Comments Received
2019-001: Assessments and Fees


Type: Rule
Number: 2019-001
Date: 2019-03-08
Comments Due: 2019-02-25
Sector: All sectors
Status: With Minister for review

Comments Received

DateCommentsSector
2019-02-25 [2019-001] Tracey Primmer - Travelers Canada

Please find attached the comments of Travelers Canada. Thank you.

Insurance
2019-02-25 [2019-001] Intact Insurance

Please see attached.

Insurance
2019-02-25 [2019-001] Eric de Roos - Canadian Credit Union Association

Credit unions and caisses populaires
2019-02-21 [2019-001] Kim Donaldson - Insurance Bureau of Canada

Please find attached our comments of the Revised FSRA Fee Rule consultation.

Thank you,

Kim

Insurance
2019-02-20 [2019-001] Erika Kuehnel

Ever increasing administrative fees for sole provider healthcare operations and small clinics may act as a barrier to quality, evidence informed patient care. Increased financial/administrative requirements discourage smaller providers from providing treatment to motor vehicle injury claimants, resulting in patients with established relationships with capable providers moving to providers do not know the patient's history, preferences or goals. This makes care more costly/less efficient. It offers an incentive to large/chain clinics, that may offer less personalized care, and promotes a protracted course of recovery. This is counter to current measures under the Ontario government in recent years to deliver the "right care to the right patient at the right time".

Health Service Provider
2019-02-13 [2019-001] Trina Ting

Chiropractors who treat fewer than 6 MVA patients per year should be excluded from the annual fee

Health Service Provider
2019-02-05 [2019-001] Janet Grantham - Mainstreet Credit Union

I support taking a transitional year to implement the risk weighted approach to fee assessment this is regardless of the fact that there will be a small cost to my credit union.

Credit unions and caisses populaires
2019-01-04 [2019-001] Brendan Wycks - CAFII

Insurance
2019-01-04 [2019-001] Brendan Wycks - CAFII

Insurance
2019-01-04 [2019-001] Ric Marrero - ACPM

Pension Plan
2019-01-04 [2019-001] Eli Dadouch - Firm Capital Corporation

Myself and Firm Capital have been licensed since early 1988. The vast majority of these changes are not helpful to the industry and do not address the issue. We need a two tier system, one for Mortgage Bankers and the current system for Mortgage Brokers. The current system does not recognize the Non-Bank Mortgage Banker. These proposed changes will create a lack of capital flowing to the consumer borrower. As seen in the early 1990’s a lack of capital has a long term affect on real estate values. (1) keep the 2 year licensing cycle, no consumer benefit is achieved by changing to a 1 year cycle - only additional administration cost to the Brokerage; (2) The $200 non-qualified syndicated fee is an un-fair “penalty” for complying with the Act. The $200, 5 day payment requirement is a further “red-tape” administration problem. Do not penalize the industry for those that lacked judgement in addressing suitability for investors. A different set of rules need to be applied to a proper non-bank lending entity, such as a publicly listed MIC with an independent board of directors, not a $200 penalty for complying with the Act. Consult with those that actually cover this sector, not the general brokerage industry, who act as brokers to lenders. These changes are harmful to the consumer and educated investors and not protective in any manner.

Mortgage brokerage
2019-01-04 [2019-001] Denis Dubois - Desjardins General Insurance Group

Please find attached DGIG’s response to your request for comment on the proposed rule regarding FSRA assessments and fees.

Insurance
2019-01-04 [2019-001] Paul Taylor - Mortgage Professionals Canada

Please see attached for comments from Mortgage Professionals Canada. Thank you.

Mortgage brokerage
2019-01-04 [2019-001] Eric de Roos - Canadian Credit Union Association

Credit unions and caisses populaires
2019-01-04 [2019-001] Jim Elson - Ontario Bar Association

Please find attached a submission from the Ontario Bar Association

All sectors
2019-01-04 [2019-001] Jim Keohane - Healthcare of Ontario Pension Plan

See attached January 4, 2019 letter submitted on behalf of Healthcare of Ontario Pension Plan.

Pension Plan
2019-01-03 [2019-001] Catherine Allman - Ms.

Please find attached comments from the Canadian Association of Direct Relationship Insurers (CADRI) to FSRA Proposed Rules 19-001 and 19-001B.

