Auto Insurance
Public comment closed
Comment Due Date

FSRA is committed to fostering a strong, sustainable, competitive and innovative financial services sector and to protecting the public interest.

Today, FSRA’s Innovation Office is releasing its Innovation Framework for consultation. 

The proposed framework outlines FSRA’s regime for facilitating open dialogue with innovators and our Innovation Office. It:  

  • sets out our guiding principles and approach to innovation;
  • describes our regulatory review process to make innovations easier for new entrants and industry incumbents; and
  • promotes the use of test and learn environments, starting with our Auto sector, which will help introduce new products, services and business models.

The consultation is now open and will close on November 18, 2021.

Helpful links:


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.

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Sector Comment Date posted Sort ascending
Credit Unions and Caisses Populaires
[2021-017] Sabena Sandhu - Canadian Credit Union Association

Property and Casualty and General Insurance
[2021-017] Elliott Silverstein - CAA
On behalf of CAA Insurance, attached is our submission for review.
Life and Health Insurance
[2021-017] Brendan Wycks - Canadian Association of Financial Institutions in Insurance (CAFII)
18 November, 2021

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

RE: CAFII Feedback on FSRA Consultation Document “All Together Now: FSRA, the Innovation Office, and an Innovation Framework for a More Innovative Ontario Financial Services Sector”

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 the Authority’s consultation document “All Together Now: FSRA, the Innovation Office, and an Innovation Framework for a More Innovative Ontario Financial Services Sector.”

Our Association is largely supportive of the Innovation Framework outlined in the consultation document, but we have some advice and recommendations to offer which we believe will help strengthen the framework. Therefore, we have divided our submission into two sections: Innovation Framework Concepts, Assertions, and Proposals Which CAFII Supports; and CAFII Observations, Advice and Recommendations Related To Strengthening Innovation Framework.

Innovation Framework Concepts, Assertions, and Proposals Which CAFII Supports

• FSRA’s primary role as a regulator is to protect consumers.

• FSRA’s vision for a vibrant Ontario financial services sector (page 4).

• the Innovation Office’s three key tenets/priorities of minimizing friction and reducing regulatory uncertainty and barriers; pursuing responsible innovation by driving greater choice and value for consumers while protecting their interests; and embracing a continuous learning and improvement theme.

• FSRA's innovation strategy and process will open dialogue between innovators and FSRA, providing certainty for innovators and helping to identify their regulatory responsibilities towards a clearer path for approval. This greater clarity will in turn reduce the costs of regulatory compliance and help remedy compliance concerns for innovators (page 8).

• the role and approach outlined for the Innovation Office in managing the Innovation Framework, including the “orchestrator model” (page 11). We concur that for the Innovation Framework to be successful, executives and their departments throughout FSRA must be committed to it; and that FSRA as a whole is responsible for owning and driving the innovation process.

• FSRA’s intention not to direct the substance of innovation, but rather to act as a facilitator for new products and services developed by the private sector.

• FSRA’s intention to “challenge established structures and closed mindsets that stifle innovation.”

• the Innovation Office’s embracing of a “Test and Learn Environment” (TLE) as central to the Innovation Framework, as it will allow for constant learning and adjustment.

• a rigid structure and approach are inconsistent with innovation; and the flexible approach FSRA is adopting will significantly increase the probability of successful outcomes.

• the flexibility which the Innovation Office is building in by allowing regulated entities to choose to pursue an innovation opportunity through the Innovation Office first, or through their existing contacts in their sector’s FSRA Core Regulatory Team first, or to avail of a mix of both avenues in tandem. Providing both options of these dual “outside-in” and “inside-out” approaches will open things up to the best thinking from FSRA and the industry around any particular innovation opportunity.

• FSRA’s intention to tailor its approach to each Innovation Framework participant’s unique characteristics and needs, recognizing that there is no “one size fits all” in the diverse financial services industry.

• existing regulatory tools can be leveraged in advancing the Innovation Framework; and while some new regulatory tools will be needed, the most important tool in promoting innovation is mindset.

• FSRA’s inclusion of a highly illustrative and informative Use Case example in the Innovation Framework consultation document. While the particular Use Case is rooted in the automobile insurance sub-sector of property & casualty insurance, its innovation characteristics are also readily applicable to the life and health insurance sector.

• FSRA’s indication (page 24) that it is interested in supporting and fostering all types of innovation opportunities, from ‘quick wins’ that can be addressed concretely in the short- or medium-term to more structural, long-term opportunities that require more detailed analysis but could unlock significant consumer and industry value if addressed.

CAFII Observations, Advice and Recommendations Related To Strengthening Innovation Framework

• handled properly, innovation and consumer protection are not inherently in conflict; rather, innovation can deliver the direct benefit of enhanced competition and increasing options and choices for consumers. Innovation can actually play a role in enhancing consumer protection by strengthening regulatory monitoring and controls, e.g. “regtech.”

• FSRA should consider ways in which the Innovation Office could encourage the BIPOC community and female entrepreneurs to participate in the Authority’s innovation efforts, in order to support and foster diversity, equity, and inclusion in the financial services sector.

• the Innovation Office should constantly scan and monitor the domestic and global business environments for innovations and trends that are emerging inside and outside of financial services; and FSRA should seek out and embrace those innovations that consumers are rapidly adopting, especially if they are readily transferable to financial services and/or to Ontario, as applicable.

