FSRA’s webinar on proposed Life and Health Managing General Agent (L&H MGA) Rule and proposed Fee Rule amendment (November 5, 2025)

0:01

Welcome to today's webinar, Fezra's webinar on Fezra's Proposed MGA Rule and Fee Rule Amendment.

0:09

Before we get started, I would like to go over a few items so you know how to participate in today's event.

0:15

You have the opportunity to submit text questions to today's presenters by typing your questions into the questions pane of the control panel.

0:23

You may send in your questions at any time during the presentation.

0:27

We will collect these and address them during the Q &A sessions at the end of each of today's presentations.

0:34

I would now like to introduce Tim Mifflin, Acting Director Policy Market Conduct. Tim?

0:41

Thank you Wendy. Good morning everybody.

0:43

Thank you for attending today's webinar on FISRA's public consultation on the revised Life and Health Managing General Agents rule and the proposed FISRA fee rule amendment.

0:54

My name is Tim Mifflin and I am the Acting Director of FISRA's Market Conduct Policy Branch and I will be your moderator for today's webinar.

1:04

I understand over 700 people have registered for today's webinar event.

1:08

It's great to see so much interest.

1:10

Thank you to everybody who's taken the time out of their days to join us.

1:16

Turning to the agenda, this morning we'll walk you through the key elements of two public consultations that we have underway.

1:25

Firstly, we'll walk you through the consultation on a revised proposed Life and Health MGA rule.

1:31

And secondly, we'll walk you through the proposed physical fee rule amendments.

1:37

If approved by the Minister of Finance and in conjunction with amendments to the Insurance Act, the rules would establish the licensing framework for Life and Health MGA's in Ontario.

1:48

We won't have time to cover all the detail proposed rules, but we hope today we'll provide you with a good understanding of the key changes we're proposing.

1:57

We'll also outline next steps, including how you can provide your comments and feedback with respect to the consultations, and we'll take a few minutes at the end to answer questions submitted either during the registration stage or during the webinar presentation.

2:14

But let's first begin with a land acknowledgement.

2:19

We acknowledge the land we're on is a traditional territory of many nations, including the Mississaugas of the Credit, the Anishnabeg, the Chippewa, the Hood and Orshanee, and the Wanda peoples, and is now home to many diverse First Nations, Inuit, and Métis peoples.

2:36

We acknowledge that Toronto is covered by Treaty 13 with the Mississaugas of the Credit, and the Williams Treaty signed with multiple Mississaugas and Chippewa bands.

2:51

For today's webinar, I'm very lucky to be joined by two with my colleagues, Yovanka McBean, who's director of licensing, and Andrea Foy, senior manager, licensing and title protection policy team.

3:06

Next slide, please.

3:11

Okay, so starting with a timeline overview.

3:14

The work on the two rules falls under one of FISRA's priorities for the 2025-26 fiscal year, and that is to strengthen the market conduct regulation and supervision of intermediaries, including MGA's.

3:28

As you may know, FISRA first published a proposed MGA rule for public consultation back in January this year.

3:35

Thank you to everyone that responded.

3:36

We received over 30 stakeholder submissions, letters, and comments, so thank you for those.

3:43

After careful consideration of the stakeholder feedback that we received, FISRA has released the revised rule for a second round of public consultation.

3:51

and this consultation, which is already open, runs until November 19th of this year.

3:59

At the same time, we are publicly consulting and propose amendments to the FISRA fee rule to support the new licensing framework for life and health MGA's.

4:08

And the consultation on the fee rule closes on December 19th of this year.

4:14

Looking ahead, and consistent with the Ontario Government's announcement included as part of the 2025 Ontario budget, The new licensing framework for Life and Health MGA is being targeted for implementation by June 1, 2026.

4:29

Therefore, June 1, 2026 is the date FISRA plans to begin accepting applications for new Life and Health MGA licenses.

4:40

Next slide please.