Insurance
2019-01-03 [2019-001] Intact Insurance

Insurance
2019-01-03 [2019-001] Erica Kelsey - Aviva Canada

Insurance
2019-01-03 [2019-001] Rhonda Choja - Libro Credit Union

Please find attached Libro Credit Union's submission for both fee rule 001 and 001B. We thank you for the opportunity to respond and look forward to continued collaboration with regards to the fee rule and ongoing relationship between Libro and the FSRA.

Regards.
Rhonda Choja
VP Corporate and Advisory Services
Libro Credit Union

Credit unions and caisses populaires
2019-01-02 [2019-001] Virginia Nsitem

There is so much time and effort into completing forms, and often documents are rejected for simple errors, causing more time and administrative hours to correct. Payments are always delayed. In addition, we have addes administrative costs associated with processing extended health coverage. Any increase in fees does not appear to be justified as there does not seem to be any benefit to the provider.

Health Service Provider
2019-01-02 [2019-001] Evan Cooperman - Foremost Financial Corporation

Please see attached for our comments.

Mortgage brokerage
2019-01-02 [2019-001] Peter Shena - Ontario Pension Board

Please see the attached letter.

All sectors
2018-12-31 [2019-001] David Mandel - First Source Mortgage Corporation

See attached as it relates to Private Lending and Non-Qualified Syndicated Mortgages. The perpetuation of a big miss by regulators as proposed.

Mortgage brokerage
2018-12-28 [2019-001] William Jones - Canadian Federation of Pensioners

Please find attached the comments of the Canadian Federation of Pensioners to Consultation 2019-001: Assessments and Fees.

William Jones
Director, Canadian Federation of Pensioners

Pension Plan
2018-12-27 [2019-001] Ontario Teachers' Pension Plan

Please find enclosed the Ontario Teachers' Pension Plan's comments on Proposed Financial Services Regulatory Authority of Ontario Rules 2019-001 & 2019-001B.

Pension Plan
2018-12-20 [2019-001] Canadian Life and Health Insurance Association

Please find comments from the CLHIA attached. Thank you for the opportunity to provide input.

Insurance
2018-12-21 [2019-001] The Co-operators

Insurance
2018-12-21 [2019-001] Independent Financial Brokers of Canada

Insurance
2018-12-21 [2019-001] Your Neighbourhood Credit Union

Credit unions and caisses populaires
2018-12-20 [2019-001] CAAT Pension Plan

The CAAT Pension Plan welcomes the opportunity to comment on FSRA's Assessments and Fees consultation. Attached you may find our submission.

Pension Plan
2018-12-20 [2019-001] Insurance Bureau of Canada

Insurance
2018-12-20 [2019-001] Canadian Association of Independent Life Brokerage Agencies

Insurance
2018-12-14 [2019-001] OMERS _

Pension Plan
2018-12-11 [2019-001] Ontario Rehab Alliance

The Ontario Rehab Alliance (ORA) is very encouraged by the level of consultation, openness and transparency that FSRA has demonstrated to date. However, following consultation with our members we believe that most licensed HSPs are unable to absorb and accept the proposed fee increase without an undertaking to bring about a comparable increase to HSP rates, evaluate the demonstrable value and effectiveness (in reducing fraud) of licensing and provide more insight into licensing-related activities and costs.

The ORA strongly supports the philosophy underlying the proposed exemption of HSPs with few claimants annually. Namely, the retention and recruitment of licensed providers serving smaller more remote communities. However, we are surprised by the larger than anticipated size of the proposed group of HSPs with 6 or fewer claimants annually, the impact on the regulator’s fee revenues and the corresponding impact of increased fees for non-exempted HSPs. We would like to know more about the composition of the proposed exempted group to better inform our position on exemption, namely:

• The geographic distribution of exempted HSPs
• The breakdown of treating vs IE providers in this group

Health Service Provider
2018-12-10 [2019-001] Patricia Fleet

Why the increase in fees to practice through HCAI (which is mandatory) when there is no increase in fees to service MVA clients? And there has been no increase in the fees to service clients since 2014?

Health Service Provider
2018-12-06 [2019-001] Anjelika Alechina

The proposed fee increases of the location and claimant annual fees are unreasonable. Health Service providers with twelve (12) or fewer claimants per year should not have to pay an annual fee, averaging one claimant per month.

