Comments to OSFI Regarding Draft Advisory on Changes to the Membership of the Board and Senior Management

Date de parution : 02/28/2014
Personne(s)-ressource(s) : Ethan Kohn

February 28, 2014

Mr. Philipe Sarrazin
Managing Director, Legislation and Policy Initiatives
Office of the Superintendent of Financial Institutions
255 Albert Street
Ottawa, Ontario
K1A 0H2

Dear Mr. Sarrazin:

Changes to the Membership of the Board and Senior Management

The CLHIA welcomes the opportunity to provide comments on the January 20, 2014 draft Advisory on Changes to the Membership of the Board and Senior Management. We appreciate the importance of appointing qualified candidates to the board of directors and senior management of federally regulated life insurance companies and fraternal benefit societies and, therefore, the need for the final Advisory to be workable for both insurers and fraternals, and for OSFI.

Established in 1894, the Canadian Life and Health Insurance Association (CLHIA) is a voluntary trade association that represents companies which together account for 99 per cent of Canada's life and health insurance business. The industry, which provides employment to more than 142,000 Canadians and has investments in Canada of about $615 billion, protects about 27 million Canadians through products such as life insurance, annuities, RRSPs, disability insurance and supplementary health plans. It pays benefits of over $66 billion a year to Canadians and manages about two-thirds of Canada's private pension plans.

Our initial review of the draft Advisory gave us pause because, as currently written, it would create important implementation issues for member companies. Subsequently, having had the opportunity to discuss with you how OSFI intends to operationalize the new guidance, and having received your clarifying e-mail dated February 14, 2014, we find that many of the questions that we had on the draft Advisory have been answered...