CLHIA Responds to Nova Scotia Bill 19, An Act to Amend Consumer Protection Statutes

Date de parution : 11/30/2017
Personne(s)-ressource(s) : Brad Kuiper

November 30, 2017

Ms. Laura O’Hearn
Senior Policy Analyst, Deputy Registrar of Credit – Deputy Registrar of Mortgage Brokers
Business and Consumer Services
PO Box 1003
Halifax, NS
B3J 2X1

Dear Ms. O’Hearn:

The Canadian Life and Health Insurance Association (CLHIA) is pleased to comment on the Mortgage Regulation Act (MRA) amendments.

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. During 2016 in Nova Scotia, life and health insurers made benefit payments of $1.7 billion, or roughly $33 million a week, to policyholders and beneficiaries. As well, and of particular note for this consultation, the life insurance industry has been providing residential mortgages for over 100 years, with current holdings valued at $3.1 billion across the country and $87 million in Nova Scotia.

In our 2013 submission, we recommended that insurance companies be added to the list of entities that are exempt from the Regulations. We appreciate that the 2017 draft Regulations reflect this recommendation under Section 3(d). However, we are concerned that, as drafted, Section 3(d) may not capture all insurance companies, specifically provincially incorporated insurers. We would respectfully request that the wording be revised along the following lines to accommodate both provincially and federally incorporated insurers.

“Persons exempt from Act
1. For the purposes of subsection 3(1) of the Act, all of the following are exempted from the Act:

(d) “a company as defined in the Insurance Companies Act (Canada) or licensed under the Insurance Act.”
(f) ”

Thank you for the opportunity to comment on the MRA amendments. If you require additional information or wish to discuss further, please contact me at or 416-359-2011.

Original signed by
Brad Kuiper
Director, Marketplace Regulation