Expert Advisory Panel – FSCO/FST/DICO Mandate Reviews
Ministry of Finance
Financial Institutions Policy Branch & Income Security & Pension Policy Division
Frost Building North, Room 424
95 Grosvenor Street, 4th Floor
Toronto, Ontario M7A 1Z1
Email: fipbmandatereview@ontario.ca
Dear Messrs. Cooke, Daw, and Ritchie:
On behalf our Chair, Peter McCarthy, I am writing to thank you for providing CAFII with the opportunity to participate in the Panel’s July 30 roundtable meeting regarding the FSCO/FST/DICO Reviews.
As we indicated in our original submission of June 5, 2015, CAFII believes that FSCO’s regulatory framework should continue to be principles-based and foster an open marketplace where consumers are able to choose how and where to purchase insurance coverage, whether that be through traditional sales channels or alternate channels such as Branches, Call Centres, online, or mobile devices. Regarding the creation of an Insurance Council, should such a body be created, it should be “channel neutral” so that representatives of any one channel are not in a position to negatively affect a competing channel(s). CAFII also feels that the current approach to regulation of Authorized Insurance Products is working well and consumers are well-protected by our members’ compliance with the CBA Code of Conduct for Authorized Insurance Activities, FCAC oversight, and compliance with relevant CLHIA Guidelines.
We would also like to reiterate our strong support for FSCO’s participation in national co-ordinating bodies such as the Canadian Council of Insurance Regulators (CCIR) and the Council of Insurance Regulatory Organizations (CISRO). CAFII works closely with both organizations and has found them to be very effective in sharing knowledge and best practices, and encouraging harmonization of regulations across the country. This results in strong consumer protection and makes it more efficient for our members to conduct business and that ultimately provides consumers with better access to the valuable products our members provide.
By way of example, the CCIR conducted a comprehensive consultation on Electronic Commerce in Insurance Products and provincial jurisdictions are now aligning with CCIR’s recommendations when making changes to their regulatory frameworks for insurance e-commerce. On the CISRO front, CAFII has participated in consultations regarding modernizing the Life Licence Qualification Program (LLQP) and CISRO members are now in the final stages of implementing a new, nationally harmonized LLQP for January 1, 2016.
It is critical that FSCO continue to play a significant leadership role at a national level with these organizations.
Thank you for considering the views of CAFII members. We look forward to the release of your upcoming Position Paper and to providing our Association’s views on its proposals.
Should you require further information from CAFII or wish to meet with representatives of our Association, please contact our Executive Director, Brendan Wycks, at brendan.wycks@cafii.com or 647-218-8243.
Sincerely,
Greg Grant, MBA, FLMI, ACS
Board Secretary and Chair, Executive Operations Committee
Canadian Association of Financial Institutions in Insurance
c.c. David McLean, Policy Advisor, Financial Institutions Policy Branch, Ontario Ministry of Finance