CLHIA comments re: Manitoba's Proposed Framework for a Restricted Licensing RegimeRelease Date: 07/05/2013 Staff Reference: Erica M Hiemstra; Frank Zinatelli
July 5, 2013
Deputy Superintendent of Financial Institutions - Insurance
Financial Institutions Regulation Branch
Winnipeg, MB R3C 3L6
Dear Mr. Moore,
The Canadian Life and Health Insurance Association Inc. (CLHIA) is pleased to provide comments (attached) in response to your June 3, 2013 letter, in which the proposed framework for a restricted licensing regime in Manitoba to be implemented by amending the existing Insurance Agent and Adjusters Regulation.
Our comments include specific feedback regarding the draft amendments to the Regulation and some points on a few broad-based issues, which are summarized below.
- · We strongly support Manitoba's efforts to harmonize with the restricted licensing regimes in Saskatchewan and Alberta. Indeed, as you will see in our comments, we support even further harmonization. In some cases, where the approaches in Saskatchewan and Alberta differ, we recommend one approach over the other based on our practical experience with both regimes.
· The linking of the proposed restricted licensing regime with incidental sellers of insurance as defined in The Insurance Amendment Act appears to introduce a possible limitation on what is covered by the proposed regime. It seems to exclude insurance coverage that is not purchased incidental to the sale of a product or service.
· We offer some suggestions for clarifying and streamlining the prohibition against tied-selling, which is an important consumer protection measure.
Your very truly,
(Original signed by)
Vice President and General Counsel