Activité d’échange de l’ARSF de 2024 – Enregistrements
L’échange de l'ARSF 2024 s’est concentré sur la réglementation dans un environnement en évolution rapide avec des discussions en groupe réunissant de nombreux experts du secteur des services financiers et dirigeants de l’ARSF.
Vidéo des points saillants
Séances du matin
8 h 45 – 8 h 55
Mot de bienvenue de l’hôtesse, Judy Pfeifer, directrice générale des relations publiques (voir biographie)
8 h 55 – 9 h 5
Salutations de la présidente du conseil d’administration de l’ARSF, Joanne De Laurentiis (voir biographie)
9 h 5 – 9 h 15
Salutations de l’honorable Peter Bethlenfalvy, ministre des Finances (voir biographie)
Transcription de vidéo - Salutations de l’honorable Peter Bethlenfalvy, ministre des Finances
9 h 20 – 10 h 15
Causerie avec Mark White, directeur général de l’ARSF (voir biographie)
Transcription de vidéo - Causerie avec Mark White, directeur général de l’ARSF
10 h 35 – 11 h 10
Les conséquences du changement climatique sur les services financiers, les consommateurs et le rôle de l’autorité de réglementation
11 h 25 – 11 h 55
L’essor de l’IA, son application aux services financiers et ses conséquences pour les autorités de réglementation
11 h 55 – 12 h 5
Mot de la fin de Mark White, directeur général, ARSF
Transcription de vidéo - Mot de la fin de Mark White, directeur général, ARSF
Séances de l’après-midi
13 h 5 – 14 h 30
Courtage hypothécaire : À quoi ressemble la mise en place d’une culture de la conduite positive? Adaptation de l’approche aux maisons de courtage de différentes tailles.
13 h 5 – 14 h 30
Assurance vie et assurance santé : Les consommateurs au centre des préoccupations – À quoi ressemblent une culture de la conduite forte et un contrôle efficace dans le secteur de l’assurance vie et de l’assurance santé?
Transcription de vidéo - Séance #2 Assurance vie et assurance santé
13 h 5 – 14 h 30
Assurance IARD (autres que l’assurance automobile) : Garantir le traitement équitable des consommateurs d’assurances IARD (autres que l’assurance automobile), y compris notre travail sur la gestion des sinistres en assurance habitation et l’amélioration de notre politique et de notre approche de la supervision de la sous-traitance par les assureurs.
Transcription de vidéo - Séance #3 Assurance IARD (autres que l’assurance automobile)
13 h 5 – 14 h 30
Planificateurs financiers et conseillers financiers : Approbation des organismes d’accréditation et leur rôle dans la protection des consommateurs dans le cadre de la protection des titres des professionnels de la finance.
Transcription de vidéo - Séance #4 Planificateurs financiers et conseillers financiers
13 h 5 – 14 h 30
Caisses : Vision à long terme et évolution du secteur des caisses
Transcription de vidéo - Séance #5 Caisses : Vision à long terme et évolution du secteur des caisses
13 h 5 – 14 h 30
Régimes de retraite : Gestion des risques et réglementation fondée sur des principes
Remarque : la qualité audio est médiocre pendant les sept premières minutes de la vidéo en raison de problèmes de microphone.
13 h 5 – 14 h 30
Assurance automobile : Réforme de la réglementation des taux et de la souscription d’assurance automobile – Améliorer les résultats pour les consommateurs grâce à une supervision basée sur le risque
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Good morning.
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On behalf of all teachers, good morning.
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Awesome.
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Thank you very much.
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Good morning, and welcome to our third annual FSRA Exchange event.
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My name is Judy Pfeifer.
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I'm the Chief Public Affairs Officer and I'm honoured to MC today.
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Before we begin, we'd like to do our land acknowledgment.
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Before we begin, it's important to acknowledge the land we are on is the traditional territory
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of many nations, including the Mississaugas of the Credit, the Anishnabeg, the Chippewa, the Haudenosaunee
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and the Wendat peoples and is now home to many diverse First Nations, Inuit and Métis peoples.
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We acknowledge that Toronto is covered by Treaty 13 with the Mississaugas of the Credit
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and the Williams Treaties signed with multiple Mississaugas and Chippewa bands.
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Before we begin
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some housekeeping, I just want to remind everybody this session is being taped.
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We have simultaneous French translation,
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and the most important part,
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we're taking all questions by the app.
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So when you got your registration confirmation, you got a login and a passcode.
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I know, another passcode.
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You can go from this QR code.
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If you take a picture of it, put your camera on it, you see a little yellow thingamajig and you press on it.
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You're going to need to know your email and your passcode, but that's how we're taking questions today.
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So just a reminder, if you've not logged in, you've got some time to do it right now.
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In terms of today's event.
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We will take questions through the website.
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If you're having difficulty logging in or your passcode does not work, if you flag a member of the FSRA team,
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they will come and take your question written down and input it into the conference app.
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So great news today.
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This continues to be our largest FSRA Exchange.
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This year we have over 1,200 people participating.
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Last year you may recall we had 300 people in house.
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Today we have over 640.
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And then we have an additional 600 people online.
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People ask us, why do you do the online feature?
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We do it for two reasons.
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One, doesn't matter where you live in the province,
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you should be able to access our event without having to come to downtown Toronto.
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Second of all, we want our staff who can't come to see the conversation to help them become better regulators.
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So over the course of the morning, we're going to explore some challenges and opportunities
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facing financial services and how we can better protect consumers.
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On the conference website, you can findthe information about all of our speakers.
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In the afternoon, we will break into sector specific workshops.
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And then please join us at 2:30 for our reception.
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This morning we're going to
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start with remarks from our Board Chair.
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Joanne has been the FSRA Board Chair since 2021.
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She comes to FSRA with an accomplished career as President and CEO of Investment
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Funds Institute of Canada, President and CEO of Central Credit Union of Canada,
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and Vice President of the Canadian Bankers Association.
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Joanne.
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Please.
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Thanks, Judy.
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God, there's so many of you here.
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Welcome.
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It is great to see such a large audience.
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And I want to welcome as well those of you who are online.
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So again, thank you for coming,
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but I want to start by
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thanking in particular those of you who are here
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who sit on our Advisory, our Sector Advisory Committees,
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and also our Advisory Panel, our Consumer Advisory Panel.
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And, Laura, I don't know where you are, but,
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I want to thank Laura Tamblyn Watts, the Chair of that Committee.
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You know, all of
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the input we get from the Advisory Committees and in particular
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the Consumer Advisory Committee really strengthens the work we do.
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And it really helps us to understand,
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both sectoral issues and what consumers need.
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So thank you for that.
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So welcome again.
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In the few minutes,
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I've got I'm going to speak with you today.
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I want to come back
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to the theme that I highlighted last year,
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FSRA was given five years ago now.
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FSRA was given the mandate to transition
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into a principles-based regulator, or PBR for short.
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You know, we love our acronyms, so keep that PBR
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principles-based regulation.
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That approach
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drives outcomes, giving consumers choice, fairness and safety
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in the products and services available to them.
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And it allows financial services companies a greater capacity to innovate.
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As Board Chair,
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I've been hearing from people in many of our sectors
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about how we are implementing the principles-based regulation.
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Most of the comments, I'm happy
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to say, have been extremely positive,
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but I also hear concerns.
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Those who are expressing concerns
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believe there's ambiguity in the approach,
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and they are somewhat uncomfortable with the fact that we are moving away
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from the known, standard checklist
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and prescriptive requirements.
