channels, is it possible to levy the steep fee increase predominantly upon that/those sub-channel(s) and not equally upon all regulated entities in the entire life and health insurance sector?; and

• given the magnitude of the fee increase which the budget proposes to impose upon the life and health insurance sector in 2022, combined with the pandemic-recovery financial challenges being faced by nearly all regulated entities in the sector, is it possible to spread the desired fee increase over two FSRA fiscal years: 2022-23 and 2023-24?

We encourage FSRA to keep those factors fully in mind when making a final decision about the proposed fee increase to fund increased conduct supervision in the life and health insurance sector.

In closing, we thank FSRA for its continued commitment to open and transparent communication and consultation. We look forward to making further representations of our Association’s views on the Authority’s Proposed FY2022-2023 Statement of Priorities through the Life and Health Insurance Sectoral Advisory Committee’s meetings, including with the FSRA Board on 23 November, 2021.

Rob Dobbins
Board Secretary and Chair, Executive Operations Committee

CAFII is a not-for-profit industry Association dedicated to the development of an open and flexible insurance marketplace. Our Association was established in 1997 to create a voice for financial institutions involved in selling insurance through a variety of distribution channels. Our members provide insurance through client contact centres, agents and brokers, travel agents, direct mail, branches of financial institutions, and the internet.

CAFII believes consumers are best served when they have meaningful choice in the purchase of insurance products and services. Our members offer credit protection, travel, life, health, and property and casualty insurance across Canada. In particular, credit protection insurance and travel insurance are the product lines of primary focus for CAFII as our members’ common ground.

CAFII's diverse membership enables our Association to take a broad view of the regulatory regime governing the insurance marketplace. We work with government and regulators (primarily provincial/territorial) to develop a legislative and regulatory framework for the insurance sector which helps ensure that Canadian consumers have access to insurance products that suit their needs. Our aim is to ensure that appropriate standards are in place for the distribution and marketing of all insurance products and services.

CAFII’s members include the insurance arms of Canada’s major financial institutions – BMO Insurance; CIBC Insurance; Desjardins Insurance; National Bank Insurance; RBC Insurance; ScotiaLife Financial; and TD Insurance – along with major industry players Assurant; Canada Life Assurance; Canadian Premier Life Insurance Company; Canadian Tire Bank; CUMIS Services Incorporated; Manulife (The Manufacturers Life Insurance Company); Sun Life; and Valeyo.

Life and Health Insurance
[2021-016] Brent Mizzen - Canadian Life and Health Insurance Association
On behalf of Stephen Frank, President and CEO, CLHIA, please find attached the Canadian life and health insurance industry's comments on FSRA's proposed priorities.

Life and Health Insurance
[2021-016] Marco Violo - Primerica Financial Services (Canada) Ltd.
Attached, please find Primerica Financial Services' Response to FSRA's Consultation on the proposed 2022-2023 Statement of Priorities.

We appreciate the opportunity to provide our recommendations.

Submitted on behalf of Rosie Orlando, Executive Vice President, Chief Operating Officer.
Credit Unions and Caisses Populaires
[2021-016] Bernard Brun - Desjardins
Desjardins welcomes the opportunity to provide comments on FSRA’s proposed 2022-2023 Statement of Priorities. Our feedback includes a focus upon the Credit Union and the Property and Casualty (“P&C”) insurance sectors.
Life and Health Insurance
[2021-016] Susan Allemang - Independent Financial Brokers of Canada
Attached are the comments from Independent Financial Brokers of Canada (IFB) to the draft SoP.
Auto Insurance
[2021-016] Elliott Silverstein - CAA
On behalf of CAA Insurance, attached is a copy of our response to the consultation on the 2022-2023 Statement of Priorities.

Thank you.
Cross Sector
[2021-016] Yann Nachabé - Sun Life
Please find attached Sun Life's submission to FSRA's consultation on proposed 2022-2023 Statemen of Priorities
Auto Insurance
[2021-016] Catherine Allman - Canadian Association of Direct Relationship Insurers
Please find attached CADRI's comments on FSRA's Proposed 2022 - 2023 Statement of Priorities and Financial Plan.
Auto Insurance
[2021-016] Julie Nolette - Intact Financial Corporation
To whom it may concerns,
Please find attached Intact Financial Corporations comments to FSRA’s proposed priorities for 2022-2023 with respect to the Property & Casualty (Auto) Insurance sector as outlined in FSRA’s 2022-2023 priorities and financial plan.
[2021-016] Rossana Di Lieto - Ontario Teachers' Pension Plan (OTPP)
Please see attached. Thank you.
Cross Sector
[2021-016] Devin - Mataseje
On behalf of FP Canada, please find attached our response to the Proposed FY2022-23 Statement of Priorities.
Auto Insurance
[2021-016] Matt Caron - Ontario Trial Lawyers Association
Please find our comments attached.
Property and Casualty and General Insurance
[2021-016] Jackie Roy - Ontario Mutual Insurance Association
Good morning.
Please find attached OMIA's response to FRSA's proposed 2022-2023 Statement of Priorities