Health Service Provider
2018-12-04 [2019-001] Shannon McGrath - ModernOT

FSCO and FSRA add a considerable cost to our operations, both financially and administratively. As a result of the current processes, we have had to add tens of thousands of dollars in costs for administrative support and electronic software to implement this heavily regulated system. As a result, we see that many specialists, psychologists, physiotherapists in Ottawa and Kingston will no longer see clients who were involved in motor vehicle accidents, and as occupational therapists we are considering the same. The professional fee guidelines have not been increased for many years, and the loss of the ability to recuperate mileage when servicing rural communities has reduced services for Ontarians outside of major city centres. The most qualified, experienced senior health care professionals will be the first to say that they no longer see car accident victims because it is too much extra paperwork, administration and with lower rate of pay.

I am concerned that the fee structures and processes that are added administratively will take the most qualified professionals away from the Ontarians who sustain serious injuries and are in need of complex care that their insurance is supposed to provide. I would like to see less administration, allowing our professional Colleges to regulate our practices as they always have, and a review of the Professional Fees Guidelines.

All sectors
2018-12-03 [2019-001] Marie Hren - Neuro-Rehab Services Inc.

I disagree with the increase of fees to clinics, wherein clinics must bear the financial burden for sole providers. Speaking from experience, I don't believe that clinics have a higher profit margin that do sole providers - because of overhead costs, many clinics likely have far lower profits than do sole providers.

Health Service Provider
2018-12-03 [2019-001] Lisa McGowan

I find that the fees are already very high and tax my sole practitioner practice greatly. I passed my audit and work hard to ensure I follow all of the regulations. If the cost keeps increasing I won’t be able to continue to provide service and I live outside of a major city and there are few providers in this area.

Health Service Provider
2018-12-03 [2019-001] Samantha Glowinski

As an OT, I am regulated by COTO and FSCO, dual licensing that is not supported. COTO regulates my clinical and business practises. FSCO therefore adds a second and unnecessary level of oversight. Increasing fees for regulated health professionals is not supported and as we have not had a raise since 2014, regulatory fees should be reduced or eliminated.

Health Service Provider
2018-11-16 [2019-001] JR Nieuwland

We have not had a fee increase for years yet you want to increase the fees charged to us. Our costs are going up. That’s not fair. No providers should be exempt.

Health Service Provider
2018-11-16 [2019-001] Moira Hunter-Kenyon

I do not feel that it is reasonable to consider ANY increase in fees of any type when health care providers have not had so much as a cost of living increase in 6 years. Occupational Therapists who typically work in clients home have also seen an elimination of a mileage allowance. Working in a rural environment this resulted in a 10% reduction in my revenues overall as I have lots of country driving. My revenues and income have declined over 20% in the last 5 years and I simply cannot accept that FSCO needs more money from me without any consideration of an annual cost of living allowance for health care providers and reinstating the mileage allowance for OTs

Health Service Provider
2018-11-15 [2019-001] Alison Birkett

It is unreasonable to increase regulatory fees when health professionals have not had a fee raise since 2002. Regulated health professionals are doubly regulated since FSCO introduced this. Other issues related to payment should be addressed first, such as hourly rate parity and inclusion of all professionals, as those not listed in the PSG continue to benefit from a free market.

Health Service Provider
2018-11-06 [2019-001] Reena Pathak - Dr. Reena Pathak

I am liking that the fees have not increased much, but I am also liking the fact that if there are 6 or less auto cases, the AIR must be completed, but no annual fee will be charged. I am a small office and this is a good thing, since it will allow me to register and still assess and treat patients accordingly should they come with a necessity for treatment for an auto accident.

Health Service Provider
2018-11-06 [2019-001] Dan DeLuca

First off, I completely disagree with the fsra having to regulate what in essence is a bill payment. As a provider I do not provide any insurance or financial advice or service. If the fsra believe that to be the case then every single user of a credit card pos terminal in ever my single business should also be regulated. It's a money grab plain and simple and the fsra know it, but I can't do anything about that.
As to the matter of the fee increases, a bad idea.
Please ask for some clarity, I would be happy to indulge you.

Mortgage brokerage
2018-11-06 [2019-001] John Brooksbank - Chiropractic Health Care Centre

Recommendations are reasonable and supportive of small private clinics. I highly endorse the proposals provided for review.

Health Service Provider
2018-11-05 [2019-001] MARK BLAU

The Insurance companies requested this additional regulation, they should be the ones who pay for the full costs not the providers. The insurance companies set and raise their own fees each year yet we have little say as to our fee schedule. We have not had a raise in fees in years why should our fees go up?