4:44

Okay, so we'll begin our walkthrough of the rules focusing on the revised Life and Health MGA rule.

4:51

Next slide please.

4:57

FISRA's revised MGA rule is intended to strengthen the oversight of MGA's and insurance agents and further protect consumers by helping to correct troubling practices identified by FISRA's supervision work in the sector.

5:12

This includes shortfalls and gaps relating to agent screening, training and monitoring.

5:18

The rule would require agents to be well-trained and properly supervised across the sector, which would help ensure consumers are treated fairly.

5:26

This slide shows and provides an overview of the core elements of the proposed regulatory framework for MGA's.

5:34

So working left to right, in the fall of 2024 the Government of Ontario introduced amendments to the Insurance Act that will create a separate licensing class for life and health MGA's in Ontario.

5:47

This legislation creates a number of core requirements for insurance companies and life and health MGA's.

5:54

It also gives FISRA the authority to build on what's included in the Insurance Act and create new requirements via a rule.

6:03

As you can see from this slide, the revised rule includes particular requirements, specific requirements relating to the licensing of MGA's, standards of practice and obligations focusing on the recruiting, screening, and training of agents, requirements, the need for compliance systems, and new obligations for agents.

6:26

We will walk through each of these key elements on this webinar.

6:32

Next slide, please.

6:37

Before we get into the detail, I'd like to take a moment to outline some of the key aims and outcomes that FISRA aims to achieve with the proposed rule.

6:49

Firstly, we want to make sure that requirements are clear and achievable, not just for large organisations but also for smaller businesses.

6:58

Second, we want to ensure the costs of compliance do not outweigh the consumer protection benefits.

7:04

We want to avoid as much as possible creating a disproportionate competitive advantage with other distribution channels.

7:10

And lastly, we intend to minimise potential for unintended market disruptions that could in issues relating to consumer access to advice and services.

7:23

Next slide, please.

7:29

Okay, let's turn our attention to the first of the key elements in the revised rule and spend some time focusing on who will be required to be licensed under the framework.

7:41

Next slide, please.

7:49

As mentioned earlier, the government of Ontario introduced amendments to the Insurance Act, creating a separate licensing class for life and health MGA's.

7:58

If an entity performs one or more of the regulated activities outlined in the slide, which is taken from Section 407.2 of the Insurance Act, that entity will be required to be licensed under the framework.

8:13

We encourage you, therefore, to review this list and consider whether you would need to obtain a license from FINSRA.

8:23

Next slide, please.

8:28

Now I'll spend some time on an important change made to the revised rule since the first consultation earlier this year.

8:37

Stakeholder feedback received during the first consultation included concerns that a one-size-fits-all approach could impose financial and operational burden, particularly on smaller and mid-size organisations.

8:50

In response to the comments, the revised rule induces three tiers for licensed MGA's with distinct obligations.

9:00

These tiers do not determine who needs to be licensed, there's only one type of license available for all life and health MGA's.

9:07

But the tiers do determine how the obligations in the rule would be applied.

9:12

For example, under the revised rule, higher obligations or requirements would apply to Tier 1 life MGA's.

9:22

And these are the MGA's that facilitate the sale of individual life insurance, recruit, screen, train or monitor agents, and perform these activities pursuant to an agreement with an insurer.

9:35

Tier 2 MGA's are similar, but do not operate pursuant to an agreement with an insurer.

9:39

This could include, for example, sub-MGAs.

9:43

And tier 3 MGA's are the MGA's that do not fall into tiers 1 and 2.

9:51

This approach of differentiating requirements aims to maintain strong consumer protection while minimizing unnecessary costs and administrative burden.

10:01

Now, as we go through the presentation, we will note how the requirements in the rule differ depending on the three tiers.

10:14

I will now pass over to Yvanka to walk us through the licensing requirements for MGAs.

10:22

Thank you, Tim.

