CLHIA comments re: Manitoba's Proposed Framework for a Restricted Licensing Regime

Date de parution : 07/05/2013
Personne(s)-ressource(s) : Erica M Hiemstra; Frank Zinatelli

July 5, 2013

Scott Moore
Deputy Superintendent of Financial Institutions - Insurance
Manitoba Finance
Financial Institutions Regulation Branch
1115-405 Broadway
Winnipeg, MB R3C 3L6

Dear Mr. Moore,

The Canadian Life and Health Insurance Association Inc. (CLHIA) is pleased to provide comments (attached) in response to your June 3, 2013 letter, in which the proposed framework for a restricted licensing regime in Manitoba to be implemented by amending the existing Insurance Agent and Adjusters Regulation.

Our comments include specific feedback regarding the draft amendments to the Regulation and some points on a few broad-based issues, which are summarized below.

    · We strongly support Manitoba's efforts to harmonize with the restricted licensing regimes in Saskatchewan and Alberta. Indeed, as you will see in our comments, we support even further harmonization. In some cases, where the approaches in Saskatchewan and Alberta differ, we recommend one approach over the other based on our practical experience with both regimes.

    · The linking of the proposed restricted licensing regime with incidental sellers of insurance as defined in The Insurance Amendment Act appears to introduce a possible limitation on what is covered by the proposed regime. It seems to exclude insurance coverage that is not purchased incidental to the sale of a product or service.

    · We offer some suggestions for clarifying and streamlining the prohibition against tied-selling, which is an important consumer protection measure.
      · We understand that the proposed amendments to the Regulation will be implemented at the same time as the "Bill 27" amendments to The Insurance Act and amendments to Manitoba's Classes of Insurance Regulation that will adopt the classes of insurance endorsed by the Canadian Council of Insurance
    We very much appreciate the opportunity to provide input into this process and would be pleased to discuss any of our comments further at your convenience. In this regard, please feel free to contact me or my colleagues, Erica Hiemstra (Director, Distribution and Consumer Affairs, 416-359-2013, or Jodi Skeates (Senior Counsel, 416-350-2015,

    Your very truly,

    (Original signed by)

    Frank Zinatelli
    Vice President and General Counsel