Cross Sector
[2021-016] mauro lagana - FAIR Canada

Please find attached our submission in response to the Consultation on proposed 2022-2023 Statement of Priorities.

We would be pleased to discuss our submission with FSRA should you have questions.

Thank you,

Mauro Lagana
Policy Counsel
36 Toronto Street, Suite 850 | Toronto, ON M5C 2C5
[email protected]

Financial Planners and Advisors
[2021-016] James Ryu - Advocis
Please find attached Advocis' response to Consultation [2021-016], Proposed 2022-2023 Statement of Priorities.

James Ryu
Vice-President, Advocacy and General Counsel
[2021-016] Lisa Guglietti - The Co-operators

Credit Unions and Caisses Populaires
[2021-016] Stephen Bolton - Libro Credit Union
Thank you for the opportunity to comment on FSRA's statement of priorities. Please find our full comments attached via PDF.

Auto Insurance
[2021-016] Health Advocate
ID 2021-016 Consultation on FSRA’s proposed 2022-2023 statement of priorities
With respect to the auto insurance sector, the regulatory priorities harm car accident victims* who need healthcare. Since at least 2010 the excessive and misguided emphasis on fighting fraud has generated a strong yet unacknowledged bias against the interests of accident victims in Ontario. This bias has been manipulated by certain insurers as a pretext to routinely engage in abusive and unfair claims adjustment practices that harm access to legitimate healthcare. These abusive practices receive the unconditional approval of the regulator and all other stakeholders because they are falsely and groundlessly justified on the basis of fraud prevention which appears to remaintop priority for auto insurance sector. These insurers invest heavily in public relations initiatives that indoctrinate the public and all other stakeholders in a false belief that abusive claims practices are in the public interest. This biased narrative favours treating legitimate claims as fraudulent and discourages the regulator from pursuit of any initiatives that support the effective and efficient delivery of healthcare to accident victims. Meanwhile certain insurers are allowed to regularly violate the rights of accident victims in a regulatory culture that grants insurance claims adjustment practices an exemption from any oversight or critical examination as long as they adopt the appearance of investigating and fighting fraud.
Below are examples of initiatives that should be pursued by FSRA to better serve the public interest, by improving transparency and accountability for effective and efficient funding of healthcare for accident victims. These important initiatives will be opposed by insurers dominated by bloated legal departments, consultants, and claims adjustment executives whose careers and compensation depend upon a distorted exaggeration of the extent and nature of insurance fraud. The initiatives below should be promoted by FSRA on the basis of principles that fairly prioritize the interests of accident victims who need healthcare. These proposed initiatives promote the value of efficient and effective delivery of healthcare rather than only promoting a monolithic bureaucracy that opposes access to healthcare and favours the financial interests of the insurance claims adjustment and insurer legal defence industry. Improved prioritization of the interests of accident victims and their need for healthcare is required to support any improvement in this sector along with an acknowledgement of the harm that has resulted from excessive historical emphasis on fighting fraud.
1. Examine the value and need for accident victims to have access to healthcare and the harm that results from deterring access to healthcare
2. Critically examine the regulatory ideology that promotes a wholesale and continued assault on the legitimate rights of accident victims to healthcare, in favour of the fight against fraud. Examine the lack of cost and benefit analysis that has so far favoured fighting fraud regardless of the harm to legitimate access to healthcare
3. Survey accident victims regarding how their respective insurers treat them with respect to their healthcare funding needs
4. Examine the culture of FSRA that views reduced access to healthcare facilities and providers as an indicator of regulatory success rather than failure.
5. We need unbiased analysis and interpretation of claims data that does not rely so heavily on stakeholders whose livelihood and job security benefits from an exaggeration of the extent and nature of insurance fraud. Allow unbiased access to data from an independent academic professor for example, who does not rely upon consulting fees from insurance industry. Ensure that seasoned healthcare providers who have extensive experience serving accident victims as their patients have the opportunity to examine, probe and question the details of any observations of implied wrong-doing, so as to ensure meaningful and knowledgeable interpretation of observations by people who understand healthcare in the context of Ontario MVA victims.