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Concern centers around the fact that there isn't clarity
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about how to achieve the outcomes FSRA expects.
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There's also concern that transitioning to principles-based
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regulation is leading FSRA to collect
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more of your information and data.
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Over the next few minutes I will speak to those concerns
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and hopefully leave you with a greater understanding of what we are doing
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and the benefits that we all are going to reap from that approach.
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So while we have
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highlighted FSRA's move to principles-based model,
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a better description
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is that we are moving to a hybrid model.
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A hybrid model is one that seeks to rely mainly on principles
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such as protecting the rights and interests of consumers
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and promoting high standards of business conduct.
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The model will set clear outcomes that we expect
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our regulated sectors will eventually meet.
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But while FSRA
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seeks to, will seek to rely mainly on the principles to support
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the regulatory outcomes
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we've identified, there will always be a need for rules
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under specific circumstances.
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We use the term rules in two senses.
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There are FSRA rules which are generally structured
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in a more principles based and outcomes focused manner.
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And there are existing statutory requirements and regulations
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that contain prescriptive standards, such as the requirement to hold a license.
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Some of our
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rules are more principles-based and some are more prescriptive.
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Therefore, depending on the context and the policy objective.
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For example,
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FSRA has worked closely with regulators across the country to agree on how
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the cost of investing should be calculated
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for segregated funds and mutual funds.
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We will implement this approach in a detailed FSRA rule,
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to enable customers to compare the costs
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of their various investments based on consistent reports.
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That's an example of a prescriptive rule.
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Principles-based regulation
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is founded on a supervisory relationship,
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which is cooperative, collaborative,
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and requires mutual trust.
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As your regulator FSRA won't act unilaterally
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for those who are committed to achieving the identified outcomes.
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We will work to build consensus and understanding.
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We trust, but verify
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using information and data
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that you provide to assess the achievement of your outcomes.
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The exercise benefits both FSRA
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and the regulated entity.
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The insight
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that we get by your data sharing allows FSRA
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to focus on fulfilling its statutory mandate.
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So good regulation, of course, as I've said,
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comes from that data because it provides an understanding
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of the business and service it is regulating.
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So good regulation comes from a regulator
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understanding your business,
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because it allows us to be more proactive and then reactive,
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allowing us to identify potential issues.
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And course correct before something becomes a full blown
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crisis and impacts the stability of the sector or undermines
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the consumer, the confidence of the consumer.
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This is really what PBR is meant to achieve.
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From the regulator's perspective, the ability to focus on the problems that matter.
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Let me give you a couple of examples,
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about that, that will illustrate what I'm talking about.
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We recently completed
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two thematic reviews of the Credit Union sector,
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one on residential mortgage lending and the other on deposit
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taking. A total of 58 Credit
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Unions, pretty much the entire system,
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provided detailed data.
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For many, it required a substantial effort
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and considerable resources to fulfill,
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but it was worth it.
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With higher interest rates, inflationary pressures
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and a resulting housing crisis.
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We found that Credit Unions have not, let me repeat,
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not materially increased lending activity in high-risk mortgages.
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The bottom line, we are not seeing system wide issues
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that should be addressed with more prescriptive Guidance
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or rules.
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The ability
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to access that data in a timely manner allowed FSRA
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to reduce the regulatory burden
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by not imposing additional requirements,
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which would be a solution
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looking for a problem.
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The Credit Union
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data demonstrated that while other information was showing
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that financial institutions were making riskier loans,
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Credit Unions were acting prudently.
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The second thematic review was on Credit Union deposit
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taking. That data helped us understand
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current trends in deposit taking activities,
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and enabled FSRA to identify opportunities
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to enhance deposit taking practices, particularly as they relate to
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periodic self-assessments, internal audit
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efficiency and board oversight.
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These thematic reviews and the data that supported
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them, have allowed us to get an accurate picture of the sector, enabling us
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to develop a regulatory response that is both measured and appropriate.
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An ongoing analysis of that
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data will tell us whether
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our solutions are working, or whether we need to change course.
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By the way, the data
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of these thematic reviews is being shared with the Credit Union sector.
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So it gives the sector,
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the Senior Management and the Board of Directors of each Credit Union,
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information that allows them to better
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manage their operations.
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I'll give you one further example of
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FSRA’s collection analytics in action.
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Our market conduct unit completed a first of its kind
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review of Life and Health Insurance
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Managing General Agencies or MGAs,
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in this case, the acronym as a whole lot easier than Managing
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General Agencies.
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Using the data collected
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our unit discovered that some MGAs
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and their agents were using poor training materials
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and selling complex products
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that were not appropriate for their consumers.
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In fact, some customers were being harmed.
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The investigation resulted
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in enforcement action against two MGAs
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and follow-up with other MGA agents and insurers.
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So with these
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examples, I hope I've clarified the key benefits
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and the promise of a hybrid, principles and rules-based
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regulation model.
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I think that, you know, I think we all think certainly at FSRA
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and the Board, that providing the information
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and data support
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to support our analytics
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is a more effective way of supervision
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than having a team of supervisors
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descending on you, asking questions,
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gathering documents,
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that may or may not tell the story.
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The full story.
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It can lead to less burden for you over time.
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And our discussions will be more focused.
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And our efforts directed to where they matter most.
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In most cases, the information
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and data we're asking for should already exist.
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If it doesn't, a request will create a constructive
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internal dialog about the value of good information and data.
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We believe it's foundational and fundamental to understanding
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your business, particularly as we move into an AI driven world.
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The responsible sharing of information and data will be the cornerstone
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for societal advancement and well informed decisions.
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So in closing, let me summarize the key points I'd like you to take away.
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First,
00:12:49,000 -- 00:12:52,236
consumer and beneficiary
00:12:52,236 -- 00:12:55,673
protection are at the heart of everything we do at FSRA.
00:12:57,108 -- 00:12:59,176
Second,
00:12:59,176 -- 00:13:02,980
we're thinking differently and are fully committed to implementing
00:13:02,980 -- 00:13:08,185
a hybrid principle-based and prescriptive-based
00:13:09,520 -- 00:13:12,523
approach that will give us the right outcomes.
00:13:13,958 -- 00:13:15,559
Third,
00:13:15,559 -- 00:13:17,628
we encourage you to share information
00:13:17,628 -- 00:13:21,866
and data to allow us to better understand your business,
00:13:22,099 -- 00:13:26,237
which will result in better regulatory decisions and outcomes.
00:13:27,538 -- 00:13:29,340
And fourth, as I noted
00:13:29,340 -- 00:13:32,710
about our Advisory, Sectoral Advisory Committees,
00:13:33,244 -- 00:13:38,616
consultation is foundational to FSRA, and we support robust
00:13:38,616 -- 00:13:42,786
dialouge and collaboration across all of our sectors.
00:13:42,786 -- 00:13:45,256
So thanks for being here today
00:13:46,590 -- 00:13:49,226
and continuing that dialog and conversation.
00:00:05,271 -- 00:00:07,140
Consumer protection
00:00:07,140 -- 00:00:10,543
is also a priority of the Government of Ontario,
00:00:11,077 -- 00:00:14,414
and particularly so for the Minister of Finance.
00:00:15,582 -- 00:00:18,585
Since being elected in 2018,
00:00:18,918 -- 00:00:22,989
the Honourable Peter Bethlenfalvy has been a strong advocate
00:00:23,656 -- 00:00:27,127
of improving and strengthening our public service
00:00:28,194 -- 00:00:31,798
and ensuring people from all walks of life have access
00:00:31,798 -- 00:00:37,170
to efficient public services when and where they need them.