Health Service Provider
2018-11-05 [2019-001] Sherri Flegel - Sherri Flegel, RMT

One time registration fee is still cost prohibitive as sole practitioner RMT, who only takes on MVA for existing clients or their referrals. I will not be able to make back the $337 to make it even worth my while to treat MVAs. I am happy to see no annual fee for 6 or less claimants, but I still won't use the FSRA/FSC0 due to registration fees.

Health Service Provider
2018-11-04 [2019-001] Kelli Blunt

I can appreciate there are yearly increases to providing hcai. As a service provider in my small community, I believe I am one of the few providers left serving patients in this profile. It is already a costly endeavor to service patients with the paperwork requirements, billing procedure, compliance protocols and staff training and then the delay in collecting accounts receivable due to awaiting EHC and insurer payments. Therefore any further increases continues to question my decision to participate. I have continued as when my own patients suffer impairment as a result of an auto injury I don’t know where they can receive care in my community without significant travel.

Health Service Provider
2018-11-03 [2019-001] Keshena Malik

Unreasonable to increase fees when hourly provider rates are not increasing to reflect this change.

Health Service Provider
2018-10-31 [2019-001] Peter Bassit

I am not a fan of the fees to begin with. I don't believe that health providers should have to pay HCAi fees to be registered, as its primary purpose is to prevent insurance fraud and organize the MVA sector. All of which is the insurance companies responsibility. I believe the insurance companies should be paying for this as it primarily benefits them. Any increase in fee's in my opinion is ludicrous. Why do we have to pay per claimant, its ridiculous and clearly a money grab.

Health Service Provider
2018-10-31 [2019-001] Dean Love - Dean Love

I, along with a number of other providers, opted out of treating MVA victims due to the cost and hyper-regulated intrusiveness of this program. One result has been to create challenges for patients in underserviced rural areas who have to travel much farther to get care when injured in an MVA.

Health Service Provider
2018-10-31 [2019-001] Dr. Scott Wilson - Physiomed

As a clinic owner and practitioner, how are these fees directly providing value to me and my patients, and what is the reason to raise the rates. In the Extended Health and WSIB sector, we are able to invoice directly to the insurers via TELUS without a fee, not sure why this isn't the case with HCAI especially when the remuneration amounts are dictated by FSCO as well.

Health Service Provider
2018-10-31 [2019-001] Sean Batte - Sean Batte Chiropractic Professional Corporation

At present the online portal of HCAI remains complex and time intensive. Given the fees that are assessed to providers to register and maintain their registration with the FSRA, the HCAI portal should be simplified and made considerably more user friendly. Further, courses should be made available for its use.

Health Service Provider
2018-10-31 [2019-001] Joanne Hubley - Liva health

I have always found these fees a cash grab and disagree entirely with being responsible for paying AIR. Persons caring for the injured should not be penalized for using a system to help them navigate a confusing insurance model. Rather these fees should be paid by the insurer from collected premiums. The cost of doing business for Healthcare providers shouldn't come at more costs to the providers period!

Health Service Provider
2018-10-30 [2019-001] Sumon Chakrabarti

I do not agree with raising the rates as proposed. Healthcare providers have not had an increase in hourly rates for years, nor has FSCO raised the funds available for MIG ($3500) to reflect inflation. If our costs continue to increase, it does not make sense to raise the costs for renewal.

Health Service Provider
2018-10-30 [2019-001] Maathavan Thillai

Im a small practice unable to help MVA patients because of the cost of maintaining a FSCO license. I like the six or fewer claimants per year will pay NO annual fee suggested change.

Health Service Provider
2018-10-30 [2019-001] Pam Kreps - Kreps Chiropractic Centre

I do like the change to no annual fees for providers seeing less than 6 per year. I live in small town and have 2 offices 35 min apart as a sole practioner. I do this for my patients in the area. The annual fee is alot for what I see but do it for patients so they have a prationer in this area that tkes MVA cases. I am apposed to any increase for second office.
Dr Harald Kreps DC

Health Service Provider
2018-10-30 [2019-001] Janine Holleran

I don't think it is fair to make us pay a registration fee since we already paid one for FSCO. It should be waived to all providers who have already paid a registration fee.

