ID
2024-012
ID
2024-012
Type
Priorités/budget
Secteur
Intersectoriel
État
Période de commentaires du public terminée
Date
14 novembre 2024
Date de remise des commentaires
6 décembre 2024
Nous vous remercions de nous avoir fait part de vos commentaires sur l’énoncé des priorités et le budget proposés de l’ARSF.
Nous apprécions les commentaires et les questions reçus à ce jour. Vos commentaires nous aideront à élaborer notre plan d’activités annuel.
La demande de soumissions est maintenant fermée et le résumé de la consultation se trouve ci-dessous. Restez au fait des lignes directrices publiées dans notre salle de presse. Suivez-nous sur LinkedIn et inscrivez-vous à notre liste de diffusion pour obtenir des mises à jour rapides.
L’ARSF lance une consultation publique concernant sa proposition d'Énoncé des priorités et de budget pour 2025-2026.
Les priorités de l'ARSF proposées continuent de protéger les consommateurs des manières les plus rentables possibles. Pour réaliser cet objectif, l'Énoncé de priorités présente des initiatives sectorielles clés ainsi qu'un budget responsable. Il s'agit notamment de renforcer les relations avec les intervenants et d'améliorer les résultats axés sur les consommateurs, en renforçant l'efficience et l'efficacité de la délivrance des permis et en modernisant les systèmes et les processus.
L'Énoncé des priorités constituera le noyau de notre Plan d'activités annuel, ce qui sera ensuite présenté au ministre des Finances en vue de leur approbation. Les informations financières incluses dans l’Énoncé des priorités sont des brouillons et seront révisées dans le cadre du processus de Plan d’activités annuel.
La consultation est un élément essentiel de l'engagement de l'ARSF en matière de transparence et de responsabilisation. Elle garantit que les projets de l'ARSF pour l'exercice à venir tiennent compte de la rétroaction des intervenants.
L’ARSF demande aujourd'hui de la rétroaction concernant sa proposition d'Énoncé des priorités et de budget pour 2025-2026. La consultation s'achèvera le 6 décembre 2024.
Pour en savoir plus :
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| Secteur | Commentaire | Date Trier par ordre croissant |
|---|---|---|
[2024-012] Hande Bilhan - Primerica |
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[2024-012] Craig MacLennan - FP Canada |
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[2024-012] Brad Neilson - Intact |
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| Courtage d’hypothèques | [2024-012] Bekim Merdita - Rocket Mortgage Canada
As a mortgage brokerage benefiting from referrals from trusted professionals like insurance agents and financial advisors, we believe referral programs are crucial to connecting consumers with the best mortgage solutions available. The following points support the continuation of such programs while safeguarding consumer interests:1. Consumer Trust and Accessibility: Referral networks enable consumers to rely on trusted advisors who understand their financial profiles and recommend tailored solutions. Removing or heavily regulating these networks could leave consumers overwhelmed by choices and less likely to secure the optimal mortgage product. Trusted advisors play a critical role in simplifying this process and ensuring consumers receive high-quality guidance. 2. Enhancing Consumer Interests: Referral systems inherently align with consumer interests when executed responsibly. By leveraging the expertise of advisors in related industries, consumers are introduced to vetted and relevant options, ensuring they receive products suited to their needs and financial situations. Restricting these systems could result in diminished access to competitive products and informed guidance. 3. Market Efficiency: Unnecessary regulatory burdens on referral systems risk creating inefficiencies in the mortgage market. This could hinder innovation and competition, ultimately limiting consumer choice. Instead, we encourage FSRA to focus on clear, actionable standards for transparency and accountability that ensure the integrity of referral practices without adding excessive red tape. 4. Focus on Oversight, Not Overreach: While ensuring consumer protection is vital, FSRA should avoid overly prescriptive regulations that might deter professionals from participating in referral programs. Proper oversight can focus on fair disclosure of referral arrangements and adherence to ethical practices without impeding the flow of referrals that benefit consumers. Recommendations: Maintain the ability of trusted advisors to refer clients to mortgage brokers while emphasizing disclosure and transparency. Implement balanced policies that promote ethical practices in referral compensation without creating undue administrative burdens. Ensure any regulatory changes prioritize consumer empowerment through access to competitive, high-quality mortgage products facilitated by referral partnerships. By enabling trusted professionals to continue referring clients to mortgage brokers, FSRA can uphold its consumer protection mandate while ensuring Ontarians have access to the best financial products available. |
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| Assurance vie et maladie | [2024-012] Margaret Campbell - Canadian Life and Health Insurance Association |
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[2024-012] 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. |
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[2024-012] Karyn Kasperski - Canadian Association of Financial Institutions in Insurance (CAFII)