00:00:38,505 -- 00:00:41,107
Now, as you know, the Minister is in the height
00:00:41,107 -- 00:00:45,411
in the middle of the budget season and taking time out
00:00:46,079 -- 00:00:51,684
to be with us today, tells you how important he knows each of your sectors
00:00:51,985 -- 00:00:56,890
are to serving the financial needs of consumers, depositors,
00:00:57,190 -- 00:01:01,227
and plan member and plan sponsors and the economy of Ontario.
00:01:01,861 -- 00:01:03,963
It's now my privilege
00:01:03,963 -- 00:01:07,333
to invite the Minister to the stage to say a few words.
00:01:07,533 -- 00:01:08,034
Minister.
00:01:19,445 -- 00:01:20,146
Well, good morning.
00:01:20,146 -- 00:01:21,447
And, thank you, Joanne.
00:01:21,447 -- 00:01:24,450
That was a great, overview.
00:01:26,753 -- 00:01:28,388
Multiple things to think about.
00:01:28,388 -- 00:01:32,258
And, you know, principle-based regulation, consumer,
00:01:32,258 -- 00:01:33,726
data, collaboration.
00:01:33,726 -- 00:01:36,663
You really hit some big themes in my career.
00:01:36,663 -- 00:01:39,532
I spent 15 years in New York and,
00:01:39,532 -- 00:01:42,435
working for TD and Dominion Bond Rating Service.
00:01:42,435 -- 00:01:46,606
And, you know, I saw that overly prescriptive, rules-based
00:01:46,706 -- 00:01:50,843
regulatory system versus Canada's and OFSI's
00:01:50,843 -- 00:01:54,514
principle-based regulation system, really have different
00:01:54,514 -- 00:01:57,617
outcomes in the financial crisis of 2000 and 2009.
00:01:57,617 -- 00:02:02,855
So I really applaud the work of your board, Joanne, and your service
00:02:02,855 -- 00:02:06,859
to FSRA, to Mark White and the team, and all the Board Members
00:02:06,859 -- 00:02:08,795
that are here today.
00:02:08,795 -- 00:02:11,497
You know, folks, this is a new organization, it’s
00:02:11,497 -- 00:02:16,135
still a puppy, having been merged of two other organizations.
00:02:16,135 -- 00:02:17,904
So the amount of progress
00:02:17,904 -- 00:02:21,674
that has been made really in five years, Joanne, is really remarkable.
00:02:21,674 -- 00:02:24,877
And so, I think, a round of applause for FSRA. Would be well
00:02:24,877 -- 00:02:26,579
warranted at this point.
00:02:31,384 -- 00:02:32,118
Now, we do have
00:02:32,118 -- 00:02:35,888
a rule, Joanne, that any acronym is $5 in the jar.
00:02:35,888 -- 00:02:37,256
And I think he broke that rule twice.
00:02:37,256 -- 00:02:40,092
So you owe us ten bucks.
00:02:40,092 -- 00:02:42,862
I do want to thank everyone for being here.
00:02:42,862 -- 00:02:46,966
You represent so much of the vital economic interests,
00:02:46,966 -- 00:02:49,969
financial interests of Ontario, right here in this room.
00:02:50,169 -- 00:02:54,540
Be it, Property and Casualty, be it Life, be it Credit Unions, be
00:02:54,540 -- 00:03:00,479
it Pension, be it Title Protection, you know, a range of industries.
00:03:00,479 -- 00:03:02,481
It's so important that we collaborate.
00:03:02,481 -- 00:03:06,752
I really like that point and share data because we have a common objective
00:03:06,752 -- 00:03:10,656
to have safety and soundness in our financial system, but to move
00:03:10,656 -- 00:03:15,628
forward in a very, complex world that isn't getting any less complex.
00:03:16,562 -- 00:03:20,800
I'm going to have a few remarks here, and I'm gonna frustrate my team
00:03:20,800 -- 00:03:23,836
because I go off script so often and I think I'm about to do it again.
00:03:25,371 -- 00:03:28,207
You know, I think the rapidly changing environment is what I look
00:03:28,207 -- 00:03:30,142
toward real leadership.
00:03:30,142 -- 00:03:33,045
You know, how do we respond to a changing environment,
00:03:33,045 -- 00:03:34,547
a changing economy?
00:03:34,547 -- 00:03:36,882
We know the world is a very complex place.
00:03:36,882 -- 00:03:38,451
And boy, we're seeing complexity
00:03:38,451 -- 00:03:41,821
like we've never seen before, certainly not recently.
00:03:42,521 -- 00:03:46,492
And so the ability for an organization like the Financial Services
00:03:46,492 -- 00:03:50,730
Regulatory Authority—said that to avoid $5, by the way...
00:03:51,697 -- 00:03:53,799
is so critical
00:03:53,799 -- 00:03:56,802
and I know we're going to continue on the provincial side
00:03:57,169 -- 00:04:01,707
to support the organization, to support the work that you do
00:04:02,041 -- 00:04:05,077
and to support the many industries that are represented in this room.
00:04:06,078 -- 00:04:10,149
You know, change is a positive thing, but we have to do smart change.
00:04:10,149 -- 00:04:13,285
And I think, that is what is occurring.
00:04:14,120 -- 00:04:16,455
I can tell you that from, my
00:04:16,455 -- 00:04:19,091
perspective, I continue to work day in, day out.
00:04:19,091 -- 00:04:23,429
You're right, we have a budget that I have to table, honour, before
00:04:23,696 -- 00:04:25,064
March 31st.
00:04:25,064 -- 00:04:29,668
And I can tell you that we continue to invest in a responsible
00:04:30,369 -- 00:04:33,138
fiscal plan and a path to balance.
00:04:33,138 -- 00:04:36,408
I think that's really important that we don't lose sight.
00:04:36,408 -- 00:04:40,446
That, you know, the more debts and deficits we rack up, we're just
00:04:41,247 -- 00:04:43,582
burdening the next generation.
00:04:43,582 -- 00:04:46,619
And so intergenerational issues are really big
00:04:46,619 -- 00:04:49,655
as we think about how we manage the fiscal policy.
00:04:50,322 -- 00:04:51,724
And I can tell you that,
00:04:53,392 -- 00:04:54,126
the environment
00:04:54,126 -- 00:04:57,463
that we're in, excuse me; high inflation coming down
00:04:57,863 -- 00:05:01,367
2.9% in the last print, headline inflation
00:05:01,767 -- 00:05:04,703
2.7%, actually in Ontario,
00:05:04,703 -- 00:05:08,207
is directionally positive, is still very high and many, many people
00:05:08,741 -- 00:05:11,744
in this province feel like we're in a deep recession.
00:05:12,278 -- 00:05:14,747
You know, many of us are fortunate, many are fortunate.
00:05:14,747 -- 00:05:17,916
But many, you know, to be able to
00:05:19,084 -- 00:05:23,522
afford the food, the cost of food, the cost of rent, the cost of a mortgage
00:05:23,522 -- 00:05:24,890
that's rolling over,
00:05:24,890 -- 00:05:27,926
the cost of day-to-day life is hurting many, many people.
00:05:27,926 -- 00:05:28,527
And in government
00:05:28,527 -- 00:05:32,431
we have to be very mindful of that in the economy
00:05:32,431 -- 00:05:35,367
and the economic environment that we're in.
00:05:35,367 -- 00:05:38,370
Today, I can say that the government
00:05:38,470 -- 00:05:42,741
continues to invest prudently and responsibly
00:05:43,442 -- 00:05:45,878
to build a strong province
00:05:45,878 -- 00:05:49,915
while staying on track to balance the budget.
