Print Page   |   Contact Us   |   Sign In   |   Register


Draft 2020-21 FSRA Priorities and Budget – November 18, 2019

Our submission welcomes FSRA’s focus on innovation to increase competition and consumer choice. We offer our continued support and advice to FSRA – specifically in its work to create an efficient, effective online licensing platform, and in the development of an auto insurance data-and-analytics strategy.


Putting Drivers First - Amendments to regulations made under the Insurance Act and the Compulsory Automobile Insurance Act – November 12, 2019
Our submission welcomes recent amendments allowing Ontarians to carry electronic proof of insurance and asks the government to allow policy terminations to be communicated electronically.

Feedback on CISRO's GILQR June 2019 Stakeholder Meetings - August 23, 2019

Following a productive General Insurance Licensing Qualification Review Committee (GILQR) stakeholder meeting, we've developed a modified option for the committee's consideration. Our model features a common curriculum while allowing for the small amount of insurance content that varies across jurisdictions.


FICOM Insurance Fees Consultation Paper – July 24, 2019
Our submission calls for a fairer approach to fees for extra-provincial insurers, and assurances that the new fee structure will not result in cross-sector subsidization.


Consultation Paper: Licensing of Insurance Adjusters and Damage Appraisers in New Brunswick – June 27, 2019
As an advocate for companies that provide insurance to customers in multiple jurisdictions, we appreciate the proposals outlined by FCNB in this discussion paper to streamline and modernize NB’s licensing regime and align it with other Canadian jurisdictions.

FSRA Draft 2019-20 Priorities and Budget – February 7, 2019
We support FSRA’s proposed priorities for its first year of operation, and ask the regulator to review current market conduct measures before requiring new data from insurers.

Proposed FSRA Rule 2019-001 Assessments and Fees and 2019-001B Fees and Assessments (Interim) – January 4, 2019

Our comments on FSRA’s proposed rules for assessments and fees call for careful consideration of the financial pressures faced by direct relationship insurers. We look forward to FSRA’s support of streamlined regulation as we adapt to meet the challenges of new technologies and evolving customer expectations.


AMF draft regulation on alternative distribution methods - December 10, 2018

Our response supports AMF's draft regulations for insurers selling online, while calling for more clarity in some areas to reflect the realities of the customer experience.

CISRO General Insurance Licensing Qualification Review (GILQR) – August 31, 2018

Our submission calls for a review educational requirements for licensing to help move the industry towards a single set of licensing criteria and a single renewal for insurers who operate in multiple jurisdictions.

CISRO Strategic Plan 2019-2022 – August 30, 2018
We’ve asked CISRO to incorporate CADRI’s three strategic priorities of modernization, harmonization and engagement into its strategic plan – as we both face common multi-jurisdictional challenges of technological change, high customer expectations and new business models.

BC Financial Institutions Act & Credit Union Incorporation Act Review – June 25, 2018

We call for better representation of direct-relationship insurers on the Insurance Council of BC Board, and encourage BC to join with other jurisdictions to better coordinate and streamline licensing processes for agents.

CCIR/CISRO Guidance – Conduct of Insurance Business and Fair Treatment of Customers – June 18, 2018
By participating in joint work by CCIR and CISRO to create a national standard for fair treatment of customers, we continue to promote harmonization of insurers’ codes of conduct, policies and procedures.

FSCO draft Superintendent’s Guideline – May 8, 2018

Our comments on FSCO’s draft guideline include calls for harmonization with CCIR and alignment with the evolving operating environment to support our industry’s fair treatment of consumers.

FSCO Statement of Priorities – May 8, 2018
We are encouraged by the Financial Services Commission of Ontario’s draft Statement of Priorities, including its proactive approach to technological innovation and its transition to FSRA.

CCIR consultation on Conduct of Insurance Business and Fair Treatment of Customers – March 8, 2018

Our four recommendations aim to ensure CCIR guidelines are well-aligned, take account of existing legislation, provide clarity with regard to intermediaries, and reflect new technological developments.

Proposal to modernize Alberta’s insurance regulations – February 7, 2018
Our recommendations for regulatory changes would help insurers use new technologies to meet changing customer expectations for easier access and better information.


