Cross Sector
Public comment closed
Comment Due Date

Thank you for providing your feedback on FSRA’s proposed Statement of Priorities and budget.

We appreciate the comments and questions received to date. Your feedback will help to inform our Annual Business Plan.

The request for submissions is now closed and the consultation summary is below. Stay up to date on our newsroom, follow us on LinkedIn, and subscribe to our mailing list for quick updates.

FSRA is launching a public consultation on its proposed 2023-24 Statement of Priorities and financial plan.

FSRA’s proposed priorities continue to focus on fostering principles-based regulation, while delivering on outcomes that ensure consumer protection, support innovation and effectively address emerging risks and supervision needs in the sectors it regulates.

The Statement of Priorities and budget will form the core of FSRA's Annual Business Plan. FSRA will then submit its Annual Business Plan to the Minister of Finance for approval.

Consultation is an essential part of FSRA's commitment to transparency and accountability. This ensures that FSRA’s plans for the upcoming fiscal year consider stakeholder feedback.

FSRA is now seeking feedback on its proposed 2023-24 Statement of Priorities and budget. The consultation will close on November 11, 2022.

Consultation summary reports for each sector:


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
Mortgage Brokering
[2022-012] Lauren van den Berg - Mortgage Professionals Canada

Property and Casualty and General Insurance
[2022-012] Julie Nolette - Intact Financial Corporation

Auto Insurance
[2022-012] Catherine Allman - Canadian Association of Direct Relationship Insurers
Please find attached CADRI's comments on FSRA's Proposed 2023 - 24 Statement of Priorities and Financial Plan.
Credit Unions and Caisses Populaires
[2022-012] José Gallant - Alterna Savings

Cross Sector
[2022-012] Susan Allemang - Independent Financial Brokers of Canada
Independent Financial Brokers of Canada (IFB) appreciates the opportunity to comment on the draft Statement of Priorities.
Cross Sector
[2022-012] mauro lagana - FAIR Canada

Auto Insurance
[2022-012] John Taylor - Ontario Mutual Insurance Association
Please find attached our submission on FSRA's proposed 2023-2024 Statement of Priorities
Cross Sector
[2022-012] Matt Caron - Ontario Trial Lawyers Association (OTLA)
Please find OTLA's submission attached.
Life and Health Insurance
[2022-012] Brent Mizzen - CLHIA
On behalf of Stephen Frank, President and CEO, CLHIA, please find attached the industry's feedback on FSRA's proposed priorities and budget for 2023-24.

Thank you for the opportunity to provide the industry's comments.

Cross Sector
[2022-012] Consumer Advisory Panel - Consumer Advisory Panel
Enclosed please find the submission by the Consumer Advisory Panel Members.

For questions, please contact the Consumer Office.
Life and Health Insurance
[2022-012] Brendan Wycks - Canadian Association of Financial Institutions in Insurance (CAFII)
November 11, 2022

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 FY2023-2024 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 FY2023-2024 Statement of Priorities.

In this submission, we have focused our comments largely on those sections of the consultation document which are of direct relevance to our Association’s members, i.e. the Environmental Scan, FSRA-Wide Priorities, Life and Health Insurance Sector-specific Priorities, and FSRA’s Proposed Fiscal Year 2023-24 Budget.

CAFII largely agrees with FSRA’s observations in its Environmental Scan and, in particular, its views on the ongoing impact of the COVID-19 pandemic:

The COVID-19 pandemic continues to have a profound impact on the global economy and social interaction, and FSRA remains committed to managing its impact on regulated sectors and the people on which they rely. Rather than a return to business-as-usual, Ontario’s financial services and pension plan sectors have transitioned to a “new normal.” Fully remote or hybrid workplaces and increased reliance on digital technologies have greatly impacted the sectors that FSRA regulates, including consumer interactions.

We believe that there is considerable uncertainty in the economy, which is creating challenges for the industry. Those challenges include inflation; rapidly rising interest rates; talent acquisition and retention; changing employee expectations around working remotely versus in the office; heightened health issues among the workforce and consumers, including mental health issues; elevated consumer expectations to be able to conduct all insurance and financial services transactions digitally; climate change; and supply chain and other international challenges that significantly impact both global and local economies. CAFII held a webinar with Pollara Strategic Insights Vice-President Lesli Martin on October 5, 2022 which provided corroboration of heightened stakeholder concerns around many of these issues, including a remarkable research finding that 45% of women would quit their jobs if forced to return to full-time work in the office .

