January 15, 2014
Ms. Jennifer Howard
Minister of Finance, Manitoba
103 Legislative Building
450 Broadway
Winnipeg, Manitoba R3C 0V8
RE: Meeting Request From Canadian Association of Financial Institutions In Insurance
Dear Minister:
Congratulations on your recent appointment as Minister of Finance.
As it has been some time since representatives of the Canadian Association of Financial Institutions in Insurance (CAFII) have met with officials from your Ministry and since we have not yet had the opportunity to meet you, we are writing to request a meeting in Winnipeg in February to discuss key initiatives and issues that CAFII is currently pursuing and their relevance to Manitoba consumers, policy-makers, and regulators.
Our topics for discussion (see attached Backgrounder for elaboration) would include:
- the vast under-served middle market of Canadians and alternate distribution of simple, accessible insurance products;
- electronic commerce;
- CAFII’s focus on plain language, consumer financial literacy, and consumer protection;
- interprovincial harmonization and multi-jurisdictional licensing; and
- legislative and regulatory developments in Manitoba and other jurisdictions. With respect to this topic, we would like to discuss
- insurance implications of the Agreement on Internal Trade;
- importance of Manitoba’s participation in the Canadian Council of Insurance Regulators (CCIR) and the Canadian Insurance Services Regulatory Organizations (CISRO);
- Manitoba’s updated Insurance Act which is harmonized with the other Western Canada provinces; and
- Manitoba’s draft Incidental Sellers of Insurance (ISI) Regulation, which will establish a corporate licensing regime governing the Creditor’s Group Insurance products that CAFII members offer.
With respect to the draft ISI Regulation being developed by the Superintendent of Insurance and the Insurance Council and now nearing finalization, CAFII has been in regular consultation discussions with Deputy Superintendent Scott Moore and has offered input and feedback based on our experience with the development of ISI regimes in Alberta and Saskatchewan. Our Association’s recent response submission to the second draft of Part 2, Restricted Insurance Agent Licences, of Manitoba's Insurance Agents and Adjusters Regulation is included with this letter for your information.
In our view, harmonization of provincial ISI regimes is imperative; and there is no compelling consumer protection reason for Manitoba to vary from the established, successful ISI regimes in other provinces, both of which appear to have found the right balance between consumer protection and business efficiency.
Despite our discussions, there are some proposals remaining in the second draft of Manitoba’s ISI Regulation that are outliers in comparison to the Alberta and Saskatchewan regimes. We would appreciate an opportunity to share our concerns, highlight the consequences of differing requirements across the Western Canada markets, and propose some potential solutions.
Therefore, Minister Howard, we would like to meet with you and/or another senior official from your Ministry to discuss our key initiatives and issues. Hopefully, Superintendent Jim Scalena and/or Deputy Superintendent Scott Moore would also be able to attend this meeting. A delegation of two to three CAFII representatives would be pleased to meet in Winnipeg, at a mutually convenient time in February. We’d appreciate it if your office could propose two or three possible meeting dates/times next month.
Thank you for your consideration of this request. To reply, please contact Brendan Wycks, our Executive Director, at brendan.wycks@cafii.com or 647-218-8243 at your earliest convenience.
Yours sincerely,
Moira Gill
Chair, Licensing Efficiency Issues Committee
c.c. Jim Hrichishen, Deputy Minister of Finance
Jim Scalena, Superintendent of Financial Institutions Regulations Branch
J. Scott Moore, Deputy Superintendent of Financial Institutions – Insurance