Health Service Provider
2018-10-30 [2019-001] Lisa McGowan - Private Practice

As a Registered Occupational Therapist I am already regulated by my college, COTO, whose annual fee is much higher than some other colleges. The purpose of the college is to protect the consumer, which would included the insurance industry. The duplication of fees should be eliminated, and certainly fees for the duplication should not increase. It adds insult to injury that a fee increase is contemplated when RHPs have gone without an increase in hourly fees for 5-6 years along with loss of ability to invoice for incurred mileage. I have contemplated stepping out of this area of practice as a result

Health Service Provider
2018-10-30 [2019-001] Bob Maitland

The purpose of treating individuals involved in MVAs is to return them to pre-accident status. Not only is this a demanding task, but the additional regulation of healthcare providers by an entity that is neither a regulated health profession governing body, nor an arbiter of evidence-based medicine is neither sound nor warranted and makes for an even more adversarial environment between insurers, claimants and providers. Furthermore, the lack of quinquennial SABS review, which are customary in the past, since September 2010, along with the absence of yearly service provider fee increases in line with inflation, are indicative of the partial nature of the newly formed FRSA. I hope that this decision is reconsidered for the benefit of all invested parties.

Health Service Provider
2018-10-30 [2019-001] Reza Nejad - healthcare management group

Dear reader,
The fees are in excess. The insurance companies spearheaded HCAI and they should be the one to pay the cost of running it not the providers that are forced in using it without an alternative mode of the submission made available to them.
Best regards,

Health Service Provider
2018-10-30 [2019-001] Stephen Konkle

I am a Health Service Provider who currently treats less than six MVC patients (claimaints) per year, as I have for the last 5 years. I would welcome the new fees for service providers, as it would allow me to direct bill for these claimants, whereas I currently do not. However, I do worry about additional fees for having a clinic audited, etc.

Health Service Provider
2018-10-30 [2019-001] Alicia McDougall

As regulated health care professionals, we already pay annual regulatory fees to our respective colleges. Additionally, our practices as healthcare providers and from a business perspective are regulated by our respective colleges. Therefore, FSCO adds a second and unnecessary level of oversight. Further to this, increasing fees for regulated health professionals with no associated increase in pay scale is not supported. If any changes should be made, there should be a decrease in fees and an increase in pay scale to accommodate inflation in our economy.

Health Service Provider
2018-10-30 [2019-001] Kim Lamont - Kim Lamont & Associates

I am a Registered Occupational Therapist, and therefore am already regulated (both in my interactions with the public and in my business practices) by COTO. I willingly pay a large fee each year for this, because it protects my profession. I do not gain any benefit from the duplication of regulation of practice by FSCO, now FSRA, nor does my profession. I believe that Regulated Health Professionals in good standing should not be required to be licensed under FSRA. Further, I cannot understand the justification for a regulatory fee increase when the rates paid to Health Care Providers has not increased in 5 years.

Health Service Provider
2018-10-29 [2019-001] Nevena Moylan - Nevena Moylan

Service provider rates have not gone up since 2010, yet fees are increasing. Why?

Health Service Provider
2018-10-29 [2019-001] Gina Matesic

I am curious how you can request an increase in fees, when our own fees have not increased in several years? This seems to be quite contradictory. I also am curious WHAT the increased fees are related to? I am grateful for my role as a health care professional, with the ability to work with injured persons to help them be healthier and achieve a greater quality of life. There are times in this industry that the "health care" concept seems to get lost, and that there is not a respect for the true care and compassion that we have for our clients. We are responsible to them, and thus continue our education, ensure we are treating from an evidence-based practice and adding value...that should be worth something, shouldn't it?

Health Service Provider
2018-10-29 [2019-001] Wendy Nieuwland - Skill Builders Physiotherapy & Rehab Centre

I feel that it very unnecessary to regulate service providers who are already regulated. Our licensing bodies who we have to pay a fee to for this regulation ensures that we follow all rules and if we didn't, we would lose our license. This extends to finances, our record keeping and how we conduct our business practices. There is no need to waste your resources on this double regulation both of which are government run. I would highly agree with regulating those who wish to bill for claimants through HCAI who are not regulated health practitioners. And I do not agree with a fee increase since we have not had a fee increase in several years for our services yet our costs of doing business are going up just like yours. I respectfully hope you will take this into consideration.