6. Analysis that recognizes how historic systemic changes to models for funding healthcare and supervision of healthcare have the potential to harm or promote access to legitimate healthcare funding for accident victims. Examine how these systemic changes, can profoundly alter observed claims experience over time. In this way, we can finally stop mindless and excessive attribution of fluctuations of claims experience (beyond inflation) to fraud.
7. Comparison of approaches to funding healthcare across different provinces or countries to see if more efficient and effective systems can be considered that favour better outcomes for the health and wellbeing of accident victims. Also compare to public agencies that fund healthcare for accident victims, like WSIB
8. Commit to examining over time, the fundamental logic or absence of logic supporting SABS healthcare provisions, an onerous and biased LAT system that rewards abusive insurers, outdated HCAI forms and procedures, many of which systematically obstruct and delay healthcare for accident victims. Question the prevailing assumption that every additional bureaucracy is in the public interest because it reduces access to healthcare. What evidence is there that each element of that bureaucracy actually deters fraud vs primarily results in obstruction of legitimate access to healthcare?
9. Why are some MVA healthcare guideline fees at least 50% below market rates and what impact does that have on access to healthcare?
10. Examine how statutory declarations are routinely used by certain insurers without reasonable grounds to unfairly obstruct funding for healthcare in the absence of specific evidence that they serve any genuine public interest or any meaningful relevance to determining the insurer’s liability.
11. Why is there not a simpler way of coding healthcare services to be billed rather than using an outdated and obscure coding approach for which there is no consensus within certain healthcare fields as to how to code procedures? Examine how certain insurers use this diversity of administrative approaches to falsely infer wrong-doing among providers and pressure healthcare colleges to take needless actions against healthcare providers for trivial administrative nuances.
12. Why does FSRA invest excessive resources and attention on trivial administrative issues regarding how healthcare facilities operate in the absence of any logical justification in terms of the public good?
13. Examine the extent to which the Ontario system deters healthcare providers from serving accident victims and causes facilities to abandon healthcare licenses because of a punishing bias against providers who serve accident victims.
14. Examine how healthcare services are concentrated in smaller and smaller number of providers and facilities who remain to serve accident victims in the face of monumental deterrents that have caused so many providers and facilities to exit the industry.
15. Examine the resulting harm inflicted on accident victims who experience delays and difficulties accessing healthcare simply because it is difficult finding a suitable provider from a smaller and smaller pool of providers.
16. Critical examination of “risk-based” algorithms employed by insurers and possibly FSRA that depict the resulting large volume of services delivered by fewer and fewer remaining providers and facilities as suspicious and requiring further groundless deterrents in a vicious and mindless cycle designed to discourage access to healthcare
17. Examine the influence that certain insurers exert over health regulatory colleges, how healthcare colleges are pressured to adopt a twisted risk assessment models that favour reduced access to healthcare. Healthcare colleges are pressured to perceive the public interest as favouring policies and standards that reduce access to healthcare for all patients and thereby reduce risk. These systemic biases implicitly depict improved access to healthcare as potentially “risky” and therefore to be discouraged by healthcare colleges in the absence of evidence to support this “risk” assessment. Examine how the power and influence of insurance companies causes regulatory colleges to neglect their true legal mandate to serve the public interest by enabling access to safe and effective healthcare by those that need it.
18. Demand greater transparency and granularity in the data submitted by various insurers to justify premium rates. Improve the clarity of disclosures regarding premiums needed for healthcare funding so as to distinguish funds spent by insurers on healthcare vs funds spent adjudicating and legally obstructing healthcare. Use this data to compare performance of insurers in effectively and efficiently funding healthcare vs wasteful expenses to obstruct and delay healthcare
Any of the above initiatives would help FSRA better serve the public interest and its mandate with respect to regulating auto insurance, but first it needs to get its priorities straight and acknowledge the harm that accident victims have experienced as a result of disproportionate prioritization on fighting fraud. For over a decade, fighting fraud has been the priority that has governed 100% of public policy and regulatory action and lack of action with respect to accident victims, and this emphasis has resulted in enormous harm to the health and well-being of car accident victims for over a decade.