00:05:49,915 -- 00:05:52,017
Ontario's labour market
00:05:52,017 -- 00:05:56,855
is showing strong 2023 results overall,
00:05:56,855 -- 00:05:59,858
but it has recently shown signs of reflection.
00:06:01,226 -- 00:06:04,463
And despite ongoing challenges,
00:06:04,463 -- 00:06:09,768
such as high Bank of Canada interest rates and inflationary pressure,
00:06:09,802 -- 00:06:14,039
Ontario's economy remains resilient,
00:06:14,039 -- 00:06:19,077
and is expected to continue to grow in 2024
00:06:19,311 -- 00:06:23,649
just as it did last year.
00:06:23,649 -- 00:06:25,350
You know from day one,
00:06:25,350 -- 00:06:28,120
our government made a promise to the people and stakeholders
00:06:28,120 -- 00:06:33,392
of Ontario to give, to govern in a way that is responsible and transparent.
00:06:33,392 -- 00:06:37,229
Joanne, you talked about collaboration and sharing data,
00:06:37,229 -- 00:06:41,366
and our government feels very strongly about data and using data.
00:06:41,366 -- 00:06:44,202
And if you can't measure things, you can't manage them.
00:06:44,202 -- 00:06:45,304
And we have a lot to do.
00:06:45,304 -- 00:06:47,439
You know, we are very much
00:06:47,439 -- 00:06:50,776
Silicon Valley North here in Canada and particularly in Ontario.
00:06:51,243 -- 00:06:54,880
We have a great artificial intelligence, great data
00:06:54,880 -- 00:06:58,717
and digital capabilities right here in Ontario, right here in Toronto.
00:06:58,717 -- 00:07:02,587
Not far from here, Waterloo and Ottawa and many other parts of Ontario.
00:07:03,021 -- 00:07:06,058
So we have to use that as a competitive advantage as we move forward.
00:07:06,725 -- 00:07:08,527
And I feel strongly about that.
00:07:08,527 -- 00:07:11,863
You know, government is a very complex organization.
00:07:12,464 -- 00:07:15,967
And right across the street from government is the private sector.
00:07:16,535 -- 00:07:19,805
And right across the street to the west is academia, represented
00:07:19,805 -- 00:07:20,839
by the University of Toronto
00:07:20,839 -- 00:07:23,842
and all the great colleges and universities that we have.
00:07:24,009 -- 00:07:27,012
And in just a little while,
00:07:27,279 -- 00:07:30,282
some private benefactors donated
00:07:30,482 -- 00:07:33,885
$100 million to build the new artificial intelligence
00:07:34,720 -- 00:07:38,757
office right across from my office in Frost, up at Queen's Park.
00:07:38,757 -- 00:07:42,194
So my view now is blocked by an artificial intelligence
00:07:42,728 -- 00:07:45,297
building, and I think that's a good thing.
00:07:45,297 -- 00:07:48,033
I think that's a good thing, because Ontario
00:07:48,033 -- 00:07:51,369
and Canada have such great competitive advantages.
00:07:51,803 -- 00:07:54,606
You know, we're able to work collaboratively across
00:07:54,606 -- 00:07:58,343
government, public sector, private sector, academia to get better
00:07:58,343 -- 00:08:01,346
outcomes for the people of Ontario and for Canada.
00:08:01,580 -- 00:08:03,715
So know that we will continue in that regard.
00:08:05,183 -- 00:08:05,717
You know, I do
00:08:05,717 -- 00:08:09,187
know that, I will talk about a couple of other things right now.
00:08:09,187 -- 00:08:12,190
One is that, you know, I'm touched on how
00:08:13,158 -- 00:08:15,460
the environment is very difficult for people.
00:08:15,460 -- 00:08:18,797
And as you serve your clients, many of you serve clients in this room.
00:08:19,531 -- 00:08:22,267
You know, remember that times are tough,
00:08:22,267 -- 00:08:24,035
that we're looking at ways to put more
00:08:24,035 -- 00:08:27,906
money back in people's pockets to make life a little bit affordable.
00:08:27,906 -- 00:08:29,674
We've cut the gas tax, for example.
00:08:29,674 -- 00:08:33,011
We've indexed a number of social welfare programs to inflation.
00:08:33,011 -- 00:08:35,814
First time that's ever been done by any government.
00:08:35,814 -- 00:08:40,619
You know, we continue to find ways to reduce fees, like dropping the
00:08:40,719 -- 00:08:45,657
license plate stickers that took money out of people's pockets.
00:08:45,657 -- 00:08:47,158
And we'll continue in that regard.
00:08:48,326 -- 00:08:50,695
I can say to you today
00:08:50,695 -- 00:08:53,565
that our government understands
00:08:53,565 -- 00:08:55,533
that people already
00:08:55,533 -- 00:08:58,503
have to be very careful with how they spend
00:08:58,503 -- 00:09:00,805
their hard-earned money.
00:09:00,805 -- 00:09:03,608
And that's why I will continue that work.
00:09:03,608 -- 00:09:07,245
I do want to talk about another area that our vision
00:09:07,245 -- 00:09:10,248
for Ontario is so paramount.
00:09:11,082 -- 00:09:14,019
And that is infrastructure and housing.
00:09:14,019 -- 00:09:17,889
You know, this, this great province has attracted so many people.
00:09:17,889 -- 00:09:21,826
If you're other than indigenous, everyone came from somewhere else.
00:09:22,694 -- 00:09:25,830
My parents came from war torn Hungary, and I met,
00:09:26,197 -- 00:09:29,834
Sandor, you're in this room somewhere who came from Budapest six years ago.
00:09:29,834 -- 00:09:34,072
Now works at FSRA, works in your supervisor area for Credit Unions.
00:09:34,606 -- 00:09:37,575
You know, as I travel around the world,
00:09:37,575 -- 00:09:42,280
one thing I keep hearing over and over again is how they view Canada.
00:09:42,881 -- 00:09:47,118
And they view Canada as a sea of stability, a beacon of hope
00:09:47,118 -- 00:09:51,356
for people, a beacon of freedom and democracy in a very troubled world.
00:09:52,090 -- 00:09:55,326
And that's why I think it's so critical that our government
00:09:55,326 -- 00:10:00,598
and our policies continue to focus on putting in place
00:10:01,366 -- 00:10:04,035
the conditions to grow,
00:10:04,035 -- 00:10:07,038
whether people are here or come from somewhere else.
00:10:07,405 -- 00:10:08,306
And what does that mean?
00:10:09,307 -- 00:10:09,941
That means that we
00:10:09,941 -- 00:10:12,944
have to work on housing and we have been.
00:10:13,011 -- 00:10:15,547
You know, a whole generation is finding it
00:10:15,547 -- 00:10:18,550
impossible to own a house.
00:10:18,616 -- 00:10:20,952
You know, when my parents came
00:10:20,952 -- 00:10:24,355
and I wasn't born yet. They met here in Toronto.
00:10:25,156 -- 00:10:29,494
My first experience was living in Montreal where
00:10:30,562 -- 00:10:33,831
my grandparents lived with three of my great grandparents.
00:10:34,766 -- 00:10:36,968
Plus, my mother's brother.
00:10:36,968 -- 00:10:39,971
You know, multi-generational in one house but they had a house.
00:10:41,806 -- 00:10:45,310
You know, my granddad and my father and my mother were able to find jobs.
00:10:45,710 -- 00:10:47,745
They were able to grow a family.
