CLHIA's further comments on the Life Insurance Agent Market Conduct QuestionnaireRelease Date: 10/16/2017 Staff Reference: Brad Kuiper
October 16, 2017
Ms. Swati Agrawal
Manager, Market Conduct Compliance Unit - Financial Services Commission of Ontario
5160 Yonge Street, P.O. Box 65
Toronto, ON M2N 6L9
Dear Ms. Agrawal,
The CLHIA has identified a few comments on the Life Insurance Agent Market Conduct Questionnaire missed in our original submission. We believe these comments may be of value to FSCO and have summarized them below.
Section 1: CURRENT INFORMATION
BACKGROUND DETAILS - Without further direction, we are unsure if you will get consistent responses to "Years of relevant experience".
OTHER BUSINESS ACTIVITY - Consider changing the “Other” checkbox to “Other licensed activity”.
Proportion of 2016 Sales - Consider providing guidance on this column. For example, the percentage breakdown might be based on number of policies sold or commissions earned.
Section 2: DISTRIBUTION CHANNEL
4) We suggest rewording the National Account Agent description to "iii) Has a contract with an insurance affiliate of an investment dealer..." as life agents would not have an insurance contract with an investment dealer.
6) For consistency, consider changing chart b) to "Average Amount Invested...”
Section 3: MORTGAGE ACTIVITY - We suggest revising questions b) and b) b) along the following lines to accommodate compensation other than fees:
b) “Do you receive a fee or other benefits for referring clients...", and b) b) “If Yes, estimate the total value of referral fees or other benefits received..."
Section 4: DOCUMENTS ATTACHED - First Check Box - We suggest revising the text as only the agent can file a claim against their errors and omissions policy. "I have made a claim against my E&O policy within the last five years, for my activity as a licensed agent in Ontario."
Please accept my sincere apology for not including these points in our original letter. Thank you, once again, for the opportunity to provide comments on the Questionnaire.