Financial Planners and Advisors
[2021-016] Marc Lapalme - Al Poulin Financial Services
Good day, here are my comments. More and more compliance, administration and information technology (IT) are the big brothers of this industry, whereas good customer service and plane language are dying a slow and painful death. We have too many regulators who overlap each other all day long, client service departments (for every company) who take too long to address a situation (weather simple or complex), by transferring our calls to another department or another person etc. where we need to start our story over and over again. All in the name of compliance, administrative procedures and of course conform with IT platform changes (which seem to change every 5 minutes). How come is it the online or self directed sites don't have to go through all this? Several of my clients tell me and have shown me that either Wealth Simple or iTrade is way easier, and their right! It's super easy! If I had one form that encompassed all the disclosures my clients would be much happier and I would be able to serve them better. There's my 2 cents.
Life and Health Insurance
[2021-016] Brian W Goodman - Assante/AEIS
Working with very few HNW clients and usually with clients of more modest means, it constantly seems ridiculous to me that the same emphasis and accreditation must be submitted regarding ID, PEPs, AML and similar compliance requirements. Often these items are required from clients we have known well for several years .yet must take the time to submit once more.
Should there not be a lower transaction limit, such as $50,000 - $100,000 with less stringent requirements?
It is these medium and lower income clients often most in need of financial advice and help, yet the time to care for them takes as much or more time to conclude any new plans than it does for the higher income client. As a result the push is always to seek out those who have the most.
Regulators and the financial industry need to be seeking ways to service and assist those with fewer means.
The regulator's fixation on AML, PEPs etc. doesn't help the modest investor or encourage the advisor to take the time to help them.
Surely some streamlining is in order.

Mortgage Brokering
[2021-016] Dawson Young - Mortgage Intell
HI I am a 20 year financial advisor and a 15 year mortgage agent. for the mortgage industry I would like to see the following

1) Mortgage fees especially on private mortgages are out of control. a lawyer typically would charge 900$ for a transaction(and they have a university degree) and the mortgage broker charge a flat fee/ a percentage of the amount being borrowed. example a $500,000 deal a good agent would charge $5000 (1%) and an expensive agent would charge $10,000 (2%) . I think both numbers are extremely high and they are taking advantage of people when they are down.

if you ever want to chat further about this issues in the Financial planning world or the mortgage agent would feel free to give me a call.

2) For bank deals the compensation needs to be the same across all lenders. lenders currently pay extra based on volume up to 30% extra. This is a clear conflict of interest. I have attended many conference calls throughout the years and someone always asks who is paying the most today. there should be no bonuses. Just like the investment world about 19 years ago this was eliminated.
Financial Planners and Advisors
[2021-016] Dawson Young - Investment Planning Counsel
HI I am a 20 year financial advisor and a mortgage agent. if I were to change anything they would be

1. the education requirement's for financial advisors are embarrassing. A high school drop out can take a couple courses and get in the industry (banks love this). At min a everyone should have a 3-4 year business degree before they can take licensing courses. Adding rules are great but we need to attract educated professionals.
Financial Planners and Advisors
[2021-016] John Armstrong - Maia & Associates
In regard to your proposed increased market oversight for Life & Health to protect consumers:
Contrary to popular belief the life and health industry is not in fact a pack of hungry wolves looking to prey on the flocks of sheep they service. Increasing oversight and paperwork does nothing to make them safer. It in fact does the exact opposite. By increasing the cost of doing business for stakeholders in the Life & Health sector you are in fact incenting the less scrupulous participants to cut corners and act in a way which may conflict with the clients best interest. Paperwork does absolutely nothing to impede the small % of advisors who are operating contrary to clients best interests. Proof of this is demonstrated very clearly in the mutual funds arena where billions of client assets have been moved into inappropriate investments in order to avoid the greater scrutiny of that platform.
A much smarter and effective way to protect clients is to INCREASE BARRIEERS TO ENTRY INTO THE INDUSTRY. Anecdotally it makes no sense to let a bunch of criminals into a business and then spend millions in resources and time to regulate, enforce and paper them when you can simply do an upfront background check and put hurdles in place where they will trip themselves up BEFORE they enter the business and become a problem.
Secondly you should regulate the TIMELINE for which entrants may hold themselves out as planners/advisors. Its not at all enough to meet whatever criteria you have in place for credentials. Make them only able to be referred to as "Junior Planners/Advisors" for 5 years. Usually by that time 90% of the people who entered the business have failed (by industry standards adjusted for corporate number fudging through re-hires, legacy hires etc) THOSE are the advisors who cause 90% of the client issues and complaints. It makes absolutely zero sense to burden established excellent professionals with reams of senseless paperwork and even less sense to subject clients to it. I could care less how many studies and polls and thinktanks/consultants you have hired that tell you otherwise. I guarantee less than 1% of clients read any of those forms. Clients do NOT want more forms or regulation. Start providing real protection and effective protection for consumers before its a problem.

