Cross Sector
Public comment closed
Comment Due Date

Thank you for providing your feedback on FSRA’s Proposed 2021-22 Statement of Priorities.

We appreciate the comments and questions received to date. Your feedback will help to inform our final statement of priorities.

The request for submissions is now closed.

Learn more about this consultation

FSRA is publishing its proposed 2021-22 Statement of Priorities and Budget for public 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 is inviting the general public and all stakeholders to review and provide feedback on the proposed 2021-22 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 budget 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.

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#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
Cross Sector
[2020-014] Bernard Brun - Desjardins Group

Cross Sector
[2020-014] Martha Durdin - Canadian Credit Union Association, CCUA

Cross Sector
[2020-014] José Gallant - Alterna Savings

Cross Sector
[2020-014] Jacques Goulet - Sun Life Canada

Cross Sector
[2020-014] Lisa Guglietti & Alec Blundell, EVP & Chief Operating Officer - The Co-operators Group Ltd.

Mortgage Brokering
[2020-014] J.P. Boutros - Mortgage Professionals Canada
On behalf of President and CEO Paul Taylor, please see the attached. Thank you.
Auto Insurance
[2020-014] Rhona DesRoches - FAIR Association of Victims for Accident Insurance Reform
Please find attached.
Thank you.
Mortgage Brokering
[2020-014] Anoop Bungay -
Kudos on your two new priorities, FSRA.

MQCC™ offers its leadership to you and your industry regulatees, on a Pan-Sector basis.

Best wishes,

Anoop Bungay
Life and Health Insurance
[2020-014] Earleen Moulton - CAILBA

Auto Insurance
[2020-014] Julie Nolette - Intact Insurance
We are pleased to provide our thoughts on FSRA proposed 2021-2022 Statement of priorities.
Life and Health Insurance
[2020-014] Susan Allemang - Independent Financial Brokers of Canada
Attached is the response from Independent Financial Brokers of Canada (IFB)
Auto Insurance
[2020-014] Christie Brenchley - Ontario Society of Occupational Therapists
The Ontario Society of Occupational Therapists is pleased to support the Financial Services Regulatory Authority's development of 2020-21 priorities. Please see the Society's input attached below.
Auto Insurance
[2020-014] Catherine Allman - Canadian Association of Direct Relationship Insurers
Please find attached CADRI's comments on FSRA's 2021-22 Statement of Priorities and Budget.
Credit Unions and Caisses Populaires
[2020-014] Stephen Bolton - Libro Credit Union
Thank you for the opportunity to provide feedback on FSRA's 2021-22 Statement of Priorities. Libro Credit Union offers the attached feedback within our response letter. We look forward to continue dialogue with FSRA on these important issues of mutual interest.
[2020-014] Rossana Di Lieto - Ontario Teachers' Pension Plan (OTPP)
On behalf of Ontario Teachers' Pension Plan, please find our comment letter attached. Thank you.
Auto Insurance
[2020-014] Vanessa Rankin - Ontario Association of Social Workers
The Ontario Association of Social Workers (OASW) is pleased to provide input to the Financial Services Regulatory Authority of Ontario (FSRA) regarding FSRA’s proposed 2021-22 Statement of Priorities. Please find our submission attached.

Thank you in advance for consideration of our submission and should you have any questions, please do not hesitate to contact me.

Vanessa Rankin, MSW, RSW
Senior Policy Advisor
Email: [email protected] | Web:
Ontario Association of Social Workers
Life and Health Insurance
[2020-014] Keith Martin - Canadian Association of Financial Institutions in Insurance (CAFII)

Auto Insurance
[2020-014] Erica Kelsey - Aviva Canada
Please see attached submission. Thanks!
Financial Planners and Advisors
[2020-014] James Ryu - Advocis
Dear Sirs/Mesdames,

On behalf of Advocis, The Financial Advisors Association of Canada, please find attached our comments in regards to FSRA's draft 2021-22 Statement of Priorities.

James Ryu
[2020-014] John Taylor - Ontario Mutual Insurance Association
Please find attached our submission with regards to Proposed FY2021-2022 Statement of Priorities.
Life and Health Insurance
[2020-014] Brent Mizzen - Canadian Life and Health Insurance Association
Attached please find CLHIA's comments on FSRA Statement of Priorities.
Auto Insurance
[2020-014] Dr. Moez Rajwani & Dorianne Suave, Coalition Co-Chairs - The Coalition of Health Professional Associations in Ontario’s Automobile Insurance Sector (“The Coalition”)
Please accept our feedback on the FSRA Proposed FY2021-2022 Statement of Priorities.