10:24

So as part of the application for an MGA license, FISRA will be assessing an applicant's suitability and eligibility, including whether an applicant is suitable for a license, that is an applicant MGA, by looking at relevant factors.

10:39

For example, the MGA's past conduct, or whether the MGA has a designated compliance representative that meets the requirements outlined in the proposed rule.

10:50

This is something we'll come back to in the next slide.

10:54

Whether an applicant MGA has a compliance system reasonably designed to achieve the outcomes outlined in the revised rule, proof of insurance, and an Ontario mailing address for service by registered mail.

11:07

Regarding licensing expiry, the revised rule clarifies that each Life and Health MGA license will expire on either the date specified on the license or if no date is specified, two years from the date the license took effect.

11:22

Next slide, please.

11:27

As noted earlier, having a designated compliance representative, or DCR, is part of the eligibility requirements for an MGA license.

11:37

So, all tiers of MGA's will be required to have a designated compliance representative.

11:43

However, as you can see, the eligibility and duties associated with the designated compliance representative being proposed in the rule are different based on which tier the MGA falls under.

11:56

Tier 1 and Tier 2 MGA's share the same designated compliance representative eligibility criteria responsibilities, while Tier 3 MGA's have slightly different requirements.

12:10

For example, a DCR for a Tier 1 or Tier 2 MGA must have the knowledge to be able to perform their duties.

12:20

These duties include, but are not limited to, implementing, monitoring, and periodically updating the MGA's system.

12:29

Similarly, the revised rule requires tier one or tier two MGA's that no longer have a DCR to appoint a qualified replacement within five business days or, if not possible, designate a director or officer to assume the role temporarily. Next slide please.

12:52

So as briefly noted earlier, all life and health MGA's must maintain in an amount reasonable with regards to size, complexity, operations and risk profile of the Life and Health MGA, Sub-MGA and Associated Agents, both General Liability Insurance and Errors and Omission Insurance.

13:13

I'll now pass it back over to Tim and he'll speak about the standards of practice and obligations being proposed in the revised rule.

13:20

Thank you.

13:24

Thanks, Juvenka.

13:25

Next slide, please.

13:29

Fantastic.

13:32

So as Juvenka mentioned, in the following slides, I'll go over the standards of practice and obligations that apply to MGA's and insurers in relation to key agent-related activities, including recruiting, screening, and training.

13:47

But before we do that, we should summarize the circumstances under which responsibilities may or may not be delegated by insurers and MGA's. Next slide, please.

14:06

During the first consultation, we receive stakeholder feedback about the burden and inefficiencies that can be associated with duplication of activities between insurance companies and MGA's.

14:18

In response, PHISRA has amended the rule to further clarify expectations around the delegation of activities.

14:26

The revised rule maintains that insurance companies are accountable for maintaining reasonable compliant systems for overseeing agents throughout the distribution chain and it provides greater detailed clarity on the delegation of certain activities provided certain requirements and conditions have been met.

14:45

For example, an insurer is permitted to delegate certain agent-trained responsibilities to Tier 1 MGA's if the insurer has a system reasonably designed to ensure the Tier 1 MGA will properly handle those responsibilities.

15:01

At the same time, The revised rule prohibits certain responsibilities from being delegated down.

15:08

For example, MGA's cannot delegate any activities with respect to their compliance system responsibilities outlined in the revised rule.

15:17

The revised rule also clarifies that the entity delegating activities remains accountable for any responsibilities under applicable insurance law.

15:30

Next slide please.

15:34

Okay, so now we'll spend some time on the actual standards of practice and obligations.

15:41

The revised rule outlines updated standards of practice and obligations related to recruiting, screening, and training for both MGA's and insurers.

15:51

Next slide, please.

15:56

Let's start with a requirement applicable to insurers regarding a screening of agents and prospective agents.

16:05

Screening is a critical gatekeeping function that can directly affect consumer protection.