The Canadian Association of Financial Institutions in Insurance (CAFII) thanks the Financial Services Regulatory Authority of Ontario (FSRA) for the opportunity to provide comments on FSRA’s Proposed FY2025-2026 Statement of Priorities. In this submission, we have restricted our comments to those sections of FSRA’s Proposed FY2025-2026 Statement of Priorities that are germane to CAFII members, i.e., to the Environmental Scan, to the FSRA-Wide Strategic Priorities, and to the Life and Health Insurance Sector-specific Priorities. We are aligned with the broad strokes of your environmental scan. Ontarians are preoccupied with the economy, the cost of living, and housing costs. A June 4, 2024 presentation to CAFII by Lesli Martin, Senior Vice President, Pollara Strategic Insights, revealed that Canadians have a more negative view of economic performance than what the data suggests, with 73% feeling that the economy was in recession when in fact it was not. Ms. Martin noted that perception is reality and that Canadians’ negative attitudes affected their spending, savings habits, and their views of the Canadian economy.[1] Of particular relevance to the industry is that insurance is often viewed as a supplemental expense. With household finances stretched, an already underinsured and uninsured Canadian marketplace could see lower levels of insurance coverage if Ontarians feel that they cannot afford the costs of optional insurance. We also agree with your observations about the increasingly rapid pace of technological change including artificial intelligence, which is an area that we are monitoring closely. A presentation was made to CAFII by Melissa Carruthers and Azadeh Dehghanpour, partners at Deloitte, on these issues and they were of the view that there are many opportunities for these technologies to be used in positive ways to improve the customer experience in insurance including in customer service and claims settlement.[2] CAFII supports your attention to vulnerable consumers, and our members take this issue very seriously. CAFII made a written submission on March 8, 2024 on FSRA’s consultation on its proposed approach to strengthening the protection of vulnerable consumers. With respect to FSRA’s Strategic Framework, it is CAFII’s view that FSRA is an exemplary regulator engaging in open consultations and transparency. FSRA is principles-based, outcomes-focused, and committed to sincere and honest collaboration. We note in this regard, as examples, the highly informative webinar held on principles-based regulation on October 7, 2024, and the ongoing sessions of the Life and Health Insurance Sectoral Advisory Committee, of which CAFII’s Executive Director Keith Martin is an active participant. CAFII and its members value their interactions with the executives of FSRA, who are singularly professional and well-informed. In that regard, CAFII applauds your ongoing commitment to “Strengthen stakeholder relations and improve consumer-focused outcomes,” and supports your efforts around enhancing licensing efficiency and effectiveness, and modernizing systems and processes. With respect to your work on life and health insurance, including your initiatives to ensure that the MGA distribution channel has proper oversight, we encourage FSRA to help Ontarians understand the importance of life insurance to a robust financial plan. Financial literacy is a critically important area that CAFII and its members are committed to. A March 2024 survey of Canadians commissioned by CAFII and conducted by independent research organization LIMRA found that Canadians are underinsured and uninsured against their lives and health.[3] The study found a concerning trend among Canadian homeowners: a significant 80% lack sufficient insurance coverage, being either uninsured or underinsured with Credit Protection Insurance (CPI) or traditional life insurance.[4] This shortfall in coverage leaves many families inadequately protected against unforeseen life events. FSRA plays a critical role in ensuring the stability and oversight of the life insurance sector, giving confidence to consumers that it is properly regulated and is treating them fairly. A summary of some of the findings from our LIMRA research initiative can be found in Appendix A to this submission. CAFII is very interested in the work of the Innovation Office to partner with Fintech Cadence in the pursuit of increasing fintech’s knowledge of and access to FSRA’s Test and Learn Environment, which could lead to more innovation in the sector. As well, CAFII members of the Diversity, Equity, and Inclusion (DEI) Working Group learned much from a presentation by Swati Agrawal on the work FSRA has done on these issues with the International Association of Insurance Supervisors (IAIS), and we hope to have a webinar with Ms. Agrawal in 2025 to discuss the work of the IAIS in this area. In closing, CAFII again expresses its appreciation of FSRA’s continued commitment to open and transparent communication and consultation. We look forward to making further representations of our Association’s views on FSRA’s Proposed FY2024-2025 Statement of Priorities through the Life and Health Insurance Sectoral Advisory Committee’s meetings, which, as noted CAFII actively participates in. Sincerely, Karyn Kasperski Board Secretary and Chair, Executive Operations Committee Appendix A Low-income homeowners are significantly more likely to be uninsured compared to those in higher income brackets. Of those who are insured, 75% of low-income