00:10:47,745 -- 00:10:49,647
They felt safe in this country.
00:10:49,647 -- 00:10:52,350
So I think we have to continue collectively
00:10:52,350 -- 00:10:55,486
supporting the environment to build more infrastructure, houses,
00:10:55,953 -- 00:11:00,058
the social infrastructure, health care, home care, long-term care,
00:11:00,758 -- 00:11:03,728
hospital beds, mental health and addiction.
00:11:04,028 -- 00:11:07,665
These are all important part of our plan to build Ontario.
00:11:08,132 -- 00:11:09,934
We have to build more roads.
00:11:09,934 -- 00:11:13,471
You have to build more subways and transit, public transit.
00:11:13,471 -- 00:11:14,272
That's what we're doing.
00:11:15,373 -- 00:11:17,842
And we're doing it all simultaneously.
00:11:17,842 -- 00:11:21,879
Because if we are going to continue to be the beacon of hope
00:11:22,513 -- 00:11:25,917
in the world and one of the great, great democracies of the world
00:11:25,917 -- 00:11:29,087
that Canada is, we got to be ready for everybody coming here.
00:11:29,420 -- 00:11:32,423
And that's a challenge that all of us in this room.
00:11:32,590 -- 00:11:36,461
My ask of all of you in this room is to continue working day in and day out
00:11:36,928 -- 00:11:39,931
to support this great province in the way you do.
00:11:40,898 -- 00:11:44,402
Now, I'd like to stay longer, but apparently I have to go back
00:11:44,402 -- 00:11:48,005
to Queen's Park and take some tough questions in question period.
00:11:48,406 -- 00:11:52,310
But before I do, I'm going to hop over to the TSX
00:11:52,910 -- 00:11:55,780
and I'm going to help open up the day and ring the bell.
00:11:55,780 -- 00:11:58,216
And the reason that I'm doing that is of course
00:11:58,216 -- 00:12:01,619
the Property and Developers Association of Canada Week.
00:12:02,486 -- 00:12:03,721
And why do I say all that?
00:12:03,721 -- 00:12:06,791
Because we're also very focused on the environment.
00:12:07,658 -- 00:12:10,995
We're very focused on building electric vehicles and the whole supply
00:12:10,995 -- 00:12:13,397
chain, including the critical minerals in the north
00:12:13,397 -- 00:12:17,201
right through the battery manufacturing and the assembly of electric vehicles.
00:12:18,236 -- 00:12:18,970
And it's important
00:12:18,970 -- 00:12:22,440
that we also focus on the environment
00:12:22,873 -- 00:12:26,811
as we navigate these uncertain waters and climate change.
00:12:27,178 -- 00:12:30,381
Part of the insurance I spoke with, Paul, I don't know where you are,
00:12:30,381 -- 00:12:35,319
but you're right there, talking about, catastrophic insurance.
00:12:35,953 -- 00:12:37,688
These things all intersect.
00:12:37,688 -- 00:12:41,859
And I would ask each one of you in your role, at whether you're at FSRA,
00:12:42,393 -- 00:12:46,030
and whether you're in the Pension industry, the Credit Union industry,
00:12:46,030 -- 00:12:49,100
the Life industry, the P&C industry, all the other industries that
00:12:49,100 -- 00:12:52,103
you represent here today, you're playing a role
00:12:53,104 -- 00:12:54,338
on building Ontario.
00:12:54,338 -- 00:12:58,709
You're playing a role on making and continuing to make Ontario and Canada
00:12:58,709 -- 00:13:01,145
the greatest country on the face of the earth.
00:13:01,145 -- 00:13:02,513
Thank you and have a great conference.
00:00:05,038 -- 00:00:06,239
Now I'd like to invite
00:00:06,239 -- 00:00:09,609
Mark White, FSRA CEO, to come to the stage,
00:00:10,043 -- 00:00:13,680
and he will be taking questions from Clare O'Hara, an award winning journalist
00:00:13,913 -- 00:00:17,917
for the Globe and Mail, who covers wealth management and insurance.
00:00:18,718 -- 00:00:21,755
Mark will be touching on a range of topics,
00:00:21,755 -- 00:00:25,458
and Mark always wants to have real hard questions.
00:00:25,959 -- 00:00:28,995
And then afterwards, he'll be taking questions from the audience.
00:00:28,995 -- 00:00:34,834
Just a reminder, if you've not logged in or screenshot, please do so now.
00:00:35,235 -- 00:00:38,805
And if you're not able to raise your handsFSRA staff will come
00:00:38,805 -- 00:00:41,808
and collect it over to Mark and Clare.
00:00:42,842 -- 00:00:43,443
Good morning.
00:00:43,443 -- 00:00:44,043
Good morning, Clare.
00:00:44,043 -- 00:00:44,811
How are you today?
00:00:44,811 -- 00:00:45,278
Great.
00:00:45,278 -- 00:00:48,615
And it's great to be back in person.
00:00:48,615 -- 00:00:52,151
I think we chatted a couple of years ago for the exchange and it was online,
00:00:52,685 -- 00:00:54,954
so it's fabulous to see so many faces.
00:00:54,954 -- 00:00:57,123
And welcome to everyone online as well.
00:00:57,123 -- 00:00:58,992
Haven't forgotten about you.
00:00:58,992 -- 00:01:01,327
So as you can
00:01:01,327 -- 00:01:04,330
imagine, we have a lot of sectors to hit, a lot of questions.
00:01:04,564 -- 00:01:05,532
But I did want to start off,
00:01:05,532 -- 00:01:08,534
Mark, you know, FSRA talks a lot about protecting consumers
00:01:08,668 -- 00:01:11,571
across many different sectors in the financial services.
00:01:11,571 -- 00:01:13,773
So since last year, you know, what has FSRA done
00:01:13,773 -- 00:01:17,176
that shows its commitment to hearingand acting on consumer issues?
00:01:17,176 -- 00:01:19,612
And how do you measure that success?
00:01:19,612 -- 00:01:22,615
Well, it's always difficult to measure your success with respect to consumers,
00:01:22,615 -- 00:01:27,053
but it has been since day one an important element, as Joanne
00:01:27,053 -- 00:01:30,757
said, it really is our primary object to consumer protection.
00:01:31,190 -- 00:01:32,992
And so we've continued to build on things
00:01:32,992 -- 00:01:36,596
that work for us, our Consumer Office,the Consumer Advisory Panel.
00:01:36,829 -- 00:01:40,166
Laura Tamblyn Watts the chair is here, and some of the members of Consumer
00:01:40,166 -- 00:01:43,803
Advisory Panel that continue to give us real insights and we resource them
00:01:44,037 -- 00:01:47,173
so that they're able to provide their own analysis and submissions.
00:01:47,173 -- 00:01:50,176
And I attend their meetings because I always learn from that.
00:01:50,243 -- 00:01:52,912
We continue to do things like Financial Literacy Day,
00:01:52,912 -- 00:01:55,882
Pension Awareness Day, our second Pension Awareness Day.
00:01:55,882 -- 00:01:59,685
Was this a couple of weeks ago, big successes
00:02:00,186 -- 00:02:02,855
and we've actually been realizing that we need to dig deeper.
00:02:02,855 -- 00:02:05,858
So we've been doing research on important consumer issues
00:02:06,325 -- 00:02:10,096
and that research manifests itself in how we regulate.
00:02:10,096 -- 00:02:14,267
and so auto and financial advisors andplanners, we've done research
00:02:14,567 -- 00:02:17,570
that's changing how we're supervising those sectors.