16:10

The revised rule requires insurers to maintain a system to assess each agent's suitability before authorizing them to act as an agent.

16:19

To avoid duplication of activities where both insurers and MGA's are performing this activity, the revised rule allows insurers to delegate screening to Tier 1 MGA's if the Tier 1 MGA as an adequate screening process in place.

16:35

It's worth noting that where insurers are sponsoring an agent application, the insurer cannot delegate this screening activity down to a tier one MGA.

16:46

Under the revised rule, insurers are also prohibited from delegating screening responsibilities to tier two and tier three MGA's.

16:56

Next slide, please.

17:02

So let's turn to insurer obligations in relation to training.

17:05

In relation to training, a revised rule requires insurers to develop clear, accurate, and non-misleading training materials covering product features, costs, terms, conditions, and exclusions.

17:20

They are required to provide training materials to all associated MGA's and agents, and to ensure agents receive complete training and understand products and applicable laws.

17:31

With respect to delegation activity, insurers cannot delegate the creation of training materials described above to any MGA and training activities to Tier 2 or Tier 3 MGA's.

17:46

Next slide please.

17:52

Okay, switching gears, let's talk about the standards of practices applicable to life and health MGA's.

17:59

The revised rule requires MGA's that recruit agents or prospective agents to sell individual insurance.

18:05

They must have a recruiting process in place to ensure those agents or prospective agents do not engage in any licensed activities unless they are licensed as an agent, authorized by an insurer, trained, and operates in compliance with applicable laws.

18:23

Next slide please.

18:29

Screening.

18:31

The revised rule places great obligations on MGA's to whom an insurer delegates activities relating to agent and prospective agent screening.

18:38

As such, Tier 1 and Tier 2 MGA's delegated with screening responsibilities must maintain a screening process and ensure agents have been assessed for suitability and that only properly assessed individuals are recommended to an insurer for sponsorship.

18:57

With respect to delegation of screening activities, the revised rule stipulates that screening may only be delegated to another Tier 2 or Tier 3 MGA if the delegated MGA can ensure compliance.

19:09

In order for the delegating MGA to ensure compliance, the revised rule requires all MGA's to provide information reports regarding the suitability of associated agents, prospective agents, to both insurers and other MGA's associated with them. Next slide please. Training.

19:34

With respect to the training requirements for MGA's, the revised rule requires Tier 1 MGA's that agents to have a process to ensure training is clear, accurate, and not misleading, that the insurer is notified of changes to its training materials, and agents understand the products they sell.

19:54

Similar to requirements that apply to screening I spoke about in the previous slides, training may only be delegated to another Tier 2 or Tier 3 MGA if the delegated MGA can ensure compliance.

20:06

Lastly, all MGA's must provide reports and share suitability information with the associated insurer upon request.

20:16

Next slide please.

20:21

The next key element of the proposed regulatory framework we want to cover is compliance systems.

20:29

Next slide please.

20:34

The compliance system requirement is applicable to both insurers and MGA's.

20:42

The revised rule builds on compliance system requirements included in the Insurance Act.

20:46

As we will see in the next few slides, these requirements can generally be categorized under the following key functions and activities.

20:55

Oversight of individual agents, oversight of MGA compliance, and oversight of delegated activities.

21:07

Next slide, please.

21:17

Starting with insurance companies' compliance systems as it relates to individual agent oversight.

21:23

The revised rule requires insurers to monitor associated agents to ensure they comply with all applicable insurance laws.

21:31

They are required to report uncedable agents to FISRA and to take appropriate corrective action.

21:38

The rule also requires insurers to monitor data related to agent conduct to detect patterns of non-compliance and promptly address any actual non-compliance that could result in consumer harm.

21:54

Next slide, please. So moving on from agent oversight, turning to MGA oversight.

22:04

As noted earlier, the revised rule requires insurers maintain a system reasonably designed to oversee the tier one MJs they are associated with.