In light of these unprecedented pressures in the economy and society, CAFII applauds FSRA’s commitment to burden reduction and to focused, appropriate, meaningful regulation of the industry.

Our Association is currently monitoring the role of inflation, wage pressures, housing costs and general economic uncertainty on the propensity of people to purchase life and other insurance to protect themselves and their families in the event of death, disability, critical illness, or involuntary loss of employment.

By way of further CAFII-specific background, the Authorized Insurance/credit protection insurance (CPI) products offered by CAFII members enable Ontarians to avail themselves of optional group insurance related to a specific borrowing need such as a mortgage or line of credit, and to secure protection against financial loss related to death, disability, critical illness, or involuntary loss of employment. The consumer target market for CPI is principally unserved and under-served Canadians – people who typically do not have access to a licensed insurance advisor due to their modest financial assets and net worth – who appreciate CPI’s affordability, convenience/accessibility, and simplicity. The availability of CPI in the marketplace helps to address the societal issue that a significant proportion of Canadians are under-insured or even totally uninsured with respect to life and health insurance. In 2019, according to LIMRA, half of Canadian adults did not own any life insurance coverage.

We currently have a consumer research survey in the field that asks consumers if they are cutting back on insurance purchases due to higher inflation and interest rates; and we plan to publish the results of that research in early 2023. Reduced purchasing of insurance puts consumers at risk and can have catastrophic consequences for families in the event of the death, disability, or critical illness of an income earner who is not insured.

CAFII takes note of FSRA’s comments on suitability-related issues, and we agree with the importance of consumers being offered the right products. We wish to emphasize, however, that CPI -- which CAFII members offer under the federal Bank Act and related Regulations, but which is also provincially regulated -- cannot be offered by licensed individuals and product recommendations cannot be offered to consumers considering these optional products. As such, CAFII members are not able to assess “suitability” for customers interested in the protection provided by CPI, but rather can assess “eligibility.”

We concur with FSRA’s observation that consumers have heightened expectations about being able to engage with insurance providers digitally. We commissioned research with Deloitte Canada, released in 2022, on how CAFII member companies can offer the best digital CPI experience to consumers, and we held a webinar on June 29, 2022 which shared the findings with insurance regulators and policy-makers .

With respect to the concerns which FSRA cites around third-party outsourcing, we note that there are multiple regulatory expectations which industry must live up to around outsourcing, including CCIR/CISRO’s Guidance: Conduct of Insurance Business and Fair Treatment of Customers. CAFII members have extensive controls and systems in place to ensure that outsourcing does not impact the fair treatment of customers.

CAFII agrees with FSRA’s views stated in the section on Environmental, Social and Governance (ESG) that the issues under that banner will continue to grow in importance for the industry. We have made the point that climate change undoubtedly has an impact on the life and health insurance industry, and we held June 2020 and September 2021 webinars with expert panelists on that important topic .

CAFII supports FSRA’s strategic framework and we believe that the four related pillars specified are appropriate. With respect to the strategic priorities itemized under the four pillars, we support FSRA’s stated commitment to strengthen its consumer focus.

We particularly encourage FSRA to continue to engage in independent, third-party consumer research and data analysis so that the Authority will be well-briefed and prepared to respond to the trends that will impact consumers, given that consumer preferences are evolving rapidly in response to societal and technological change.

In that connection, CAFII would be willing to offer its services as a ‘research sounding board and advisor’ to FSRA, should the Authority wish to avail itself of our offer, given that our Association has significant experience in conducting independent, third-party consumer research via our research partner Pollara Strategic Insights, a firm which we believe is also FSRA’s professional services provider in this area; and given, as well, that CAFII member companies have significant depth and breadth of experience in conducting consumer research that delivers actionable insights.

CAFII has also previously communicated to FSRA our support for the following initiative: “Implement existing FSRA guidance by building processes to use revenues retained outside of the Consolidated Revenue Fund under the Financial Services Regulatory Authority of Ontario Act, 2016 for educational, research and knowledge or information-enhancement initiatives” (page 12).

CAFII supports FSRA’s commitment to “modernize systems and processes,” and, in that connection, we particularly appreciate the following commitment: “…FSRA will also work with regulated sectors to improve data collection, reduce reporting and administration by sector participants. Better data will improve FSRA’s ability to efficiently provide regulatory oversight” (page 14). We encourage FSRA to try to address known industry data needs through CCIR’s Annual Statement on Market Conduct (ASMC), to avoid duplicative data collection initiatives. Finally, we believe that this section would benefit from an explicit reference to FSRA’s possible direct use of technology to enhance regulatory monitoring and supervision initiatives, including the use of RegTech.