00:02:18,004 -- 00:02:21,007
In the area of consumers generally,
00:02:21,107 -- 00:02:24,777
we've identified that vulnerable consumers are at greater risk
00:02:25,178 -- 00:02:28,648
and that their relationship with their financial services providers is
00:02:28,948 -- 00:02:31,284
not one of trust and confidence.
00:02:31,284 -- 00:02:35,521
And so we've now published a planfor consultation about how we can deal
00:02:36,022 -- 00:02:39,725
with the vulnerable consumers and support them so that they feel
00:02:39,725 -- 00:02:43,162
more at ease and comfortable in dealing with institutions.
00:02:43,729 -- 00:02:48,067
Another area we've done research, really quite cutting edge on Mortgage Brokerage
00:02:48,434 -- 00:02:52,638
and we've identified there, particularlywith respect to private mortgages,
00:02:53,005 -- 00:02:54,874
that consumers need to know
00:02:54,874 -- 00:02:58,477
what their options are and what it means when they get into a private mortgage,
00:02:58,711 -- 00:03:01,714
because it's not the same as dealing with a financial institution.
00:03:01,914 -- 00:03:05,284
We've also done things like trying to inform consumers now
00:03:05,284 -- 00:03:08,521
not only on mortgages but something like financial advisors.
00:03:08,521 -- 00:03:11,524
We've just launched the what we call credential check,
00:03:11,757 -- 00:03:14,794
and that allows someone who wantsto know whether advisor or planner
00:03:15,127 -- 00:03:17,997
is actually who they are, what are their credentials.
00:03:17,997 -- 00:03:21,600
They can go to one place and basically get that information right away,
00:03:23,369 -- 00:03:24,603
other quick things
00:03:24,603 -- 00:03:28,574
we've now have because of governmentchanges that Minister Bethlenfalvy
00:03:28,574 -- 00:03:33,879
put through, we now have a fund from the monetary penalties we levy
00:03:34,347 -- 00:03:37,650
that we can use to benefit the sectors and consumers.
00:03:38,050 -- 00:03:41,887
We recently closed our first round of submissions and we're evaluating them
00:03:42,154 -- 00:03:45,057
and that will give us other ways that we can help consumers
00:03:45,057 -- 00:03:48,027
basically furthering research and education.
00:03:48,027 -- 00:03:51,497
And finally, I'll just talk for a moment about one of our great supervisory
00:03:51,497 -- 00:03:55,868
successes, the Take All Comers, which is an auto insurance issue,
00:03:56,302 -- 00:03:59,739
where auto insurers are obligated to take
00:03:59,739 -- 00:04:02,408
every customer who comes which meets the requirements.
00:04:02,408 -- 00:04:05,010
And so that has been a tremendous success for us as well.
00:04:05,010 -- 00:04:08,013
So there's been an awful lot going on at FSRA over the last year,
00:04:08,013 -- 00:04:09,749
all with the consumers in mind.
00:04:09,749 -- 00:04:10,416
Great.
00:04:10,416 -- 00:04:12,818
And you just jumped into my next section.
00:04:12,818 -- 00:04:14,753
So I definitely want to touch upon Auto Insurance.
00:04:14,753 -- 00:04:18,124
It's a section that I've started to pay more close
00:04:18,124 -- 00:04:21,760
attention to, and that's around the rising cost of auto insurance.
00:04:21,760 -- 00:04:27,166
In Ontario, car insurance rates have jumped by about 12% in the last 18 months.
00:04:27,433 -- 00:04:32,972
So that means in Ontario right now, the average premium is about $1,744.
00:04:33,272 -- 00:04:37,142
That's up from $1,555 at the end of 2021.
00:04:37,877 -- 00:04:39,945
So what is FSRA doing to make things better?
00:04:39,945 -- 00:04:41,280
And last year at the Exchange,
00:04:41,280 -- 00:04:44,350
you mentioned things around working to refine rate settings.
00:04:44,617 -- 00:04:47,353
So maybe you can touch upon the outlook for that.
00:04:47,353 -- 00:04:48,654
The rates.
00:04:48,654 -- 00:04:51,190
Yeah, I mean, costs are going up
00:04:51,190 -- 00:04:54,560
across the board, but in auto insurance, the rate of inflation
00:04:54,593 -- 00:04:58,330
is higher than other goods and services, and that's a statistical fact.
00:04:58,864 -- 00:05:01,734
Last couple of years, part of it is increased driving,
00:05:01,734 -- 00:05:04,703
but there's also basically even interest rates
00:05:04,703 -- 00:05:08,440
also affect costs in the auto sector, even in the longer term.
00:05:08,440 -- 00:05:12,011
If you look over the last, say, five years, theft has gone up.
00:05:12,378 -- 00:05:15,914
Vehicles are more expensive. Parts and labor costs more.
00:05:16,115 -- 00:05:16,982
Even rental car
00:05:16,982 -- 00:05:20,686
costs are statistically more expensive now than they were five years ago.
00:05:21,153 -- 00:05:25,424
So you talked about Ontario being up 12%, but in other jurisdictions
00:05:25,724 -- 00:05:30,329
it's up 32.9% in Québec over the last 12 months on preliminary data,
00:05:30,329 -- 00:05:35,768
25% of the Atlantic provinces and 21% in Alberta.
00:05:35,934 -- 00:05:37,469
I'm sorry, those are the five year numbers.
00:05:37,469 -- 00:05:41,373
So 32% Québec, 25% Atlantic,
00:05:41,540 -- 00:05:44,543
21% Alberta versus Ontario
00:05:44,843 -- 00:05:47,846
being up 12% in the last
00:05:48,480 -- 00:05:52,918
2023 numbers, which is preliminary, but it's still instructive.
00:05:52,918 -- 00:05:56,021
Québec was up 12.4%, Atlantic up
00:05:56,121 -- 00:05:59,291
10%, Ontario up 8%.
00:05:59,858 -- 00:06:04,830
Alberta, which actually capped its rate increases, was up 7.6%.
00:06:05,297 -- 00:06:08,901
So when I look at that, I think Ontario is actually doing both in the last year
00:06:09,201 -- 00:06:12,271
and the five years leading up to that, actually doing remarkably
00:06:12,271 -- 00:06:16,208
well because we have even greater cost pressures in many respects.
00:06:17,276 -- 00:06:20,279
We are going through a transformation and you alluded to this,
00:06:20,579 -- 00:06:23,949
it's about our rate setting and underwriting reform.
00:06:24,416 -- 00:06:27,686
And we realize that we've been in the business of approving rates
00:06:27,920 -- 00:06:31,356
instead of in the business of managing markets and consumer interests.
00:06:31,857 -- 00:06:35,294
And so what we're looking at doing is empowering consumers
00:06:35,827 -- 00:06:39,097
through making sure that insurers understand their obligation
00:06:39,097 -- 00:06:43,268
to be treating consumers fairly as well as
00:06:44,303 -- 00:06:45,437
get feedback.
00:06:45,437 -- 00:06:49,775
We want to try this as well as can you still hear me back there?
00:06:50,242 -- 00:06:54,846
But as well as making sure that insurers are aligned
00:06:54,846 -- 00:06:57,849
so that they have their systems and processes
00:06:58,183 -- 00:07:01,353
really focused on providing the best product
00:07:01,353 -- 00:07:03,488
that they can for consumers that will make sure
00:07:03,488 -- 00:07:06,525
they treat them fairly through their rates and underwriting processes.