22:14

This includes ensuring the tier one MJs comply with applicable insurance law.

22:20

The revised rule also requires the insurer to provide upon request tier 1 MGA's with necessary information reports to allow that tier 1 MGA to fulfill its own obligation to maintain a compliance system. Next slide please. Okay, delegation.

22:46

As mentioned previously, insurers may delegate certain duties to a tier 1 MGA. A good example of this is agent monitoring.

22:54

For this to take place, an insurer must be satisfied that the Tier 1 MGA's compliance system is reliable.

23:02

Insurers cannot delegate Agent 1 and engineering responsibilities to Tier 2 and Tier 3 MGA's.

23:07

Insurers cannot delegate oversight of their associated Tier 1 MGA's to another entity.

23:15

Lastly, Tier 1 MGA's are required to provide insurers with all information and reports necessary to support the insurer's compliance system.

23:26

Next slide, please.

23:33

Now let's turn to the compliance system requirements for MGA's.

23:38

Every Tier 1 MGA must maintain a compliance system that ensures the MGA remains in compliance and that the agents it oversees are also in compliance.

23:51

A Tier 1 MGA's compliance system must monitor and report to FISRA instances where there is reasonable evidence of unsuitable agents.

24:00

Similar to the requirement that applies to insurers, the Tier 1 MGA's compliance system must also monitor data to detect patterns of non-compliance, follow up on any concerning trends and properly address the identified non-compliance that could result in consumer harm.

24:22

Next slide, please.

24:28

Tier 2 and Tier 3 MGA oversight.

24:30

Tier 1 MGA's must ensure associated Tier 2 and Tier 3 MGA's comply with all applicable insurance laws, are monitored for suitability and reported to FISRA when found to be unsuitable.

24:45

The rule would require Tier 2 and Tier 3 MGA's to provide requested compliance information and reports to associated Tier 1 MGA's or insurers.

24:56

A point worth noting here is that a Tier 1 MGA cannot delegate its reporting duties as well as responsibilities related to agent monitoring.

25:08

Next slide, please.

25:14

Client continuity plans.

25:17

Another key element of the compliance system is a requirement to maintain a client continuity plan.

25:25

Insurers must have a plan to ensure clients continue to receive services from agents if tier 1 MGA can no longer provide these monitoring and screening activities.

25:37

The same requirement applies to tier 1 MGA's in the event that tier 2 MGA or tier 3 MGA associated with the tier 1 MGA is no longer able to provide this service.

25:52

Next slide please.

25:56

Okay, the fourth key element we wanted to cover relates to Asian obligations.

26:05

Next slide please.

26:11

The revised rule aligns that every agent or prospective agent cannot act as an agent unless they are licensed by FISRA, they have completed relevant training covered in the revised rule, and they are authorized by an insurer to sell the insurer's products.

26:28

Every agent associated with an MGA or insurer must also provide documentation related to the agent's suitability when requested.

26:45

The revised rule outlines reporting requirements which include but not limited to submitting an annual information return to FISRA and notifying FISRA of any changes in business or contact information, for example a mailing address.

27:14

Transition As mentioned previously, if approved by the entities would be able to begin applying for a Life and Health MGA license from June 1 of next year.

27:29

As part of the implementation, FISRA is proposing a 24-month transition period.

27:35

An important thing to note here, entities that meet the definition in the Act and currently operate in Ontario must submit an application by the license application deadline, which would be six months before the end of the transition period.

27:54

Next slide, please.

28:02

This slide, which I recognise is a busy slide, is aimed at providing a summary of how proposed standards obligations apply across the three tiers.

28:12

We have covered these points as part of the presentation, but I hope that this format and slide provides a useful summary and reference point for you to return to once the materials are published on the FISRA website.

28:24

but we hope it provides a good summary of the core elements, the key elements across the three different tiers.

28:33

I'll now pass you over to Andrea, who provides with the overview of the proposed fee structure.