Proposed increase to Insurance Council of BC’s fee limits – September 29, 2017
Our recommendation that proposed fee increases for insurers, if necessary, should be implemented gradually over a number of years

Response to “Fair Benefits, Fairly Delivered” - September 6, 2017

Our comments welcome a simpler, more efficient auto insurance system as exists in other provinces

Proposal to amend Alberta Human Rights Act – August 31, 2017
Our recommendation that the proposal should include pricing exemptions allowing discounts based on age-related criteria, as in other provinces

Proposal to amend New Brunswick Insurance Act – August 14, 2017
Our comments on the proposal to ensure property insurance coverage for innocent co-insured when loss or damage occurs through an intentional or criminal act by another insured person or party

FSCO Statement of Priorities – May 31, 2017
Our comments on the Financial Services Commission of Ontario’s draft Statement of Priorities addressing fair treatment of consumers and ways to better enable innovation

CCIR Strategic Plan 2017-2020 – January 26, 2017
Our submission to the Canadian Council of Insurance Regulators (CCIR) on its new strategic plan with recommendations on modernization, harmonization and engagement to benefit consumers, regulators and industry


Direct Compensation Property Damage (DCPD) – December 9, 2016

Our feedback to Alberta Treasury Board endorsing the DCPD model for property damage as an option for Albertans

FSCO Statement of Priorities – May 31, 2016
Our comments on the Financial Services Commission of Ontario’s draft Statement of Priorities addressing harmonization of regulatory policies, improved market intelligence, awareness-raising and fraud prevention

CCIR issues paper: “Natural Catastrophes and personal property Insurance” – September 30, 2016
Our response to CCIR’s issues paper providing input the impact of natural catastrophes on the insurance marketplace, insurance coverage currently available and consumer understanding of the risks

Alberta Automobile Insurance Premiums Regulation Discussion Paper – August 30, 2016
Our responses to specific questions posed in the discussion paper by Alberta’s Treasury Board and Finance Department

CCIR Draft Annual Statement on Market Conduct – August 25, 2016
Our submission on ways to increase CCIR’s access to relevant data without placing undue administrative burdens on insurers

CCIR Electronic Proof of Automobile Insurance (EPIA) – June 29, 2016
Our comments on CCIR’s issues paper in which we support the acceptance of EPIA as a standard practice across Canada

Modernizing the New Brunswick Insurance Licensing Framework – January 22, 2016
Our comments on the New Brunswick Financial and Consumer Services Commission’s recommendations for a new licensing framework for agents and brokers


CCIR Harmonized Annual Statement on Market Conduct – December 14, 2015

Our submission to CCIR on achieving a focused and effective harmonized annual statement while protecting proprietary information

Alberta Treasury Board Stakeholder Dialogue on Insurance Council Regulation - November 2, 2015
Our letter to Alberta’s Treasury Board and Finance Department outlining concerns about supervision of insurers and the approach to providing proof of licensing

Earthquake Advisory Wording Consultation - October 30, 2015
Our response to the Insurance Bureau of Canada’s Earthquake Advisory Wording Consultation

FSCO Statement of Priorities – June 9, 2015
Our comments on the Financial Services Commission of Ontario’s draft Statement of Priorities, including discussion of a simplified system for rate filings for auto insurers

BC Financial Institutions Act - September 16, 2015
Our submission to the Government of British Columbia review of the Financial Institutions Act, including discussion of ways to improve consumer education and protection

FSCO mandate review – June 9, 2015
Our follow-up submission to the Expert Advisory Panel review of the mandate of the Financial Services Commission of Ontario providing additional discussion of new approaches to regulating the insurance industry

FSCO mandate review – May 27, 2015
Our initial submission to the Expert Advisory Panel review of the mandate of the Financial Services Commission of Ontario providing information about industry trends and discussion of a new approach to regulating the insurance industry

User Based Insurance Policy - January 30, 2015
Our comments on the Alberta Treasury Board’s draft notice for the Private Passenger Usage Based Insurance Implementation Process addressing concerns about additional administrative complexity


2014 Submissions

2013 Submissions


2012 Submissions


Membership Software Powered by YourMembership  ::  Legal