ID
2025-004

Type
Rules
Sector
Life and Health Insurance
Status
Public comment closed
Date
Comment Due Date

Thank you for providing your feedback on FSRA’s consultation on proposed Rule 2025-001 – Life and Health Insurance Managing General Agents.

The request for submissions is now closed.

We appreciate the comments and questions received to date and look forward to sharing with you the final Guidance. Stay up to date on Guidance releases on our newsroom. Follow us on LinkedIn and subscribe to our mailing list for quick updates.

Ontario’s financial services regulator (FSRA) is proposing a new rule to better protect consumers and strengthen oversight of life and health insurance managing general agents (L&H MGAs).

It will also help ensure consumers are treated fairly and consistently and they are receiving advice from well-trained and properly supervised agents.

The proposed rule builds on recent amendments to the Insurance Act creating a separate licensing class for L&H MGAs in Ontario. It establishes clear licensing, compliance and agent oversight requirements for businesses performing certain regulated L&H MGA activities related to the sale of life and health insurance. The proposed rule also enhances accountability for L&H MGAs and insurers by clarifying roles and responsibilities in agent supervision and introduces requirements for agents who work with L&H MGAs.

The proposed rule is part of FSRA’s six-point action plan to correct troubling practices in the life and health insurance sector which are harming consumers.

FSRA encourages stakeholders to submit feedback on the proposed rule, open for consultation until March 31, 2025.

Learn more:

FSRA continues to work on behalf of all stakeholders, including consumers, to ensure financial safety, fairness, and choice for everyone. Learn more at www.fsrao.ca.

Sector Comment Date posted
Life and Health Insurance
[2025-004] Margaret Campbell - CLHIA
Note: This document was received on May 30, 2025. It replaces the one received on April 30, 2025, which included one word in error. The original document is available upon request.
Life and Health Insurance
[2025-004] Carole Yari - TPAAC
Life and Health Insurance
[2025-004] Giuseppina Marra - Desjardins Group

Life and Health Insurance
[2025-004] Nina Kavalinas - CAILBA
Please find attached the response to the rule consultation from the Canadian Association of Independent Life Brokerages.
[2025-004] Richard Williams - World Financial Group Insurance Agency of Canada
Life and Health Insurance
[2025-004] Michael Camacho - The Travel Health Insurance Association of Canada
Please find attached the response from The Travel Health Insurance Association of Canada (THIA).
Life and Health Insurance
[2025-004] Will Chang - Financial Horizons
Life and Health Insurance
[2025-004] Phil Marsillo - IDC Worldsource
Life and Health Insurance
[2025-004] Andrew Fitzpatrick - Canada Life
Please find Canada Life's comment letter attached.
Life and Health Insurance
[2025-004] Shelden Smollan - Experior Financial Group Inc.
Life and Health Insurance
[2025-004] Nicola Acocella - The Advisor Group
Thank you for providing an opportunity to submit feedback on the Proposed L&H MGA Rule.

The Advisor Group (TAG) is an ethical, compliant organization with no hesitation whatsoever in supporting rules or regulations designed to protect our industry and our customers. However, we believe that many of the underlying assumptions in the proposed Rule are inaccurate and have produced a set of draft regulations that are not reflective of the businesses and customers we serve.

Our concerns are varied and include the following:
Regarding the term L&H MGA - we are a firm that provides advisor support services and do not operate in a manner like Individual Insurance MGA businesses. We do not sell Individual Insurance products, nor do we manage individual financial assets, investments, or savings. The proposed Rule inaccurately co-mingles Individual Insurance and Group Insurance and does not accurately reflect the operations or activities of our Group business.
Article 407.2 ‘Regulated Activities’ - The scope of services/requirements are far too broad and do not reflect the reality of our Group MGA business.
The 'supervision of agents/ licensing of agents / training of agents' requirement may reflect the reality of Individual MGA businesses but do not reflect the activities related to Group businesses.
Please consider:
Agents who contract with us for support services have already gone through a very detailed licensing process with any insurance company they utilize and have provided proof of Errors & Omissions insurance.
We do not contract with any advisor who isn’t already licensed in good standing with the applicable insurers and who does not have active E&O insurance
Advisors who utilize our services ‘own’ the customer business and we do not share ownership of these customers in any way. To the contrary, the value proposition to our advisor partners reinforces their ownership and states that we are merely a service provider and not a direct competitor
It would be fair to state that we do not provide ’training' per se. The advisors who utilize our services are proficient in Group business. We do sometimes offer broad-based industry education, but we do not offer curriculum based training.
Review 407.4 - The requirement of a 30-day submission deadline for the addition and termination of agents is far too short.
Article 407.10 - This article creates duplication whereby Group MGAs and insurers are required to build governance and compliance practices that mirror each other. There are significant investments in time and money involved and some Insurers will take this opportunity to exit the MGA business due to their unwillingness to invest in these processes.
Our MGA business model currently provides an opportunity for small advisors to compete with large, national and multi-national advisory firms and to access insurers who don’t want to bother with small advisory firms. In our opinion, these proposed regulations will limit consumer choice and inadvertently help monopolize the group advisory business in Canada between a handful of super-sized firms.
Unlike Individual MGA businesses, Group L&H MGAs do not have access to a centralized services / compliance / governance / library platform like APEXA
Third Party Administration and MGA businesses are often linked. In the earliest version of this discussion there was reference to TPA businesses but that distinction seems to have disappeared. We would like to see overt discussion on any regulations as they relate to this business, especially TPA firms that pay claims (known as TPP firms).