28:38

Andrea.

28:41

Thank you, Tim.

28:42

Good morning, everyone.

28:44

The fee structure to support the Life and Health MGA licensing framework will be established through amendments to FISRA's existing fee rule, and will align with FISRA's functioning as an independent self-funded regulator.

28:59

And as with all its fees, in designing the fee structure, FISRA considers principles such as consistency, transparency, and fairness.

29:08

And as we move forward and in assigning fees to the sector, FISRA will take a measured approach, which will not only limit costs and spread them out over time, but also allow the sector time to mature and to incorporate new regulatory expectations into their business operations.

29:28

And you will see as part of the notice that accompanies the consultation on the fee rule amendment that we have included some cost estimates for the sector. Next slide, please.

29:44

At this time, FISWRIT does not have sufficient information to move forward with a complete fee structure.

29:50

And this information is critical to ensure that we design fees that are fair and reasonable.

29:56

So as a result, FISRA is taking a two-phased approach.

30:00

Phase one, which is what we are consulting on right now, is an amendment to the FISRA fee rule to introduce a licensing application fee that will come into effect June 1, 2026.

30:13

Phase two will be a subsequent amendment to the FISRA fee rule that will establish other fees, for example, a renewal fee, that will support the recovery of our startup and ongoing costs after the transition period.

30:29

And so this phased approach will allow FISRA time to gather the information that is necessary to develop a structure that is appropriate and to support the collection of this data, we have asked specific questions as part of the public consultation and your feedback will be important to the development of the work we're doing in phase two.

30:49

So, for example, we're asking questions like how many MGA's are out there, how might they be broken down by the proposed tiers, as well as what might be an appropriate way to allocate costs across the sector.

31:06

In assuming that we move forward with the two-year transition period, we do aim to communicate additional details on the fees under phase two in fiscal year 27-28.

31:16

Next slide, please.

31:22

And so, as we mentioned, FISR is currently consulting on phase one of the approach with the introduction of a licensing application fee of $1 ,000.

31:33

This is a non-refundable one-time payment at the time of the submission of an application, and it is specific to the work that will be done in reviewing the application.

31:43

So any fees that may be paid in the future, such as a renewal fee, those will be determined as part of phase two.

31:50

And in determining this $1 ,000, Pfizer did consider the fees that we charge in other sectors, as well as trying to balance cost recovery with what the sector may reasonably be able to afford.

32:05

And so I will hand it back to Tim to speak to the public consultation and next steps.

32:10

Thank you.

32:15

Thank you, Andrea.

32:19

Next steps.

32:20

If you could go to the next slide, please.

32:24

Thank you.

32:29

So, stakeholder feedback is an integral part of FISRA's rulemaking process.

32:33

It's so valuable as a policymaker.

32:35

It's so valuable to receive the comments and feedback from individuals like yourselves and across the sectors, across the insurance sector.

32:44

As a reminder, FISRA's second round of public consultation revised rule is currently open will close on November 19th of this year, and the consultation on the proposed fee rule amendments, which runs longer, will remain open until December 19th of this year.

33:03

After the consultation's end, visitors will take time to review the feedback and comments and consider finalising the rules for submission to the Minister of Finance.

33:15

Next slide, please.

33:23

This concludes the formal portion of today's presentation.

33:28

We'll now take some time to answer some of the questions that have been submitted to us.

33:32

I can see that a lot of the questions already come in via the chat, we'll take some of those, but also some of the questions that were submitted to us when you registered for this webinar event.

33:47

We won't be able to get through all the questions.

33:51

For the questions we were unable to address today, we will follow up with an email to attendees.

33:57

That includes a list of the questions, our responses, and will also include a recording of this webinar.

34:04

Please note that in cases where questions are similar, where we can group them together as themes, we may consolidate them and provide a single response.

34:18

Okay, so turning to the first question, which Ivanka asked you to pick up, please.