With respect to the “Enable Innovation” priority, CAFII strongly supports FSRA’s ongoing efforts in this area. The digitization expectations of consumers and industry players are constantly increasing and shifting, thereby challenging the regulatory system to adapt faster than current mechanisms can keep up. The deliverables and outcomes specified by FSRA under this priority are appropriate in our view, and we continue to believe in the benefits of “regulatory sandboxes” that provide a safe, monitored space within which to test innovative products and services while ensuring consumer protection.

Our Association fully supports FSRA’s commitment to enhance its own talent management framework, as we believe that FSRA is already facing or will soon face the same challenges which the industry is facing -- arising from heightened retirements, a shrinking talent pool, and new employee expectations including enhanced flexible work arrangements such as working remotely versus from the office. We are encouraged by the high calibre of the FSRA management team and we believe that the Authority has, since inception, recruited a talented employee team which has been, and will continue to be, critical to enabling the Authority to fulfill its mission and mandate.

With respect to the life and health insurance sector-specific priority “Enhance Market Conduct Oversight to Protect Consumers,” we support the initiatives outlined therein. In that connection, we want to highlight that CAFII members have made, and will continue to make, investments in systems, processes, oversight, monitoring, employee training, and controls to ensure that FTC expectations are achieved.

CAFII was pleased to learn that FSRA has become a member of the International Association of Insurance Supervisors (IAIS). Stemming from that very positive development, we took note of the many references in the Proposed FY2023-2024 Statement of Priorities to FSRA’s learning from and, as appropriate, aligning with the practices of international bodies (such as the IAIS), and we fully support that thrust.

That said, we encourage FSRA to ensure that Ontario’s particular circumstances are fully considered when applying internationally-developed standards to the province’s marketplace. Canadian business culture is different from that found in many other countries partly because of its alignment with regulatory expectations. Correlated with that, FSRA and the other provincial insurance regulator members of CCIR have created and operate a professional, proactive, effective, and properly funded regulatory framework.

CAFII also encourages FSRA to play a leadership role in IAIS’ deliberations. In that connection, we were delighted to learn that in October 2022, you, Mark, had been appointed Chair of the IAIS’ Market Conduct Working Group.

CAFII has, in the past, extended kudos to FSRA for adopting CCIR/CISRO’s Guidance: Conduct of Insurance and Fair Treatment of Customers as the document which outlines the Authority’s expectations of industry with respect to FTC, without the need for a separate FSRA Guideline in this area. By doing that, FSRA set an important example, to be emulated, of supporting national co-ordination and harmonization. In that connection, we support FSRA’s many references to FTC in the Proposed FY2023-2024 Statement of Priorities; and we encourage the Authority to continue to emphasize the fact that such references are consistent with the CCIR/CISRO Guidance, making it clear that a harmonized approach continues to be prioritized.

With respect to FSRA’s proposed 2023-2024 Budget, we note that while the industry-funded revenue it calls for will increase by 2.8% over the 2022-2023 budget; and while the proposed fee assessments overall will be 3.6% higher than the prior year, the life and health insurance market conduct variable revenue line will be up by 9.6% over 2022-2023. The COVID 19-dominated 2022 year has been another very challenging one for the life and health insurance sector, and the industry has made considerable efforts to respond to shifting and heightened consumer needs and expectations in these difficult times. The industry continues to face considerable challenges. We encourage FSRA to keep those factors in mind when it is finalizing its 2023-2024 Budget.

In closing, CAFII again expresses its appreciation for FSRA’s continued commitment to open and transparent communication and consultation. We look forward to offering further CAFII commentary on FSRA’s Proposed FY2023-2024 Statement of Priorities and its related 2023-2024 Budget through the Life and Health Insurance Sectoral Advisory Committee’s meetings, in which our Association actively participates.

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.

Credit Unions and Caisses Populaires
[2022-012] Canadian Credit Union Association - CCUA
Please see attached submission from the Canadian Credit Union Association.
Health Service Providers
[2022-012] Peter Bergin
Consideration of health service provider rates. As it stands, the last adjustment in healthcare practitioner rates occurred in 2014. Since 2014, inflation in Canada has been a cumulative 18%. This involves an increase in the cost to operate a business and greatly affects the ability to serve clients.

