CLHIA Comments on FSCO's Draft 2015 Statement of Priorities

Date de parution : 06/08/2015
Personne(s)-ressource(s) : Leslie Byrnes

June 8, 2015

Mr. Brian Mills
CEO and Superintendent of Financial Services (Interim)
Financial Services Commission of Ontario
5160 Yonge Street
Box 85, 17th floor
Toronto, Ontario M2N 6L9

Dear Mr. Mills:

Re: Draft 2015 Statement of Priorities

The Canadian Life and Health Insurance Association appreciates the opportunity to comment on FSCO's Statement of Priorities for the coming year.

At the outset, we recognize that this is a period of dynamic change for FSCO and, indeed, for insurance regulators across the country, as a market conduct regulatory framework is developed that knits together and expands on existing practices to reflect the international standards established by the IAIS. For FSCO, this process also involves incorporating the recommendations set out in the December 2014 Auditor General's Annual Report.

We support the priorities identified in the Statement, and believe that they reflect the objective of the above projects -- to be a proactive, risk-based regulator, aligned with internationally recognized core principles.

We congratulate FSCO on the successful implementation of the Public Registry of Licensed Service Providers which was implemented Dec 2014 as part of the anti-fraud efforts for the Auto Insurance Industry. We appreciate FSCO's willingness to continue discussions on ways in which life and health insurers may be able to utilize this information as well to support the industry's anti-fraud efforts.

FSCO plays a significant role in the development of national initiatives, such as the work being done through the Canadian Council of Insurance Regulators in the development of a market conduct regulatory framework. The industry has already provided commentary on information collection and sharing so critical to keeping regulators informed in a risk-based environment, and looks forward to contributing to future consultations on this important project.

We are pleased to see FSCO's continued support to the Ministry of Finance on the implementation of Pooled Registered Pension Plans, and the regulations to support new legislative amendments that require long-term disability benefits to be paid under an insurance contract. Both of these initiatives will make a difference in the lives of Ontario workers.

One area where FSCO may wish to consider expanding its priority is with respect to financial literacy. The priority entitled "provide adequate disclosure of information to enable informed decisions by consumers and pension plan members" speaks more narrowly of distributing consumer protection and fraud prevention information, as well as providing enhanced information to pension plan members. We believe that improved financial literacy supports and complements market conduct regulatory objectives and that improving the knowledge and capacity of consumers to make informed decisions about financial matters should be a priority of industry and regulators alike.

Thank you for the opportunity to comment. We look forward to working constructively with FSCO over the coming year.


Original signed by

Frank Swedlove