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CLHIA's comments on the preliminary policy recommendations of the Expert Committee


Release Date: 06/06/2016
Source: Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives
Staff Reference: Peter Goldthorpe

June 6, 2016

Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives
c/o Frost Building North, Room 458
4th Floor, 95 Grosvenor Street
Toronto, Ontario
M7A 1Z1

Expert Committee:

The Canadian Life and Health Insurance Association (CLHIA) is pleased to provide comments on the Expert Committee's preliminary policy recommendations as set out in Financial Advisory and Financial Planning Policy Alternatives.

Established in 1894, CLHIA is a voluntary trade association that represents the collective interests of its member life and health insurers which, together, account for 99% of the life and health insurance in force in Canada. Our members contribute to the financial well-being of millions of Canadians by providing a wide range of financial security products, including almost $4.2 trillion of life insurance coverage. During 2014 in Ontario, life and health insurers made benefit payments of $40.3 billion, or roughly $775 million a week, to policyholders and beneficiaries. The industry has 67 head offices in Ontario, employs approximately 69,100 people, and invests over $265 billion in the provincial economy.

In a letter dated July 27, 2015 CLHIA provided comments on the Expert Committee's initial consultation. Throughout this letter, "initial response" refers to that letter.

In our initial response, we suggested that fundamental change to the existing regulatory framework for financial services is not required and that it is more appropriate to address existing gaps in a more targeted regulatory approach. We are pleased that the Expert Committee agrees with this approach and is recommending more targeted regulation to address issues it has identified.

We believe the Expert Committee's specific recommendations, taken as a whole, reinforce the distinction between financial planning and financial advising that we made in our initial response. As discussed below, we believe the best way to reinforce this distinction is to focus on regulating those who hold themselves out as financial planners.