homeowners are underinsured, meaning they lack sufficient coverage to protect their financial well-being. Despite the alarming rate of underinsurance, only 55% of all homeowners with credit own some form of CPI. This discrepancy is even more pronounced among low-income homeowners, who have notably less CPI coverage compared to their high-income counterparts. This suggests a gap in understanding of and access to CPI, highlighting the need for increased awareness and education about this form of insurance and its benefits. While 80% of Canadian homeowners are underinsured or uninsured, among low-income homeowners with credit, 24% have no life or health insurance and another 10% rely solely on CPI for their insurance needs. This is significantly more than other income groups and highlights the importance of this form of protection for financially vulnerable households. Finally, a significant portion of Canadian homeowners, 38%, fall into the category of “at risk.” These are homeowners with credit, who are uninsured or underinsured, and who would be survived by partners or dependents. This group is particularly vulnerable to financial hardship in the event of unexpected life events. Taken together, these findings demonstrate the importance of not impeding access to these insurance protections, and not unfairly tarnishing the reputation of this industry or the access to these products by underinsured and uninsured Canadians. These products offered by banks and credit unions provide critical protections in the marketplace and treat consumers fairly. The insurance is optional; full disclosure of premiums, exclusions, and limitations are made; and the industry has a strong record around claims payout. For example, separate research commissioned by CAFII and conducted by polling company Pollara Insights found that 95% of mortgage life insurance claims were paid out. About CAFII 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 15 members include the insurance arms of Canada's major financial institutions--BMO Insurance, CIBC Insurance, Desjardins Insurance, National Bank Insurance, RBC Insurance, Scotia Insurance, and TD Insurance, along with major industry players Assurant Canada, The Canada Life Assurance Company, Canadian Tire Bank, Canadian Western Bank, Chubb Life Insurance Company of Canada, CUMIS Services Incorporated, Manulife (The Manufacturers Life Insurance Company), and Securian Canada. |
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| Credit unions et caisses populaires | [2024-012] Brent Furtney - Canadian Credit Union Association
Please find attached our formal response to the FSRA Consultation on its Statement of Priorities 2025-26. We appreciate the opportunity to comment on the document and look forward to continued dialogue on the items brought forward within our response throughout the year. |
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| Assurance automobile | [2024-012] Amanda Dean - Insurance Bureau of Canada
Good Afternoon,Please see the attached submission from the Insurance Bureau of Canada. If you have any questions on our commentary please do not hesitate to reach out. Sincerely, Amanda Dean, Vice-President, Ontario & Atlantic |
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[2024-012] Regan Lalonde
Please find OTLA's submission attached. Do not hesitate to contact us if you require additional information. |
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| Assurance automobile | [2024-012] Catherine Allman - Canadian Association of Direct Relationship Insurers
CADRI's review of the Statement of Priorities calls for:• FSRA to set a service level agreement of 10-days turnaround for the majority of its licence applications and renewals (down from the current 20 days), • The retirement of FSRA’s legacy IT system in favour of a modern portal suited to users, • The conclusion of the rate and underwriting reform process in 2025, and • Approval of FSRA’s proposed 2025-2026 budget with its 2.8% decrease over last year. We welcome FSRA's questions. |
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[2024-012] Susan Allemang - Independent Financial Brokers of Canada (IFB)
Attached is the response from Independent Financial Brokers of Canada (IFB).. |
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| Planificateurs financiers et conseillers financiers | [2024-012] Amin Mawani - York University - Schulich School of Business
The Financial Services Regulatory Authority of Ontario (FSRAO) should be commended for working towards improving Canadians’ access to financial advice, financial advisors and financial planners. Timely access to financial advice may be akin to timely access to justice, since justice delayed is often considered to be justice denied. However, the quality of justice (legal system) and the legal advisors’ incentives are presumed to be uniform and sound whether delayed or provided on time. The same uniformity of financial advice quality may not always apply, in part because of the different incentives among financial advisors. It is not a secret that many advisors credentialed by the FSRAO are compensated and incentivized based on new business (e.g., either additional mortgages or additional savings products) brought in from existing or new customers into the advisors’ institution. Such advisors may also be more readily available at point of product sale. In late November, The Ontario Securities Commission (OSC) and the Canadian Investment Regulatory Organization (CIRO) launched an investigation of sales practices at