The longer the rates stay the same, the harder it is to justify the treatment of Auto Insurance claims. As hourly rates stay low, private rates are increasing to adjust for inflation. This leads to the decreased ability to take on new motor vehicle clients. When businesses are less interested in taking on new auto insurance claims, it greatly affects the general population's ability to find services. This flywheel effect negatively affects everyone, and mostly affects the general population. With a mandate to protect the general population's best interest, I encourage a review of healthcare practitioner rates across the board. More practitioners will stop taking on auto insurance claims, which is greatly unfair to people suffering from a motor vehicle accident.
Cross Sector
[2022-012] Giuseppina Marra - Desjardins Group
Mr. Mark White
Chief Executive Officer
Financial Services Regulatory Authority of Ontario
5160 Yonge Street, 16th Floor
Toronto, Ontario M2N 6L9

Desjardins Group submits for the attention of the Financial Services Regulatory Authority of Ontario its comments as part of its consultation on FSRA's proposed statement of priorities for 2023-2024.
For any additional information, do not hesitate to communicate with the undersigned.
Best regards,
Giuseppina Marra
Regulatory Affairs
Auto Insurance
[2022-012] Rhona DesRoches - FAIR Association of Victims for Accident Insurance Reform
FAIR Association of Victims for Accident Insurance Reform
579A Lakeshore Rd. E. PO Box 39522, Mississauga, ON, L5G 4S6
[email protected]
November 10, 2022

FAIR Submission to: FSRA Proposed FY2023-2024 Statement of Priorities ID 2022-012

Thank you for the opportunity to speak to the auto insurance issues facing Ontario consumers. FAIR is a grassroots not-for-profit organization of Ontario car crash survivors who have struggled with the current auto insurance system in Ontario.

We appreciate the continuing effort of the FSRA to focus on improving regulatory efficiency and effectiveness in an effort to better serve the public interest.

Our comments will be focused on auto insurance only.

Ontario’s car crash survivors continue to have issues with excessive claims denials and the resulting bottleneck of cases continues at the Licence Appeal Tribunal (LAT) Auto Accident Benefits System hearings. This is the result of a failure to ensure there is accountability built into the claims system and the LAT itself is failing to provide accountability with too few sanctions but plenty of excuses for insurers behaving badly.

While the consumer profile is elevated in this FSRA document it is clear that the FSRA focus is disproportionally placed on rates and premiums and not on consumer satisfaction. It’s hard to see how FSRA’s intention to promote a “strong, stable, and resilient sector in which policyholders and consumers are protected and have confidence in the sector” is achievable with the lack of transparency around consumer complaint outcomes. The failure to provide information about insurer behavior protects the insurers’ reputation and in that process it harms consumers and it discourages other claimants from bringing their concerns forward. It is consumers who need protection from insurer behavior, not the other way around.

It is good to see the acknowledgement of the multitude of privacy issues Ontario’s policyholders face but we’ve seen no action or plan to combat the open-ended use of personal medical information that insurers gather and share with third parties during a claim. There are no checks and balances in the system and a clear pathway to protect tens of millions of Ontario drivers and their passengers is urgently needed. Insurers need boundaries to follow and those are the curbs consumers should already be able to count on.

It is encouraging to see the FSRA has acknowledged the many layers of global uncertainty Ontarians are experiencing. Ontario’s injured car crash survivors face an increasing failure of confidence in the auto insurance product they’ve been legislated to purchase. In order to meet value for money expectations we hope that the Regulator will take measurable action to protect consumers with greater transparency and accountability through improved balance – consumers matter as much as insurers do.

FAIR Association of Victims for Accident Insurance Reform

Auto Insurance
[2022-012] Mark Wigle - Association of Independent Assessment Centres (AIAC)
Please see AIAC Letter as attached.
Auto Insurance
[2022-012] Maya Milardovic - Co-operators

[2022-012] Michael Powell - Canadian Federation of Pensioners
Please see attached submission from the Canadian Federation of Pensioners
Credit Unions and Caisses Populaires
[2022-012] Stephen Bolton - Libro Credit Union
Please see our formal response attached. Thanks.
Auto Insurance
[2022-012] Susanne Gorka - Ottawa South Chiropractic Clinic
As a practitioner who treats Motor Vehicle Injury patients, I have to note that there have been no rate increases for practitioners for at least 10 years. My auto insurance rates have significantly had price increases, staffing costs have risen, rent has risen.... and I think it is time to link MVA payments to inflation like WSIB does. TIME TO PAY PRACTITIONERS FAIRLY!
Life and Health Insurance
[2022-012] Charles W. Foster - Consultant
I have recently been engaged to assist a Life Insurance Agency licenced in a number of provinces, including Ontario, with its overall compliance obligations. Having researched the regulatory regimes in all appropriate provinces, I strongly support FSRA’s move towards a pro-active, principles based, regulatory regime for its licenced Life Insurance Agents.

