L&H Insurance Technical Advisory Committee (TAC): 
Insurer Oversight of MGAs

Meeting summary

Date: June 2, 2023
Time: 9:30 – 11:00 AM ET

1. Opening remarks

FSRA opened the meeting and welcomed new members.

  • Amy Stahlke, Sun Life, replacing Matthew Onyeaju
  • Heidi MacDonald, Financial Horizons Group, replacing David Stewart
  • Patricia Ziegler, Empire Life, replacing Paul Holba

FSRA noted that the objective of the TAC meeting is to update members on the proposed regulatory framework for Life & Health (L&H) MGAs. 

2. Regulatory framework update 

I. Overview

FSRA outlined plans to strengthen the regulatory framework through the implementation of a proposed Rule and Interpretation Guidance. The aim of the changes is to establish practical, outcomes-focused standards and requirements to address customer related issues FSRA identified through its supervisory work.

II. Supervisory activities

Over the last three to four years, FSRA has reviewed L&H MGAs from different perspectives: from MGAs, the insurers that delegate activities to them, and the agents MGAs recruit and contract with to solicit the insurers’ products. FSRA found rapid growth of some MGAs with significant increases in new recruits and agents, inexperienced agents selling complex products, a lack of appropriate agent training, and a lack of adequate controls to screen and monitor the suitability of agents.

III. Policy approach

To address the supervision findings, FSRA is developing a regulatory framework in which insurers and intermediaries involved in the distribution of L&H insurance operate to high compliance standards, resulting in consistent and fair outcomes for L&H insurance customers. This includes:

  • MGAs to have clear compliance obligations and being subject to, and accountable for, appropriate regulatory requirements and best practices
  • insurers to achieve their compliance obligations with consistently robust compliance programs that oversee MGAs’ contractual obligations and compliance in relation to the regulatory framework
  • customers to have access to appropriate L&H insurance products that deliver reasonably expected benefits and can make informed decisions based on having access to educated and professional life agents equipped to provide fair advice and pertinent information based on the consumers’ needs

IV. Proposed rule outline

FSRA provided an overview of the proposed MGA Rule. The overarching aim of the proposed Rule is to provide consistent and fair outcomes for customers. The scope of the Rule will be activity based; it will not only include MGAs, but intermediaries that are performing targeted activities that have the potential for causing customer harm. The Rule will create new obligations and prohibitions that FSRA may enforce against.

V. Proposed Guidance

The proposed Guidance will clarify agent suitability requirements under the Ontario Insurance Act. It will apply to applicants and life insurance agents (individuals, corporates, and partnerships). It will also outline key factors and circumstances FSRA will consider when assessing the suitability of a person for licensing, including additional suitability factors for MGAs.

3. Next steps 

FSRA encouraged TAC members to provide feedback on the planned changes to the regulatory framework.  

FSRA will schedule the next MGA TAC meeting for later in 2023.





Adam Barrett MoF Attended
Andrew Fitzpatrick Canada Life Attended
Amy Stahlke Sun Life Attended
Brent Mizzen CLHIA Attended
Carol Allen FSRA Attended
Chris Caldarelli FSRA Attended
Colin Simpson Equitable Life Attended
David Sutton The Edge Benefits Attended
David Stewart Financial Horizons Group Replaced
Erica Hiemstra FSRA and TAC Chair Attended
Erin McKee Echelon Partners Attended
Nina Kavalinas Financial Horizons Group Attended
Huston Loke FSRA Attended
Heidi MacDonald Financial Horizons Group Attended
Isaac George MoF Attended
John Caldwell FSRA Attended
Jusleen Dhaliwal MoF Attended
Joel Gorlick FSRA Attended
Jason Harris FSRA Attended
John Lewsen FSRA Attended
Jelena Pejic FSRA Attended
Kirubel Abebe FSRA Attended
Kim Hayes Manulife Attended
Kevin Lim FSRA Attended
Kelly Picard FSRA Attended
Lucy Kang MoF Attended
Laura McLellan FSRA Attended
Monica Liang MoF Attended
Matthew Onyeaju Sun Life Replaced
Mari-Jayne Woodyatt BFG Financial Attended
Nathan Aranha FSRA Attended
Nathan Fahey MoF Attended
Nathan Tam FSRA Attended
Olivia Lee FSRA Attended
Paul Holba Empire Life Replaced
Patricia Ziegler Empire Life Attended
Rosemary Steffler FSRA Attended
Swati Agrawal FSRA Attended
Sohail Deen FSRA Attended
Stephen Hope FSRA Attended
Sean Sorensen Walker Sorensen LLP Attended
Sheldon Stier Stier Financial Advisors Attended
Serina Yau FSRA Attended
Tamara Brooks FSRA Attended
Terri Botosan Hub Financial Inc. Attended
Tim Miflin FSRA Attended
Teri Ryan Equitable Life Attended
Wendy Horrobin FSRA Attended