The Financial Services Regulatory Authority of Ontario (FSRA) is focused on protecting consumers and maintaining public confidence in the life and health insurance sector. Consumers should be confident that their licensed agents recommend suitable life and health insurance products with the coverage that they need.

Most individual life and health insurance policies in Ontario are sold through agents contracted with Managing General Agencies (MGAs). A life and health insurance MGA is an intermediary which is generally licensed as a life insurance agent and/or corporate or partnership agency to distribute life insurance. It generally has an agreement with insurance companies to find agents to sell the insurers’ products. Typically, insurers delegate compliance duties such as agent screening, training, and monitoring to their MGAs.

Since launching in 2019, FSRA has made MGAs a focus of its supervisory efforts. In its 2020-2023 Annual Business Plan, FSRA stated that it would develop a proposed regulatory framework and supervisory approach for distribution channels that rely on MGAs. This supported FSRA’s priority to enhance market conduct oversight to better protect consumers in the life and health insurance sector.

Read on for highlights of FSRA’s supervisory efforts and regulatory actions in this area.

Conducted thematic reviews

Review of Insurer-MGA relationship

Between September 2020 and March 2021, FSRA assessed the due diligence conducted by insurers in the key areas of agent screening, training, and monitoring delegated to MGAs. This evidence-based review identified gaps and a lack of clarity relating to the specific roles and responsibilities shared among insurers, MGAs, and independent agents. The review specifically found industry-wide, systemic issues related to insurer oversight of MGAs, the results of which were published in July 2021.

In the report, on the supervisory front, FSRA also committed to building its agent oversight capacity and continuing its risk-based supervision of the end-to-end distribution. This includes assessing particular MGA business models that could potentially result in negative consumer outcomes due to the activities of persons regulated by FSRA.

Review of three MGAs

Building on the commitment to assess particular MGA business models, between December 2021 and June 2022, FSRA led a joint Canadian Council of Insurance Regulators (CCIR) cooperative review of three MGAs that followed a tiered-recruitment business model (may also be referred to as a multi-level-marketing, network-marketing, recruitment-focused, or tiered-level model). The review observations include potential market conduct and consumer risks requiring additional action by FSRA. It is recognized that this business model is not the standard practice for all life and health MGAs.

As a follow-up to this initiative, FSRA:

  • is conducting a thematic review of selected life insurance agents licensed in Ontario and contracted with three MGAs: Experior Financial Group Inc., Greatway Financial Inc., and World Financial Group Insurance Agency of Canada Inc.
  • will develop an expanded supervisory plan and initiate a review of selected insurers that have a contract with the aforementioned MGAs in the fall of 2022, beginning with ivari and Industrial Alliance and Financial Services Inc. (Industrial Alliance)
    • ivari sponsored the most agents with two of the three reviewed MGAs
    • Industrial Alliance conducted the most business with the largest reviewed MGA during the most recent (2021) review period
  • will release draft interpretation Guidance for public consultation in the fall of 2022
  • plans to consult on a proposed Rule to enhance the MGA regulatory framework in 2023
  • will consider appropriate regulatory action

Sought expert insights

In 2020, FSRA established a Technical Advisory Committee (the Committee) to seek technical input and advice from industry experts on trends and issues related to MGAs. FSRA considers the Committee’s advice and recommendations when developing Guidance and approaches to regulating the insurance sector.

For example, the Committee was instrumental in verifying the observations of FSRA’s 2021 Insurer-MGA Relationship Thematic Review. Further, the Committee has informed FSRA’s initial work on a regulatory framework for distribution channels that rely on MGAs. FSRA will continue to engage the Committee and other stakeholders as the regulatory framework develops into the interpretation guidance and proposed Rule noted above.


FSRA will continue to enhance and execute on its regulatory framework and supervisory approach for insurers, MGAs, and agents. FSRA will work with the government on policy reforms, as necessary, and stakeholders to ensure that regulated entities better understand their obligations to treat customers fairly.

As part of the policy development process for enhancing the regulatory framework for MGAs, FSRA would engage a wide range of stakeholders, including its advisory committees and consumer advisory panel, consumer advocates, trade organizations, and other Canadian jurisdictions.

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FSRA continues to work on behalf of all stakeholders, including consumers, to ensure financial safety, fairness, and choice for everyone. 

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