I also support the adoption of CISRO’s guidance, as without national regulatory harmonization, most life insurance agents will be faced with increased complexity, costs, and potentially conflicting compliance expectations across the country.

FSRA’s regulatory regime has continued to evolve since the initial establishment of it’s new, dedicated, Life and Health Insurance Agent Unit in 2020. This initiative was presumably in response to the International Monetary Fund’s, 2014 Funds review of Canada’s observance of the Insurance Core Principles [ICPs] under its Financial Sector Assessment Program).

FSRA regulates over 55,000 life agents in Ontario. The number of life agents licensed with FSRA increased 10% between December 31,2020 and December 31, 2021.

Having read information available at various locations on FSRA’s web site, I became confused about where FSRA was proposing to go with this initiative, what it expected of its regulated Life Insurance Agents and what they could do to satisfy these expectations.

On the one hand, FSRA states that it looks to Insurance Companies (whether National or FSRA regulated Ontario Corporations) to ensure compliance by their agents.

The Financial Services Regulatory Authority of Ontario (FSRA) expects insurance agents to act ethically and requires insurers to oversee and monitor agent and managing general agency conduct to protect consumers.

One would therefore expect these insurers to be the primary enforcer of the CCIR and CISRO insurance sector Guidance.

In its “Guidance” – (Approach) entitled Fair Treatment of Consumers in Insurance, FSRA announced that for internal purposes:
the Financial Services Regulatory Authority of Ontario (FSRA) will use Guidance: Conduct of Insurance Business and Fair Treatment of Customers (Guidance), adopted jointly by the Canadian Council of Insurance Regulators and the Canadian Insurance Services Regulatory Organizations on September 27, 2018, to supervise the conduct of insurers, and other entities FSRA regulates under the Insurance Act (Ontario), with respect to the fair treatment of customers.

FSRA will assess whether such entities follow the Guidance in setting and maintaining business policies and practices that are effective in ensuring fair treatment of customers.

Because this Guidance was found in the Eblast section of the FSRA web site, rather in the Guidelines Section, it is likely that a number of regulated entities are unaware of this guidance.

I read “other entities FSRA regulates” as Ontario licenced Life Insurance Agents.

In this “Guidance”, FSRA advised it did not have statutory authority to enforce compliance with this Guidance. Perhaps that is why it was not filed under Guidance on the web site.

It is also unclear whether FSRA will use this approach only for agents of Ontario Insurers it regulates or for agents of National Insurers as well. Presumably this information, together with how insurance agents will be risk rated, will be published in due course.

Finally, in March 2022, FSRA issued the following document for comment:
Market Conduct:
Life and Health Insurance Agent

Presumably the final version of this Framework will answer many of my questions.


Please consider including the following in FSRA’s Proposed FY2023-2024 Statement of Priorities:

• If possible, enact a Rule that incorporates the appropriate CCIR and CISRO Guidance as a FSRA enforceable rule,
• Publish your regulatory framework in the formal Guidance section of your Web Site under the category Life and Health Insurance. Suggest you look to FSRA’s Guidance for Credit Unions and Casse Populaires entitled Risk Based Supervisory Framework for guidance in structure and content. (The evolving strategy currently on your website under “Eblasts” should be marked “achieved – see guidance for current status”),
• Explain how you address potential jurisdictional issues – you are regulating “agents” of National Insurers who are primarily responsible for the business conduct of their agents. (A FSRA rule would likely address this issue).
• Consider publishing sample policies and procedures for use by at least some of the 55,000 Life Insurance Agents FSRO regulates. (Again, look at your Credit Union and Caisse Populaire Guidance for inspiration).

[2022-012] André Pawan Vashist
I appreciate the acknowledgement of the economic outlook and the particular impact it has on our most vulnerable people. I also appreciate the attention to climate and DEI in the ongoing role financial organizations have in our communities. Finally, I appreciate the goal to protect consumers.