Canadian bank branches. This follows a June 2023 Globe and Mail story that explored how the sales culture at Canadian banks is designed to nudge customers into high-fee products, and a 2018 review of bank practices by the Financial Consumer Agency of Canada (FCAC) that found branches have become more like stores selling investments. At that time, FCAC found that banks’ efforts to prevent sale of unsuitable products to customers were insufficient. FSRAO appropriately claims that it will remain “consumer-centric when formulating its regulatory approach toward regulated … individuals,” and that “FSRA will focus on the impact on consumers.” But it seems that other regulators are calling out the harm to customers when FSRAO may not be seeing the harm. There is a large body of literature from finance and accounting (including my own research) that has empirically established that “what gets measured, gets managed.” Advisors working at banks are evaluated on sales targets, which can pit their own interests against those of the customer. FSRAO has done a great job in highlighting which financial advisors may not be in good standing with their credentialing body. But sales pressures and sales incentives have largely been neglected by regulators as well as by FSRAO. FSRAO may now want to consider publicizing how various different types of financial advisors may be compensated (or incentivized). There is sufficient variation in compensation across credentialing bodies that needs transparency, even if some variation within members of a specific credentialing body may continue to be less transparent. While I am not presuming that most advisors are motivated or influenced by their compensation, FSRAO should at least be making financial consumers aware that self-interest could be clouding some advisors’ judgment, at least on a subconscious level. The 2024 Forum Research reports on survey-based consumer awareness about various aspects of financial advisors but is conspicuously silent on asking financial consumers on whether they are aware of differences in incentives among different financial advisors. By approving Credentialing Bodies, FSRAO may come across to the public as approving multiple credentials on an equal footing even though all Credentialing Bodies do not assess members’ competencies equally broadly, monitor equally rigorously, enforce equally diligently, or are incentivized similarly. Some credentialing bodies have made and continue to make significant long-term investments in competency framework. This includes involving academic and industry participation in their standard setting and competency framework discussions, resulting in a framework that remains applicable in practice for a broad range of clients. We may need more research to document the consumer harm faced by inadequate standards for financial planning by credentialing bodies that do not have competency frameworks or enforce their standards as diligently. Sales orientation can also detract some financial advisors from focusing on the client's best interests. A survey by the Financial Consumer Agency of Canada found 49% of respondents lived on a budget and a large percentage of Canadians continue to avoid the subject of financial literacy. FSRAO needs to accommodate the public’s lack of financial literacy rather than try to correct it. One of the top three most common questions asked by financial consumers goes along the following lines: “I have managed to save an additional $10,000 this year. What should I do with it: pay down my 7% mortgage by $10,000 on its anniversary or contribute the $10,000 to my RRSP earning 6%?” I have anecdotally investigated such advice from financial advisors working at banks and for-fee financial planners. Financial advisors at banks often advice such customers to invest in RRSPs - perhaps because they are incentivized to maximize new money brought in and not to decrease mortgages outstanding. For-fee financial planners usually recommend that the customer pay down the mortgage instead of investing in a RRSP. The answer in the customer's best interest depends on factors such as the respective rates of return, current marginal tax rate and expected marginal tax rate at retirement. Some customers may need help in estimating some of these input variables. However, a client-specific optimal solution does exist. And the stakes are fairly high over the term of the mortgage. And yet many advisors follow generic rules of thumbs that seem to serve advisors’ interests instead of consumers’ interests. FSRAO claims that they “measure success through outcomes, not inputs,” even though faulty advisory output may not be difficult to assess independently or objectively. In its job postings, FSRAO states that “our vision is to ensure financial safety, fairness, and choice for Ontarians. As a financial services regulator, we’re passionate about protecting consumers. Our principles-based approach means we can quickly and effectively respond to the changing needs of consumers and the industry.” These principles-based approach can work effectively if advisors’ compensation was not so skewed towards their self-interest. FSRAO may need more independent research to document the consumer harm faced when advisors do not keep the public's interest foremost in mind. FSRAO's narrow focus on consumers' access to advice may not be as meaningful if the quality of the advice and incentive compensation is so variable across credentialing bodies. This situation may get worse. A November 2024 survey by Intuit Canada revealed that 73% of Canadian high schoolers are aware that they lack the knowledge to make informed financial decisions, with only 20% comprehending basic financial concepts such as debt. Suboptimal financial advice to this group of customers could harm them for a long time to come. Thank you for this opportunity to submit this feedback on FSRAO’s Statement of Priorities. Sincerely, Amin Mawani, LL.M, PhD Professor of Taxation and Schulich Research Excellence Fellow |