• for the Innovation Office to foster innovation optimally such that Ontario can become best in class with respect to financial services innovation, it will be necessary for FSRA to allow maximum flexibility and permit embryonic, early-stage tech innovations – from both incumbents and new entrants -- to be tested, supported, and implemented in the province; and not to sit back and wait to see what other jurisdictions do first. The “Test and Learn Environment” (TLE) environment will support that objective, but how the TLE pipeline is structured and managed, and how accessible it is will be key for financial services innovation to flourish in Ontario. Several post-secondary institutions in the province – such as the Rotman School of Management, University of Toronto; University of Waterloo; and Ryerson University – have technology incubator labs which foster and support innovation and start-ups. FSRA should review the work of such labs at Ontario universities, and seek to leverage what works there and would be transferable to a financial services regulator.

• the Innovation Framework’s intention to foster new financial services entrants and facilitate their efforts to drive innovation and enhanced competition is laudable, provided that a path towards a common set of regulatory expectations for all market players – including new entrants as they develop and grow – is designed into the process. It’s important that FSRA’s efforts to foster innovation among new market entrants don’t result in hindering innovation among incumbents. Incumbents are not innately lacking in or behind new entrants in terms of innovation ideas or skills, but rather incumbents are often held back by existing regulations as compared to their more lightly regulated fintech/insurtech counterparts.

• to support innovation in a constant and “by design” manner, FSRA should maintain an ongoing commitment to review periodically its regulatory requirements across all regulated sectors, with a view to assessing whether they are achieving their desired outcomes. Central to FSRA’s role in the innovation process should be the avoidance of stifling innovation due to a complex regulatory environment. FSRA should also not waver from its commitment to principles-based, rather than prescriptive, regulation.

• with respect to the outlined five-step process for assessing risk, FSRA should avoid directing industry innovators as to what risks they should take on.

• with respect to the TLE fee structure, it is difficult to offer informed feedback without more detail and specificity. The concept of cost-recovery from new entrants is sensible, so long as the fees are not so prohibitive as to deter new entrants from engaging in the opportunity.

• in a future iteration of its Innovation Framework, FSRA should make the point that innovation is by its nature inherently risky; and, as a result, success for the Innovation Office does not mean that every innovation which it fosters and facilitates must yield an enduring outcome. It’s important to acknowledge that not every innovation will ultimately be adopted by the marketplace or consumers.

Concluding Comments
In closing, we thank FSRA for its continued commitment to open and transparent communication and consultation with the industry, particularly around such a novel initiative as the Innovation Framework.

As part of our commitment to supporting FSRA on this initiative, on November 29, 2021, CAFII will be hosting a webinar featuring Marlena Labieniec, Director of FSRA’s Innovation Office, in conversation about the Innovation Framework. CAFII member representatives, colleagues from allied industry Associations, and insurance regulators and policy-makers from across Canada will be invited to attend this education and dialogue webinar.

Should you require further information from CAFII or wish to meet with representatives from our Association on this or any other matter at any time, please contact Keith Martin, CAFII Co-Executive Director, at [email protected] or 647-460-7725.

CAFII and its members remain committed to supporting FSRA in its critically important regulatory work; and we look forward to continuing our involvement as a key stakeholder contributor to your efforts.


Rob Dobbins
Board Secretary and Chair, Executive Operations Committee

Credit Unions and Caisses Populaires
[2021-017] Jon Dessau - Kingston Community Credit Union
Please see attached file for Consultation response
Auto Insurance
[2021-017] Scott Parry - Desjardins Group

Auto Insurance
[2021-017] Kim Donaldson - Insurance Bureau of Canada
Attached is our submission on the Innovation Framework.

Thank you,

Auto Insurance
[2021-017] Ryan Stein - Economical
Good afternoon,

Great initiative. Thank you for the opportunity to participate in the consultation. Attached is Economical's response.


Auto Insurance
[2021-017] Erica Kelsey - Aviva Canada
Please see attached.
Auto Insurance
[2021-017] Paniz Ghazanfari - Advocis

Auto Insurance
[2021-017] John Taylor - Ontario Mutual Insurance Association

Auto Insurance
[2021-017] Julie Nolette - Intact Financial Corporation
Please find attached Intact Financial Corporation’s Written Submission to FSRA – Consultation on Innovation Framework.

Please do not hesitate to contact me if you have any questions.


Julie Nolette
VP, Personal Lines Ontario West & Atlantic
Auto Insurance
[2021-017] Catherine Allman - Canadian Association of Direct Relationship Insurers
Please find attached CADRI's comments on the Innovation Framework. Please contact me with questions.
Life and Health Insurance
[2021-017] Deanne Leifso - Manulife
Please find attached a submission from Manulife. Thank you for the opportunity to comment.
Property and Casualty and General Insurance
[2021-017] George Hardy - The Co-operators

Date posted Sector Question and response

Question: Just so I understand, this paper does not apply to the pension industry, correct? Just the areas listed on page 10?
Thank you.

FSRA response:

While Pensions are not explicitly included in the Innovation Framework, the decision of which other sectors FSRA will be using its Innovation Framework, hasn’t been made at this time. Rather, the intention is to begin with a Test and Learn Environment in the Auto sector and use that as an opportunity to assess the design and efficacy of the test environment and then determine, in conjunction with the Ministry of Finance, which other sectors should be prioritized to consider this approach. Regardless, FSRA will continue to identify areas under each sector regulatory framework where regulatory discretion can be exercised in a manner which is consistent with its statutory objects and to facilitate desired supervisory outcomes in accordance with FSRA’s principles-based approach.