Our submission supports FSRA’s proposal to adopt the CISRO’s Principles of Conduct for Insurance Intermediaries, which reflects common regulator standards for insurance intermediaries in Canada.
Our submission urges FSRA to focus on reducing the regulatory burden on insurers by adding efficiency to its six principles in its proposed principle-based regulatory framework. We tell FSRA that we look forward to providing feedback on detailed rules and prescriptive requirements in the framework, as well as FSRA’s transition roadmap.
Our submission supports the Insurance Council of BC’s proposed guidelines and suggests improvements to reduce the administrative burden on insurers. Suggested changes relate to notice of salesperson departures and inspection of virtual offices.
FSRA 2021-023 – Proposed Guidance for Operational Risk Management (ORM) Framework & 2021-021 – Proposed Guidance for Reporting & Resolution of Auto Insurance Rating & Underwriting Errors - February 28, 2022
Our submission suggests ways that FSRA can better harmonize its ORM guidance with other jurisdictions. We also propose some more practical approaches to guidance for reporting and resolution of errors.
While noting the significant increase proposed, our submission recognizes that FCNB’s standard fee for resident and non-resident agents brings it in line with other jurisdictions. It also asks FCNB to consider setting a cap on recoverable expenses.
Insurance Council of Manitoba Notice of Consultation – Potential change to Manitoba’s General Insurance Licensing Rules – February 10, 2022
Our submission asks the Council for rule revisions to support agents working remotely in Manitoba. It explains how supervisory conditions are met in virtual offices and calls for a more principles-based approach to future regulation.
Our submission thanks FCNB for eliminating the requirement for Level 1 agents to work in a specified location. It also asks FCNB to look at revising some requirements to allow insurers to innovate and reduce administrative burdens.