We thank you for the opportunity to provide feedback and look forward to any future discussions in support of our business and the development of appropriate rules and regulations.
Life and Health Insurance
[2025-004] Barb Leighton - PPI
Please find attached a letter from Cathy Hiscott, President and CEO of PPI Management Inc., in response to the request for Consultation on Proposed Rule 2025-001 Life and Health Insurance Managing General Agents.

Thank you
Life and Health Insurance
[2025-004] Samantha Sheppard - Co-operators

Life and Health Insurance
[2025-004] ed skwarek - Advocis
Attached please find the submission for Advocis.
Life and Health Insurance
[2025-004] Hande Bilhan - Primerica Life Insurance Company of Canada (PLICC)
Attached please find our consultation response.
Life and Health Insurance
[2025-004] Mario Malatesta - Peoplecorp / GroupQuest
FSRA Proposed Rule 2025-001 - Life and Health Insurance Managing General Agents
Subject: Our Comments/Feedback on Proposed Changes to Life and Health Insurance MGA Regulations

We appreciate the opportunity to provide feedback on the proposed changes and regulations regarding Life and Health Insurance Managing General Agents (MGAs).
We’d like to comment on how our own Health Insurance Managing General Agency (GMGA's) work with Third Party Advisors and provide some additional detail on the work and services we provide to our Advisors in the Group Benefits Industry. We want to suggest that they are very different in comparison of what a Life MGA does for and with their Advisors.
The services and support that are provided to Life Insurance Agents from a Life MGA are an extension of services that would’ve been provided by an insurance company. Most of that ‘Support’ and many of those services were passed down to The Life MGA.
Health Insurance Managing General Agency (GMGA's) act more like an extension of the Advisor’s role, services and work which is very different to Life MGA’s.
We as a Group MGA’s do prospect Advisors and Firms to work with us to support them as an extension of their office in doing similar work that they would be doing on their own or with an assistant. We simply help them as a back office support system with ‘the paperwork’.
We review Group Benefit Applications to ensure correctness, completeness, dotting the I’s and crossing the T’s if you will. These applications are completed and signed by the Advisor along with their clients. (Our Advisor’s Clients or Policyholders are the Advisor’s clients… not our Clients). Once Applications are received, they are sent to the insurance company for review and coverage binding.
We are the GMGA on a Group Policy; we are not the Agent of Record as it’s ONLY the Advisor or Firm that is the Agent of Record

We as a Group Benefit MGA do not:
*Recruit and or Train agents directly on behalf of the insurance company.

*Have underwriting authority or authority to make any changes to a group application or bind coverage

*Screen agents or proposed agents to determine their suitability to act on behalf of the insurer.

*Enter into written agreements with agents to sell or solicit Life and Health (L&H) insurance on behalf of a specific insurer.

*Pay commissions or any type of remuneration to our Advisors/Firms

*Supervise or monitor agents involved in the sale or solicitation of L&H insurance on behalf of the insurer.

*Manage insurance contracts or client relationships directly or indirectly. As mentioned earlier, the Client of a GMGA is the Advisor or Firm.

As I’m sure you would agree that there is quite a difference in how or what a Group Benefit MGA works with Advisors compared to a Life MGA.
Group Benefits Advisors are contracted and paid directly with the insurance companies…. Not with our Group MGA.
Canadian Insurance companies normally manage Advisor Contracts, Screening, contracting, and payment of commissions and bonuses directly with the agents.
The Group MGA's role is to help Advisors and Firms specific to their Clients Group Benefits Programs.

It is essential that FSRA recognizes the considerable differences between distribution models—some of which are designed to simply link insurers with advisors, while others remove the insurer entirely from the sales process..