Life and Health Insurance
[2022-012] JOHN W JACKSON - Jackson & Associates Limited
We support continuing efforts to educate the consumer on all aspects related to group benefit plans that include Life, AD&D, Dependent Life, Short and Long term Disability, Extended Health care and Dental coverage. In our opinion, this should include disclosure of all expenses under the plan including, from the insurers, how pooling charges are calculated and, from the advisor/broker, all compensation received including commissions, bonuses (both for production and retention) and non-cash compensation (which can include office space, conferences, etc.). our rationale is based, in large part, on ensuring the consumer/client is aware of any real conflicts that exist with a specific insurer (including sponsorship of a license) and to provide the consumer/client with an ability to link any value being provided to the cost built into their premium as compensation to the advisor/broker
Auto Insurance
[2022-012] Brendan Sullivan
Consider the income replacement benefit amount for motor vehicle injury. It is capped at $400 per week, set in 1996 and never changed. As such, the maximum payable is far below the minimum wage in the province of Ontario. A one time increase is required, or tie the amount to inflation as other insurance matters are. $400 in 1996 is $685.84 in 2022 according to Bank of Canada. Thank you.
Mortgage Brokering
[2022-012] Darcy Therien
In Mortgage Broker complaints on misrepresentation / fraud trends, the complainant is disclosed to the broker of concern. This is outside of the rest of the industry and can say with 100% confidence that the most active regulators, BC and AB, do NOT do this.

Speaking from a great deal of experience on recent FSRAO broker complaints - An enormous amount of conflict arises when you tell the agent of concern who the complainant is. We all want to get rid of the 'bad apples', but this practice will (and has) lead to lack of desire to file complaints for misrepresentation / fraud, even the complete end of filing them.

FSRAO needs either
- A better process to protect complainants, without a tonne of red tape. If you research the BC and AB processes you'll find they have an easy to use anonymous tip methods that have no red-tape. OR
- Implement a "duty to report" requirement for industry professionals (brokers and lenders).

Until changes are made, you will get minimal, or no, support from industry professionals to help 'clean up' the mortgage broker industry. I'm sure you've all read the Cullen report, this needs to happen.

Financial Planners and Advisors
[2022-012] Rick Tomalty - Caldwell Wealth & Estate Advisory Ltd.: Rick Tomalty Inc.
Over the past few years, the process for licensing as a financial advisor or a financial advisor corporation has become inexplicably long. We are advised 60 days in advance of renewal and are unable to start our licensing renewal process prior to that, yet chronically are running up against our licence expiry date before having our renewal applications processed,. Most often, the licence reaches expiry prior to the renewal being finalized. If we should consider FSRA as a service provider and we as their clients/customers, should we not expect improved service? Meanwhile we get regular updates on how well things are progressing within their processes and systems. It's hard to see the improvement from my vantage point.
Date posted Sector Question and response
Auto Insurance

Question: In 2011, the Ontario government mandated the use of the IBC owned, internet based, medical document submission system called HCAI. This system is lacking a validation work process and this flaw in the system is costing the citizens and businesses of Ontario millions in fraudulent accident benefits submissions.
My question is
a) When is FSRA going to fix this flaw in their mandated system?
b) How is FSRA going to fix this flaw in their mandated system?

FSRA response:

FSRA’s proposed 2023-2024 Statement of Priorities commits to working with health service providers and auto insurers to improve Health Care for the Auto Insurance system, including the efficiency of billing and data practices to enhance consumer outcomes.

Managing system costs and reducing fraud and abuse in the auto insurance system is important to FSRA. Current HCAI work is focused on curbing identity theft and the fraudulent use of professional credentials, including removing bad actors engaged in these and other improper billing practices.

For example, HCAI continues to work with the health service provider community to improve the efficacy of its professional credential tracker. FSRA has also enhanced the use of data analytics in its oversight and licencing of health service providers.

Credit Unions and Caisses Populaires

Question: Re: 6.2 Enhance financial stability structures, Key deliverables b) Differential premium system.
Can the “risk profile” include distribution of share dividends to the members?
and publish info to the public for comparative credit union features and credit union viability?

FSRA response:

  1. FSRA will be conducting a public consultation on proposed changes to the differential premium system in November 2022. We welcome your input about the proposed methodology during that consultation. 
  2. FSRA publishes aggregated credit union data on a quarterly basis on its website (see the “Sector Outlooks” at the following link: FSRA does not publish data received from individual credit unions.