Mortgage Brokering
[2021-016] LdG, CFP
I believe much more needs to be done to oversee or stop mortgage brokers who sell syndicated mortgages to clients who are not accredited. These agents have no investment training or fiduciary duty, yet they are locking people's money away for years. They state they are not qualified to give tax or investment advice, yet they initiate transfers and implement investment products with significant tax and cash flow implications. The public faces a serious threat from predatory agents and products in this space.
Mortgage Brokering
[2021-016] Robert Therien
I would like to see increased investigation activity and reporting of fraud in the mortgage broker industry. FSRAO has been overly lax in this regard for decades. I personally have reported fraud to the regulator, significant in a couple of cases for big industry players with plenty of evidence: zero action was taken. This is unacceptable and this lack of action is perceived by myself and many others as acceptance and tolerance of fraud in the mortgage broker industry.
Date posted Sector Question and response

Question: When should I apply for a renewal of my license, as the company has told me to apply earlier due to Covid-19 back load.

FSRA response:

This comment is unrelated to the proposed Statements of Priorities and Financial Plan.  It has been referred to the appropriate person(s).

Financial Planners and Advisors

Question: Where is the representation of registrants in this process? Is there a registrant advisory committee? How many female registrants are on the Board?

It is very important that creating Fairness, Equity, Transparency snd Discrimination policies are a top priority. Discrimination in this industry is rampant and ignoring that is the same as facilitating its continuation.

FSRA response:

"FSRA is committed to openness, transparency and collaboration with stakeholders and has established several Stakeholder Advisory and Technical Advisory Committees. These Committees provide expert advice and insight to FSRA’s Board of Directors and management, which inform FSRA’s priorities, budget and other regulatory initiatives. Membership on the Committees is by appointment through a transparent application process.  

FSRA has also established a Consumer Advisory Panel. The Panel provides a consumer perspective to help inform FSRA’s work, including proposed policy changes and related activities, including consumer-based research, policy support and consumer outreach. 

A Stakeholder Advisory Committee (SAC) will be established for the FP/FA sector once the framework has been implemented."

Auto Insurance

Question: Why does the insurance lobbyist, the IBC, own and control the mandated medical submission system that has been proven to be allowing fraud and abuse?

FSRA response:

This comment is unrelated to the proposed Statements of Priorities and Financial Plan.  It has been referred to the appropriate person(s).

Financial Planners and Advisors

Question: Why is there no registrant advisory committee?

1. I would like to see policies against discrimination and harassment and the licensing bodies be responsible to protect their registrants.
2. I would like to see transparent processes and registrant access to the NRD.
3. Ideally registration will be separate from or a division of the licensing bodies and commissions. Their sole purpose is to protect the public and despite registrants being part of the public, they have no policies, procedures or transparency in the registration process.
4. Ideally, titles for advisors will be much better for the public to understand. For instance you can easily recognize Doctor, nurse, PSW, orderly. The financial industries should be that streamlines and easily recognizable.
5. Registration should not be dependent on a firm sponsoring it. If a doctor works 15 years to become a doctor, they should be employable whether they are currently with a firm or not.
6. Registrants should be able to work through a company just as any others use a professional corp.
7. Registrants need to be represented at the Board level of securities commissions with a minimum of 50% voting. Other government agencies post their board positions however the OSC does not.
8. Ideally the commissions' policies will be back by the Fairness Commissioner.

FSRA response:

"FSRA is committed to openness, transparency and collaboration with stakeholders and has established several Stakeholder Advisory and Technical Advisory Committees. These Committees provide expert advice and insight to FSRA’s Board of Directors and management, which inform FSRA’s priorities, budget and other regulatory initiatives. Membership on the Committees is by appointment through a transparent application process.  

A Stakeholder Advisory Committee (SAC) will be established for the FP/FA sector once the framework has been implemented."