[2020-014] Kim Donaldson - Insurance Bureau of Canada

I am submitting this joint report on behalf of the Property and Casualty Insurance Industry SAC.
[2020-014] Brian Jenkins - ActuBen Consulting Inc.
I think that you need consultation of the smaller pension plans (less and 50 members), especially the defined benefit plans, that are not really serviced by the committee you currently have. I think you need actuaries and consultants that see how these plans deal with day to day issues, of which reporting has become a major time problem. Large plan people don't grasp the issues.
In addition, small plans -- but larger ones too -- need innovative ideas to deal with both the low rates of return and negative real/nominal rates of return as well, as the funding issues related to the decrease work force that the closing of industry has entailed. I don't think higher fees from the regulators would be helping the situations that are there or coming.
The currency deflation and price inflation we currently see is going to be a very big problem for most plans and the PBGF. Regulation really needs to adapt before it becomes a problem if protecting plan members' pensions.
Auto Insurance
[2020-014] Matt Caron - Ontario Trial Lawyers Association (OTLA)
Please find OTLA's submission to FSRA's proposed FY2021-2022 Statement of Priorities. Please email should you have any questions or require any additional information.
[2020-014] Deborah Thompson - MEBCO
Please find attached a response from the Multi-Employer Benefit Plan Council of Canada (MEBCO). Thank you.

Deborah Thompson
MEBCO Executive Director
Health Service Providers
[2020-014] Laurie Davis - Ontario Rehab Alliance
Please see the attached Commentary on FSRA 2021-22 Priorities from the Ontario Rehab Alliance.
Financial Planners and Advisors
[2020-014] Jean-Francois Demore - Innova Wealth
Please prioritize open banking and the evolution of technology service providers inside Canada's banking industry.
Date posted Sector Question and response
Credit Unions and Caisses Populaires

Question: Is there any detail available for the budgeted direct and common costs?

FSRA response:

($000's) F2021-22 Proposed Budget F2020-21 Budget Variance
Credit Union 6,578 6,306 272
Market Conduct 539 321 217
Other Direct      
    Policy 1,103 1,056 47
    Legal 705 512 193
    Lease 648 532 116
Other Direct  2,457 2,100 357
IT (Direct and Common) 2,266 1,106 1,160
Corp Services (exclude IT) 2,304 2,207 97
Other Common      
    Interest 208 159 49
    Amortization 1,201 721 480
    Others 1,058 769 289
Total Other Common 2,466 1,649 818
Total 16,610 13,690 818


Credit Unions and Caisses Populaires

Question: Can you provide more clarity around the 20% increase to credit unions?

FSRA response:

The 20% increased in Credit Union is from:

  • $0.2M increase in conduct supervision to meet adequate requirements for the sector. The investments will increase compliance capacity.
  • Regulatory enhancements increased by $0.2M to enhance the credit union resolution and recovery capabilities. Also there is a continuation of the investments to replace the inadequate core IT systems
  • $0.2M for amortization of DT ($6.2M current year investment which will be amortized over 5 years)
  • Regulatory effectiveness increased by $0.5M includes investments to address credit union principle based regulatory approach. The investment also includes sector participant/consumer and stakeholder communication initiatives and IT operations
  • Offset by efficiency in FTEs of $0.3M through management of staffing deployment.
  • Incremental $2.0M in regulation support and common costs. This includes $0.9M in IT support for credit union sector being transitioned from credit union-specific (DICO) costs to the proportionate costs of shared IT. The DICO IT architecture inherited in the merger with FSRA become less relevant given investments in IT and the move towards a fully integrated, secure and reliable digitally transformed FSRA IT environment. The transition will be complete in F2022-23. Details on the remaining $1.1M reg support/common cost as below:
Reg Support/Common Cost ($000's)
Increased in credit union salaries and benefits 266
Legal cost allocation 196
IT support allocation increased due to transition towards fully integrated model 890
Public Affairs 164
Increase in capital investment amortization 261
Other Common Allocations 208
Reg Support/Common Cost 1,985