Our final comment has to do with the Technical Advisory Committee that FSRA manages.
It is a shame and not understandable that not one person in the committee is from a Group MGA company. In looking at the membership list, there are 15 members representing Life MGA’s, CLHIA, Legal, Carriers, Advisors and Investments. Having input from a GMGA person would be extremely beneficial, providing proper feedback, knowledge and better explanations.


Thank you.

Mario Malatesta
People Corporation- GroupQuest Benefits Resources
Life and Health Insurance
[2025-004] Godfrey Kiu - TruStone Financial Inc.
Life and Health Insurance
[2025-004] Kim Moffatt - HUB Financial Inc.
Life and Health Insurance
[2025-004] Leo Chow Bello - POA/Advocate
Submission to FSRA – Proposed Rule 2025-001: Life & Health Insurance MGA Oversight
Submitted: Friday April 25th, 2025
In response to FSRA’s consultation on Proposed Rule 2025-001, I am submitting a case-based policy recommendation to support stronger, enforceable oversight of Managing General Agencies (MGAs) in Ontario’s life and health insurance sector. This submission draws from direct, documented experience with a vulnerable consumer harmed under existing regulatory gaps.

The case involves a Deaf Ontario resident who receives ODSP (Ontario Disability Support Program) and communicates primarily through American Sign Language (ASL), with low English comprehension. This individual was sold a complex, high-cost permanent life insurance policy by an advisor operating within an MGA hierarchy that actively marketed to the Deaf community. The product’s long-term structure and fee load were fundamentally incompatible with the financial realities of someone living on a fixed disability income.

The advisor used ASL, but this did not ensure comprehension. In fact, the use of the client’s own language raised—not reduced—the duty to confirm understanding. To this day, the individual cannot explain what the product does, why it was purchased, or where their money is going. As Power of Attorney and their primary advocate, I have personally confirmed this through repeated, direct conversations. This failure of informed consent represents a profound breach of both accessibility and suitability obligations.

Communication must go beyond words or signs. The complexity of permanent life insurance products requires not just linguistic accommodation but also numeracy accommodation. Concepts like monthly deductions, annual cost escalators, investment performance, and cash surrender value must be explained in plain, dollar-for-dollar terms. In this case, they were not. The individual still cannot explain whether they are saving money, spending money, or insuring something. This is not just a language gap—it is also a basic math gap that reflects a deeper failure in transparency, comprehension, and dignity in financial service delivery.

The advisor who sold this policy presented themselves as a financial educator and empowerment advocate within the Deaf community. Through ASL-accessible social media posts and paid seminars hosted at the MGA’s own office, they positioned their outreach as a form of community service—promoting financial literacy, self-reliance, and informed decision-making. However, these sessions functioned primarily as sales funnels, with education used as a marketing veneer to direct vulnerable attendees—many of whom were ODSP-dependent—toward complex, high-commission insurance products. The distinction between unbiased financial education and product promotion was blurred, leaving participants with the impression they were receiving guidance, when in fact they were being led into transactions that lacked independent verification or informed suitability review.

For nearly seven years, monthly premium withdrawals occurred silently from the individual’s ODSP-funded account without detection. These deductions went unnoticed due to a combination of language barriers, financial vulnerability, and social isolation. The policy remained hidden until it was independently discovered in 2025 after their account was overdrawn and long after the window for early cancellation had passed. This underscores not only a sales failure, but a sustained service failure, exacerbated by the complete breakdown of support once the advisor became unreachable.

At every stage—sales, service, escalation—the consumer was failed. No documented financial needs analysis or suitability records have been received. The insurer, when contacted, referred all inquiries back to the original advisor, effectively denying access to information and support. The agent has not returned any emails requesting the above information.

This is not an isolated case. It reflects systemic patterns already documented by FSRA and outlined in its 2021 Insurer–MGA Relationship Review:

+Lack of enforceable agent screening and oversight protocols

+Minimal or inconsistent agent training in suitability and product risk

+No formal escalation pathways when MGAs or advisors fail to respond

+Delegation of functions without insurer accountability for outcomes

Despite existing principles under the Fair Treatment of Customers (FTC) guidance, there is currently no binding requirement for insurers to screen for or safeguard vulnerable clients like those on ODSP. FTC encourages extra time and care, but offers no enforceable obligation.

Policy Recommendation – Mandatory Suitability Protocols for Public Assistance Clients
I urge FSRA to include in the final Rule 2025-001 the following enforceable safeguards:

Automatic Vulnerability Trigger
Require insurers and MGAs to flag applications where the applicant receives ODSP, Ontario Works, CPP-D, or other income-tested public support.