34:25

Will Corporate entities that are already licensed as insurance agents need to obtain an MGA license on top of the agent license they may already hope.

34:36

Thanks, Tim.

34:37

The short answer to that is yes.

34:40

We noted earlier in the presentation that section 407.2 of the Insurance Act requires all entities that perform one of the regulated activities outlined in that section to be licensed as an MGA.

34:54

So, if a corporate entity that is already licensed as an insurance agent with FISRA is, for example, engaged in the recruiting, screening, training, or monitoring of agents, this entity will also be required to obtain an MGA license in addition to their agent license.

35:13

So, the next question I understand is somewhat similar.

35:17

Yeah, that's actually good.

35:19

This relates to the DCR, the Designated Compliance Representative, and we read it to you.

35:24

My question relates to the need for an MGA to have a designated compliance representative.

35:29

Will the standard line in the rule be different for a big MGA versus a requirement for a small or boutique sized MGA?

35:39

Okay, well the short answer, the revised rule takes a proportionate approach to by introducing the three tiers of MGA's.

35:50

Accordingly, the standards for the designated compliance representatives differ across these tiers.

35:55

So as noted earlier, all MGA's will be required to have a designated compliance representative.

36:01

The revised rule provides greater clarity on the eligibility criteria and responsibilities of a DCR, which will vary depending on the MGA's tier.

36:10

For instance, DCR for a Tier 1 or a Tier 2 MGA must possess the appropriate knowledge experience, character, resources, and authority to effectively carry out the duties outlined in the revised rule.

36:24

For tier three MGA, any individual is eligible to act as a designated compliance representative unless there are reasonable grounds to believe they would be unable to carry out their duties.

36:36

So in other words, it's not the size of the MGA that determines how the standards apply to the DCR.

36:42

Rather, it's the MGA's tier that dictates what a DCR must demonstrate in terms of experience, compliance, and responsibilities.

36:53

Great. Thanks, Yvanka. Andrew, I'm going to ask you to pick up the next one. This is on fees.

37:01

Will the proposed $1 ,000 fee be payable upon renewal?

37:06

Thanks, Tim.

37:08

The $1 ,000 fee is an application fee, so it will be paid once at the time of an initial application.

37:17

So any renewal fees or other types of fees that may be implemented would be determined under phase two.

37:23

And we do want to look at different variables as we move forward with developments.

37:29

For example, the landscape of the sector, the size of the MGA, what kind of business models are out there. And as we mentioned, we don't have enough of that information to move forward.

37:39

And so we do encourage everyone to provide feedback through the open consultation to help us move with that phase two. Great, thanks.

37:51

The next question, why is the consultation on the fee rule longer than the consultation on the MJ rule, the call revised policy rule?

38:04

Okay, so under the FISRA Act, we're required to consult for 60 days when we first consult on a newly proposed rule, which is the case for the proposed amendment to the fee rule.

38:15

We are, of course, consulting for a second time on the revised MGA rule, the kind of core policy rule.

38:24

We do need to make sure that with that rule, we have sufficient time to review comments received from stakeholders, and that we have sufficient time to seek the statutory approvals needed ahead of the June 1, 2026 start date.

38:41

that's why the consultation period for that role is shorter.

38:48

Okay, those are questions we're going to be able to cover today.

38:55

So by way of concluding remarks, I'd like to thank you for taking the time to be with us today.

39:04

I'd like to remind you that today's webinar was recorded and the link will be provided to participants in the coming days.

39:11

As I mentioned, I know we haven't been able to get through all the questions submitted to us today.

39:16

We've just given you a sample of those, but we will be sending out responses to the questions received, both at the registrations stage and during the chat.

39:29

We aim to provide you an overview of both rules that we're consulting on.

39:33

I hope you found that useful.

39:35

I hope you found this session to be helpful.

39:38

Thank you again for joining and have a great rest of the day.

39:42

Thank you.