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| Fournisseurs de services de santé | [2024-012] Jeff Bolichowski - Ontario Kinesiology Association
OKA notes Section 4.2 of the proposed FY 2025-26 Statement of Priorities, seeking reforms of the auto insurance product. Kinesiologists were recognized as Regulated Health Professionals under Health Claims for Auto Insurance (HCAI) in 2013 and can prepare and supervise a treatment and assessment plan for Motor Vehicle Accident victims. These are contained in Part 5 of the Treatment and Assessment Plan form (OCF-18 form) filled out as part of the Accident Benefits process. With Kinesiologists, however, that plan must be certified by a second regulated health professional. This is unnecessary: the Treatment and Assessment Plan falls within the Scope of Practice of Kinesiologists. While the form includes a checkable box for “other” professions, Kinesiologists should be listed directly – they are a regulated health profession whose scope of practice directly covers this area. Rehabilitation of injury falls within Registered Kinesiologists’ practice. As such, Kinesiologists should have the authority to independently sign off on OCF-18 Part 5, rather than requiring certification by another health professional. |
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| Assurance IARD et assurance Générale | [2024-012] John Taylor - Ontario Mutual Insurance Association
Please find attached OMIA's submission with regards to FSRA's 2025-26 Statement of Priorities. |
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| Credit unions et caisses populaires | [2024-012] Nicholas Nestico - Libro Credit Union
Please see attached Libro Credit Union's response to the consultation on FSRA's Statement of Priorities and Budget for FY2025-26.We greatly appreciate the opportunity to provide our feedback and look forward to further dialogue in the coming year. |
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| Intersectoriel | [2024-012] Marra Giuseppina - Mouvement Desjardins (Desjardins Group)
Bonjour, Le Mouvement Desjardins est heureux de soumettre ses commentaires en lien avec la présente consultation. Nous vous remercions pour l'occasion offerte. Bonne journée! Sarah Bouhenni Adjointe administrative Affaires réglementaires |
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| Intersectoriel | [2024-012] Zoe Lui - Studio AM |
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| Fournisseurs de services de santé | [2024-012] Desiree Knack - Fit to Function Kinesiology
In order for health care providers and consumers alike in the MVA realm to continue to provide/receive quality care, rates listed in the Professional Services Guidleine for healthcare providers NEED to be increased substantially - healthcare providers have not had a raise since 2014. I don't know anyone who has not had a raise in 10 years!! It is disgraceful. I, like many, are choosing to reduce or completely stop providing service for MVA clients. Insurers expect us to do more and more, but not get paid for it, and approve less and less. Insurers continue to make claimants and providers jump through more hoops and go through more red tape. Likewise, all of us as consumers pay a lot of money to insure our vehicles, then when we need them, they do not want to cover us, all while insurance companies make billions in profit. The wasted time on delayed approvals, assessments, and denials are wasteful and keep people in the system, instead of getting better and back to work/life. We have all had enough and quite frankly, should strike. Since there is no union, that will not happen, but I do plan to cease providing services in 2025 for MVA cases. |
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[2024-012] Bob Copeland
It seems to me that subject to your budget funds that limit priorities to a depth of involvement the upcoming challenge whether you like it or not is what effect artificial intelligence will have on fraud, the prevention of fraud, office procedures & various decisions to generate unbiased & visually fair results. Needless to say, the bad actors can pay larger sums of money to smarter people who can create faster & faster programs that can see relationships. The downside of human nature is that we’re a pattern-based herd species that run on patterns learned from parents, school & life experiences. This means we're more interested in emotionally defending our learned patterns whether they are inherently reasonable or not to other people. I can only suggest to save budget funds that you see if the various licensees & businesses will agree to form a committee to deal with the common problems in this area without giving away any competitive advantages. Artificial intelligence is based on relationships & we run on patterns learned from parents, school & life experiences since we're a pattern-based herd species. This means we're more interested in emotionally defending our learned patterns compared with finding any relationship to something else including people. |
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