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Submissions

2020


Insurance Council of BC Continuing Education Guidelines – Program for General Insurance Agents and Salespersons – July 31, 2020

Our comments welcome proposed changes, which will more closely align requirements with other jurisdictions and simplify the task of supervisors.


FSRA Loss Trend Benchmarks for Private Passenger Automobile Major Rate Filings – July 27, 2020

Our submission asks FSRA to acknowledge that our members’ loss experience may vary from the regulator’s benchmark projections. We argue that flexible pricing models support and encourage an innovative and responsive marketplace.


FSRA Consultation: Auto Insurance Take-All-Comers Rule – June 5, 2020

Our submission looks at how Ontario’s current regulatory environment creates obstacles to a truly competitive marketplace. We suggest solutions to reduce cross-subsidization and improve fairness for customers.


FSRA Innovative Auto Insurance Products-Subscriptions (IAIP-S) – March 31, 2020

Our submission acknowledges FSRA’s responsiveness in creating a new regulatory approach for subscription-based auto insurance. We suggest less detail may need to be provided about the relationships between insurers and mobility companies.

Alberta Automobile Insurance Advisory Committee – March 9, 2020

Our submission seeks a principle-based, outcome-focused regulatory environment that provides motorists with competitive choice and affordable options.

FCNB Consultation Paper – Incidental Selling of Insurance, Restricted Insurance Licensing Regime – January 28, 2020

Our submission addresses the definition of incidental selling, the risks of allowing dealerships to offer replacement cost insurance on new vehicles, and practicality for designated representatives.

2019

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.


2018

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.


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