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CLHIA Comments on FSCO's Draft 2014 Statement of Priorities


Release Date: 05/29/2014
Staff Reference: Leslie Byrnes

May 29, 2014

Mr. Philip Howell
CEO and Superintendent of Financial Services
Financial Services Commission of Ontario
5160 Yonge Street
Box 85, 17th floor
Toronto, Ontario M2N 6L9

Dear Mr. Howell:

Re: Draft 2014 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 would like to commend FSCO on the results of its 2013 FSAP review that found that it had a high level of observance with international Insurance Core Principles. We would also concur with the comments of Canadian insurance regulators that it is important to take a balanced approach when applying international standards.

We support the priorities identified in the Statement, and appreciate the risk-based approach that Ontario continues to take to regulation.
We are pleased to see priority given to working with the Ministry of Finance on implementing Pooled Registered Pension Plans, and working with CAPSA to coordinate PRPP regulations. PRPPs provide a viable and low-cost workplace retirement solution for Ontario workers and small businesses, and we stand ready to support your efforts in any way we can.

FSCO's mandate has recently been expanded to include licensing healthcare service providers in an effort to tackle fraud in the auto insurance sector. CLHIA supports this activity as licensing of service providers is important to us and will also benefit life and health insurers in their anti-fraud efforts. We also appreciate the regular progress updates in this area provided to us by FSCO, which has allowed the opportunity to continue discussions on ways in which life and health insurers can access and utilize this information for anti-fraud purposes.

With respect to active coordination with CCIR and CISRO to develop a harmonized national life agent licence qualification standard, we urge FSCO to ensure that the basic objectives of this program are met without undue unintended consequences.
And finally, like FSCO, CLHIA is deeply committed to financial literacy efforts and we are glad to see a new priority added to promote consumer access to financial literacy information.

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

Sincerely,

Original signed by

Frank Swedlove