Health Service Provider
2018-10-29 [2019-001] Susan Cook

As a therapist who has been working in this sector for many years I find it interesting that an increase in our auto sector regulatory fees is felt to be needed while at the same time freezing our professional fee guidelines for the last five years. We already pay regulatory fees to our College. Additional regulatory fees should not increase. I also agree with other comments that should a facility pass their site visit, if anything, their fees should decrease.

Health Service Provider
2018-10-29 [2019-001] Nir Tamir

In 2006 fees were established in this sector. Most of us took a significant reduction in fees since 2014 there has been no increase in fee and they remain lower than they were 12 years ago. Insurance rates went up and up. It’s simply unfair to increase cost and for a duplicate license. In fact the insurers requested HCAI so they need to pay for it.

Health Service Provider
2018-10-29 [2019-001] Maria Paulsson

As a Registered Occupational Therapist I am already regulated by my college, COTO. OTs pay significant sums of money to be regulated by COTO, the purpose of which is to protect the consumer, which would included the insurance industry. There is duplication of oversight that is entirely unnecessary. The duplication should be eliminated, and certainly fees for the duplication should not increase. It adds insult to injury that a regulatory fee increase is contemplated when RHPs have gone without an increase in remuneration for 5-6 years along with loss of ability to invoice for incurred mileage.

Health Service Provider
2018-10-29 [2019-001] Sarah Good - Sarah Good

I think that it is a great idea to have providers with less than 6 claimants not pay an annual fee. I have less than six claimants most years and was considering ending my licence so that I can avoid the fee. However, if I don't have to pay an annual fee, I will remain open to seeing clients trough SABS.

Health Service Provider
2018-10-29 [2019-001] Kathleen Morris - Kathleen Morris, RMT

I do not agree with the proposed increase in charges. It is difficult for RMT's to have a large fee to pay in order to receive payment when auto insurers do not pay the full rate. We are offered a fraction of what we could make and we have an increased work load. There is extra paperwork with MVA clients; we need to spend more time creating invoices, submitting subsequent treatment plans when clients have not improved enough within the initial blocks. I personally have had to turn away new clients or lengthen treatment plans for non-MVA clients due to the inability to book them because my schedule is full because of the number of MVA treatments booked into each week. Without these MVA clients, I could see the other people and get paid my full rate. With MVA's I am still doing the same amount of laundry, booking, cleaning, and massage therapy. Would you do your job as well if you knew you were being paid $20 less per hour?

Health Service Provider
2018-10-29 [2019-001] Lance Humphries

Once every two years is quite sufficient. Excessive regulation/oversight hurts freedom and ultimately, the economy.

Mortgage brokerage
2018-10-26 [2019-001] Heather McKechnie - Heather McKechnie

I did not renew my license this year because I did not have any MVA clients and did not want to pay for the right to bill online in the event that I had another MVA client. The proposed changes to eliminate fees for a health care provider to drop fees unless they provide service to more than 6 people would have made a difference to me. I have heard so many complaints from other social workers about Insurance companies quibbling over fees is a real deterrent. I hope you do make these changes as proposed asap.

Health Service Provider
2018-10-26 [2019-001] Katie Wolk

I like that the annual fee will be eliminated for facilities like my own with fewer than 6 claimants per year. I would like to see an increase in support for claimants needing massage therapy, who only receive $58.19 per hour of treatment, while the cost of massage across Ontario is $85 to $100 per hour on average. I hope that my one-time fee I have already paid to FSCO remains a one-time fee and that I do not have to pay another one-time fee to the FSRA. If I need to pay $337 again, the service will be too prohibitive to me and I won't be renewing my facility licence.

Health Service Provider
2018-10-22 [2019-001] Jacquelyn Bonneville

As a regulated health professional, I already pay College fees that review my business, insurance fees, and FSCO licensing fees. I feel like an increase in these fees is unnecessary and a duplication of fees I already pay.

Health Service Provider
2018-10-21 [2019-001] Donna Barrett

Regulated health professionals are already regulated by their professional Colleges. This level of oversight is duplication and is co-occurring with our respective Colleges charging us fees to provide the same types of regulation. These fees are excessive and should be reduced and not increased. Our professional fees have been capped and stymied by FRSA for the past 5 years with no increase, despite the cost of inflation. In addition we have had the ability to charge mileage expenses removed from us. In effect, FRSA regulations have reduced our income (loss of mileage costs, despite the rampant increase in fuel costs that we incur to service the insured in their home environment), frozen our wages for the past 5 years with no respect or acknowledgement of the increase in cost of living, and now you have not only added, but are increasing fees for a regulation that is already provided by our Colleges. We respectfully ask you to reconsider either removing these fees altogether or reducing them to reflect a more reasonable cost given the loss of income we continue to incur in this industry as health care professionals.