Enhanced Suitability Review
Mandate a documented financial needs analysis and written rationale approved by a supervisor or compliance officer before issuing any permanent life insurance product to a low-income or vulnerable client.

Informed Consent Standard
Require insurers to ensure that communication is not merely linguistic but comprehensible—including confirmation of numeracy, use of visual tools, and the ability to articulate policy implications in plain terms.

Advisor Escalation Protocol
Mandate that insurers provide a direct, accessible path to policy servicing and disclosure when the advisor or MGA fails to respond within a regulated timeframe.

These measures would not restrict access to insurance—they would protect against the sale of inappropriate, high-commission products to those least able to bear long-term financial burden.

Once full policy documentation is received from the insurer, I intend to file a formal complaint under FSRA’s consumer protection framework. Based on all available facts, the product sold in this case appears structurally unsuitable, unsupported by documentation, and marketed in a manner that failed to meet any reasonable threshold for informed decision-making.

That said, I recognize that even a successful complaint may not result in restitution that fully reflects the scope of harm. The financial losses, psychological strain, and long-term erosion of trust in the financial system will likely exceed any remedial outcome available under current frameworks. This is not merely about individual redress—it is about regulatory deterrence. As long as the consequences for these sales practices remain limited to isolated penalties or private remediation, they will continue. A system that allows public income to be siphoned quietly, while the parties involved face minimal accountability, must be corrected through enforceable and transparent regulation.

I strongly support FSRA’s efforts to introduce licensing accountability and system-wide reform. This case provides clear, lived evidence of why those efforts must be both timely and uncompromising.

Respectfully submitted,
Leo Chow Bello.
[2025-004] Consumer Advisory Panel to The Financial Services Regulatory Authority of Ontario (FSRA) - Consumer Advisory Panel to The Financial Services Regulatory Authority of Ontario (FSRA)
The Consumer Advisory Panel had the opportunity to participate in this consultation. The Panels official submission provided in the attached document.
Life and Health Insurance
[2025-004] Sally Hagan - Group Force Benefits Inc.
Life and Health Insurance
[2025-004] Pricilla Kugathasan - Global Insurance Solutions Inc
1. Advisors should only contracted with one MGA for all the carriers.
2. need to verify the clients photo ID with the every insurance application. "photo ID with the current address".
3. Insurance carriers are asking for a NewBusiness application when applying for a new Contract. how it is possible for an advisor to run an illustration without a product knowledge.
Financial Planners and Advisors
[2025-004] Matthew Hallett - Greatway Financial
See attached
Life and Health Insurance
[2025-004] William Sadler - n/a
The changes and the present act is what we strive to do already. Thanks for the chance to respond.
[2025-004] Jocelyn Balendrez - Combined Chubb Insurance of Canada
Everything is good wonderful regulation.
Financial Planners and Advisors
[2025-004] Kirklin mckay - Cooperators
I appreciate the need to serve the public better, however I believe a new licensing program will cause unnecessary complexity and challenges to the already stringent licensing requirements that’s is currently in place. Eg addition CE and Fees to an already highly regulated system.
Life and Health Insurance
[2025-004] Myrose Tayamen
Life insurance claims should be processed as swiftly and efficiently as policy approvals. Consumers should not s control. A streamlined, transparent, and fair claims process will build trust and ensure that beneficiaries receive timely financial support when theface unnecessary delays or excessive paperwork when claiming benefits. Insurance providers must take responsibility for system or agent errors rather than denying rightful claims due to mistakes beyond the policyholder’y need it most. Isn't why insurances are here for? I think this is the best way to provide fair treatment to consumers. Not just the insurance companies having an impressive balance sheets due to enormous amount of denied claims and/or extended time delays providing the help to consumers when they needed the most.

The amount of time insurance companies should process claims should be very close or almost the same time as when they deducted the first premium.
Life and Health Insurance
[2025-004] Ekamdeep Singh
My thoughts are, there should be some restrictions on new licensed agents who have to work under supervising agent for few years to ensure their commitment, loyalty and stability towards industry and clients.
Another important thing is MLM MGAs should be monitored more frequently because most of the clients are not satisfied with after sale service from agent since he/she is busy in recruiting new agents.
Financial Planners and Advisors
[2025-004] Shadi Rangrizian - World Financial Group Inc.
Nothing to comment on at this time - thank you for eblasts/info mails.
Financial Planners and Advisors
[2025-004] Nancy Allan - Independent Financial Brokers of Canada
Please find attached the comments of IFB regarding the Proposed Rule for MGAs.
No questions have been asked about this consultation yet.