00:07:07,259 -- 00:07:09,995
And particularly we're looking at giving consumers
00:07:09,995 -- 00:07:14,633
transparency through technology so that they'll be able to ease
00:07:14,633 -- 00:07:16,034
the burden of rate searching
00:07:16,034 -- 00:07:19,037
and make sure that they're getting the best rates which are available to them.
00:07:19,604 -- 00:07:25,210
In the end, a healthy and dynamic, competitive but regulated and supervised
00:07:25,210 -- 00:07:28,814
by FSRA market is the best alternative to keep rates down.
00:07:30,048 -- 00:07:33,018
So I want to touch upon one more thing with auto insurers.
00:07:33,018 -- 00:07:35,120
We're going to come back to fraud if we have time.
00:07:35,120 -- 00:07:36,922
But territory ratings, you know,
00:07:36,922 -- 00:07:39,424
this is also something we've talked about in previous years,
00:07:39,424 -- 00:07:40,659
and this is when someone goes to
00:07:40,659 -- 00:07:44,396
price out their auto insurance companies, look at a lot of different factors
00:07:44,396 -- 00:07:48,300
or age, gender, driving records, but they're also looking about where you live.
00:07:48,600 -- 00:07:51,670
And this is also known as postcode discrimination.
00:07:51,670 -- 00:07:54,072
And we know that many in the industry have expressed
00:07:54,072 -- 00:07:57,042
a lot of concern over postal code discrimination.
00:07:57,042 -- 00:08:01,713
And FSRA recently opened a Test and Learn Environment, allows insurers
00:08:01,713 -- 00:08:05,183
to examine ideas and innovate around the topic of territory rating.
00:08:05,450 -- 00:08:08,753
But why not just ban territory rating altogether?
00:08:08,987 -- 00:08:10,188
Isn't it just unfair?
00:08:11,156 -- 00:08:13,859
Well, actually, it's not unfair.
00:08:13,859 -- 00:08:16,528
Location is one of the primary determinants
00:08:16,528 -- 00:08:19,531
of your risk as an insured driver,
00:08:20,332 -- 00:08:23,668
your risk of theft where you drive most frequently,
00:08:23,668 -- 00:08:26,738
the density of the traffic, how good the roads are.
00:08:26,905 -- 00:08:29,474
That is all determined by where you live.
00:08:29,474 -- 00:08:33,645
And so to take geography out would mean that we would actually increase
00:08:33,879 -- 00:08:39,317
cross subsidization and we'd have rates that are less fair for many consumers.
00:08:40,118 -- 00:08:43,955
So it is the problem is, is that territories
00:08:43,955 -- 00:08:47,158
the way they were constructed based on our predecessor
00:08:47,692 -- 00:08:50,829
many years ago, 2005, they just took postal codes.
00:08:51,329 -- 00:08:53,331
And what happened is now people move
00:08:53,331 -- 00:08:57,068
literally across the street from one postal code territory to another
00:08:57,268 -- 00:09:00,271
and they can see a significant increase in rates.
00:09:00,305 -- 00:09:02,774
The Minister asked us to look at this and we have determined
00:09:02,774 -- 00:09:05,844
that that postal code based system is outdated.
00:09:06,144 -- 00:09:08,079
It needs to be changed.
00:09:08,079 -- 00:09:10,682
The problem is not that people use territory,
00:09:10,682 -- 00:09:13,685
it's that territory is not allowed to be refined
00:09:13,852 -- 00:09:17,122
based upon how the risks actually transpire in the marketplace.
00:09:18,156 -- 00:09:18,490
So what
00:09:18,490 -- 00:09:21,760
we're doing is we're allowing, using our innovation framework
00:09:22,260 -- 00:09:25,864
initially focused on the GTA, all insurers can come in
00:09:25,864 -- 00:09:29,634
and say we want to change the territories to something else
00:09:29,634 -- 00:09:32,637
that we think is data based actuarially sound,
00:09:32,670 -- 00:09:35,807
and it could be many more territories or possible that it's fewer
00:09:35,807 -- 00:09:39,210
territories or that there's some type of flexibility between territories.
00:09:39,210 -- 00:09:42,213
So it's not all black and white that moving across the street.
00:09:42,347 -- 00:09:46,551
So we're open to any suggestions and that means that consumers can then buy
00:09:46,551 -- 00:09:51,489
shopping around ultimately fine insurers with different territory patterns.
00:09:51,856 -- 00:09:54,859
So you won't have that situation when you move across the street
00:09:55,059 -- 00:09:56,094
and your rates go way up.
00:09:56,094 -- 00:09:59,764
Maybe it will be true with your insurer, but some other insurer will say that
00:09:59,764 -- 00:10:01,232
risk hasn't changed.
00:10:01,232 -- 00:10:01,966
All those issues.
00:10:01,966 -- 00:10:05,537
I talked about theft, traffic density, quality of roads,
00:10:06,037 -- 00:10:09,040
you know, the risk of you being an insured customer will be the same for you
00:10:09,040 -- 00:10:10,909
when you're on one side of the street or the other.
00:10:10,909 -- 00:10:13,912
And so we actually think that is the way to allow the market
00:10:14,012 -- 00:10:16,981
to figure it out again in a supervised fashion.
00:10:16,981 -- 00:10:18,583
And we will be able to control this
00:10:18,583 -- 00:10:21,252
through our Test and Learn Environment in our innovation framework.
00:10:21,252 -- 00:10:23,655
So we're very pleased the Minister asked us to look at this
00:10:23,655 -- 00:10:26,057
and we think this would be a tremendous improvement
00:10:26,057 -- 00:10:29,394
and we're also it can also be available to outside the GTA
00:10:29,627 -- 00:10:31,563
through the major filing process.
00:10:31,563 -- 00:10:34,799
So if you're in the GTA and you're concerned about your auto price
00:10:34,899 -- 00:10:36,968
right now, you can maybe start to even shop around.
00:10:36,968 -- 00:10:37,468
You might see
00:10:37,468 -- 00:10:41,539
some differences in those rates or is it too early quite yet to do that?
00:10:41,572 -- 00:10:43,641
Well, there's already tremendous differences in rates,
00:10:43,641 -- 00:10:46,344
so we always urge everybody to shop around.
00:10:46,344 -- 00:10:48,980
That is your best protection as a consumer.
00:10:48,980 -- 00:10:50,715
And there is something in insurance
00:10:50,715 -- 00:10:54,519
which in other jurisdictions they've actually prohibited it.
00:10:54,819 -- 00:10:56,754
But it's essentially a loyalty penalty.
00:10:57,889 -- 00:10:59,490
Insurers recognize
00:10:59,490 -- 00:11:03,261
and they do analysis on what the propensity is to renew
00:11:03,261 -- 00:11:07,598
without shopping around, and it is actually shockingly high.
00:11:08,366 -- 00:11:12,970
And so you don't get the best rate sometimes unless you do shop around
00:11:13,004 -- 00:11:15,373
because there is a certain transitive insurer
00:11:15,373 -- 00:11:18,743
might be happy with all the customers it has in a certain area. So
00:11:18,743 -- 00:11:22,380
it's not really working hard to get more customers, let's say from Mississauga.
00:11:22,880 -- 00:11:26,784
So maybe someone else, another insurer actually really wants to get more business
00:11:26,784 -- 00:11:27,785
from Mississauga
00:11:27,785 -- 00:11:30,988
and they're willing to price to get those business that business from you.
00:11:31,989 -- 00:11:32,757
Okay, I lied.
00:11:32,757 -- 00:11:35,226
I want to squeeze one more in about auto insurance here.