Health Service Provider
2018-10-21 [2019-001] Leslie Birkett

As an OT, I am regulated by COTO and FSCO, dual licensing that is not supported. COTO regulates my clinical and business practises. FSCO therefore adds a second and unnecessary level of oversight. Increasing fees for regulated health professionals is not supported and as we have not had a raise since 2012, regulatory fees should be reduced or eliminated.

Health Service Provider
2018-10-21 [2019-001] Nicholas Livadas

Most Canadians seem to be enjoying pay hikes, from people earning minimum wage, those earning annual pay hikes, and other professionals increasing their fees as per market forces. My allowable billable rate is fixed and stagnant, life got very expensive, and now fees are going up. Please give me a break is some form.

Health Service Provider
2018-10-21 [2019-001] KAREN RUCAS - Life care planning consultants

Historically, health service providers were not in favour of being regulated TWICE in Ontario. Our respective Colleges not only regulate us from a clinical perspective, but also review our business practices within Ontario Regulation 95/07, Section (1)18 to 26. We pay hefty annual fees to our respective Colleges and, since 2014, large fees for FSCO licensing. Consequently, we do not wish to see licensing fees go up, particularly for those of us who have been deemed compliant during FSCO audits. We would like to see profession specific data related to audit findings and fees must go down. Alternatively, the government might re-consider this duplicative regulation and remove it entirely.

Health Service Provider
2018-10-17 [2019-001] Stephen Lidsky - PMC Funding

I don't think this is the appropriate forum to voice opinions on the definition of "non-qualified syndicated mortgage investments", however perhaps you can forward to the proper channel. A syndicated mortgage on a commercial or industrial property should not be considered "non-qualified" due to the asset class. A first mortgage for 50% of an industrial property's value almost always contains less risk than a high ratio second mortgage on a residential property, yet the latter is not subject to the same disclosure requirements. "Non"-qualified syndicated mortgage investments should be restricted to development deals, which require a greater degree of sophistication and understanding by an investor. Simple commercial/industrial properties and single family home construction do not warrant being labeled as "non-qualified".

Mortgage brokerage
2018-10-17 [2019-001] Stephen Lidsky - PMC Funding

The new proposed fee rules require mortgage brokerages to pay a fee of $200 for non-qualified syndicated mortgage investments within 5 days of a potential investor receiving the disclosure documents. Often deals are delayed or even canceled; fees should instead be due within 5 days of the closing date of the transaction.

Mortgage brokerage
2018-10-12 [2019-001] Igor Tsemokh - Mortgage Accomplished

Annual Fee must be the same as Mortgage Professionals paid under FSCO. Brokerage fee may vary depends of the numbers of Brokers/Agents. Membership Fee already increased last Year. it is not important : every Year or every 2 years. Please do not increase Membership payment.

Mortgage brokerage
2018-10-10 [2019-001] Amrut Rathod - Reliable Financial Group Inc

1. All brokers registered under mortgage brokers act and also lenders. I have faced some lenders have their own reservation and do not allow to submit the deals. Why difference? They shall entertain all brokers registered with FSCO.
2. Some agents/brokers registered with brokerage they leave in the middle or on renewal and join another brokerage FSCO or registration authority never contact to brokerage for their consent/comment.
3. All restriction to broker and brokerage but lenders and borrowers do not have to comply or their responsibility.
4. There shall be some check before mortgage application initiated by other lender or brokerage, because borrowers are shopping from one to another and earlier or beginner lender/brokerage loose the business. Meaning lender or brokerage working after earlier brokerage shall inquire first brokerage or lender or get consent.

Mortgage brokerage
2018-10-10 [2019-001] JERRY ROSE - VERICO ALLENDALE MORTGAGE SERVICES LTD.

Do not change the licensing term from two years to one yearit will only increase administration costs without serving any useful purpose.All mortgage brokerage firms and their employees have E & O E insurance so a one year term is meaningless.Make sure all syndicated mortgages are registered on the secured property in the % of each lender and you solve the problem no need for a $200.00 fee .You should also run these changes by the Ford Admin. before implementing.

Mortgage brokerage
2018-10-09 [2019-001] Richard Austin - Self-employed

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