00:11:35,226 -- 00:11:39,430
And so last year at the FSRA Exchange, there was a discussion about health care
00:11:39,430 -- 00:11:42,700
benefits for accident victims and what gets paid to those Health
00:11:42,700 -- 00:11:45,837
Service Providers who service victims such as physiotherapists.
00:11:46,237 -- 00:11:49,841
And currently the professional services guideline does not restrict the amount
00:11:49,841 -- 00:11:52,944
that a health professional can bill a client, but it does determine
00:11:52,944 -- 00:11:57,949
the amount that an insurance company is obligated to pay a health professional
00:11:57,949 -- 00:12:00,418
for the services they provide when someone is injured
00:12:00,418 -- 00:12:01,786
and FSRA is the one who sets
00:12:01,786 -- 00:12:05,323
the fee maximums for rehabilitation services for accident victims.
00:12:05,590 -- 00:12:08,492
And that hasn't changed since 2014.
00:12:08,492 -- 00:12:11,529
And FSRA also sets the minor injury guideline
00:12:12,029 -- 00:12:15,032
establishing maximum fees to health service providers.
00:12:15,032 -- 00:12:18,069
And that guideline hasn't changed since 2014 either.
00:12:18,369 -- 00:12:20,338
And so what we're hearing from health service providers
00:12:20,338 -- 00:12:22,240
is that they're seeing that the fees are too low
00:12:22,240 -- 00:12:25,776
and they're having difficulties actually servicing accident victims.
00:12:26,110 -- 00:12:28,579
Other service providers are saying that these low rates
00:12:28,579 -- 00:12:31,582
are contributing to their desire to leave Ontario altogether.
00:12:31,816 -- 00:12:36,420
So giving your authority to adjust these fees, you know, what are you intending?
00:12:36,621 -- 00:12:38,990
Are you intending to rectify this oversight
00:12:38,990 -- 00:12:41,993
and what have you done since last year when it was first mentioned?
00:12:42,426 -- 00:12:45,429
Well, I'm not sure I agree with your assumption that this is an oversight.
00:12:45,563 -- 00:12:48,099
So we actually monitor the market.
00:12:48,099 -- 00:12:49,433
So let's give you a little bit of breakdown.
00:12:49,433 -- 00:12:54,372
First of all, the benefits to the insured, to the accident victim are controlled
00:12:54,572 -- 00:12:58,709
by the statutory SABS we call a statutory automobile benefit schedule.
00:12:58,709 -- 00:12:59,777
I think it is.
00:12:59,777 -- 00:13:05,182
And so that actually is everybody's policy so that you whether you're driving,
00:13:05,182 -- 00:13:07,017
whether you're a passenger, whether another vehicle,
00:13:07,017 -- 00:13:09,987
whether you're a pedestrian, you have coverage,
00:13:10,955 -- 00:13:12,790
that's the most important thing.
00:13:12,790 -- 00:13:15,626
What we're talking about here with the professional services guideline
00:13:15,626 -- 00:13:20,664
and the minor injury guideline is what insurers are obligated to pay
00:13:21,899 -- 00:13:22,933
is no questions asked.
00:13:22,933 -- 00:13:24,869
They don't need to
00:13:24,869 -- 00:13:26,937
be involved in providing these health
00:13:26,937 -- 00:13:29,940
care services to the Health Service Provider.
00:13:30,241 -- 00:13:33,577
And so it sets a guaranteed amount that the Health Service Provider
00:13:33,577 -- 00:13:35,446
for an insurer can get.
00:13:35,446 -- 00:13:38,682
But it actually doesn't determine what that Health Service
00:13:38,682 -- 00:13:41,919
Provider can charge if the customer wants to pay more
00:13:42,553 -- 00:13:45,623
or they could also reach out to the insurer if that's some type of
00:13:45,623 -- 00:13:49,059
special service and say we should get more because of a special situation.
00:13:49,627 -- 00:13:52,163
So what this does is it actually controls
00:13:52,163 -- 00:13:55,165
the cost in the in the system.
00:13:55,866 -- 00:13:59,203
If we actually increase the PSG or MIG,
00:14:00,604 -- 00:14:01,772
that cost will then
00:14:01,772 -- 00:14:05,876
be a legitimate cost for insurers to come back and ask for rate increases.
00:14:06,343 -- 00:14:09,179
And so what we're doing here with the consumer
00:14:09,179 -- 00:14:12,383
interest in mind is we're balancing the competing objectives
00:14:12,583 -- 00:14:17,421
of keeping rates down by keeping costs under control, but
00:14:17,421 -- 00:14:22,159
making sure that accident victims are able to get needed and timely services.
00:14:22,826 -- 00:14:26,230
And so what we monitor and we're always glad to get more information on this,
00:14:26,397 -- 00:14:29,266
is whether there's actually a shortage of supply.
00:14:29,266 -- 00:14:33,637
If accident victims are not getting timely and necessary treatment,
00:14:34,305 -- 00:14:37,574
then so this is a supply issue then demonstrably
00:14:37,574 -- 00:14:40,577
we would be very concerned and want to increase these rates.
00:14:40,978 -- 00:14:43,981
But that is essentially the balancing that we're trying to get.
00:14:43,981 -- 00:14:46,050
And this is something that, yes, we are looking at
00:14:46,050 -- 00:14:48,218
and we will probably continue to look at in the future
00:14:48,218 -- 00:14:51,388
because inflation, of course, we are sensitive that it has eaten
00:14:51,388 -- 00:14:54,391
into the income of those Health Service Providers.
00:14:54,725 -- 00:14:55,559
Great.
00:14:55,559 -- 00:14:59,730
Now moving on from auto insurance into the P&C insurance sector.
00:14:59,730 -- 00:15:04,501
So when we look at P&C Property Casualty, that does not include auto.
00:15:04,768 -- 00:15:08,872
So what is FSRA seeing that has prompted you to prioritize, prioritize home
00:15:08,872 -- 00:15:13,610
insurance claims as well as the P&C MGA supervision in the non auto sector?
00:15:13,610 -- 00:15:17,381
And I'm going to get a lot of buckets for the acronyms today.
00:15:18,015 -- 00:15:21,251
Yeah. We should probably just put in $100. I’m going to put in like $500.
00:15:21,351 -- 00:15:24,555
So just like we observed
00:15:24,555 -- 00:15:28,659
as we started to look at the distribution channels in the Life and Health market,
00:15:29,226 -- 00:15:31,929
we realized that the predecessor regulators were very much
00:15:31,929 -- 00:15:33,697
about putting out some guidance
00:15:33,697 -- 00:15:37,201
and then trying to be responsive to complaints and doing enforcement.
00:15:37,668 -- 00:15:41,638
And we've tried to build out in that barbell of regulation is the middle.
00:15:42,339 -- 00:15:43,807
And so the first thing you have to do is
00:15:43,807 -- 00:15:45,776
you have to understand what's going on in the marketplace.
00:15:45,776 -- 00:15:47,811
So just like we did with Life and Health,
00:15:47,811 -- 00:15:50,781
we're now going to start to look at the distribution channels
00:15:50,781 -- 00:15:54,151
in the P&C business to understand, because they've changed a lot
00:15:54,151 -- 00:15:57,654
since the Insurance Act was put in place many years ago and understand
00:15:57,654 -- 00:16:01,858
what is the role of MGAs, for example, in the P&C and distribution channels?
00:16:01,858 -- 00:16:03,727
What is the role of brokers?
00:16:03,727 -- 00:16:06,863
Also, we do have enough complaint information
00:16:06,863 -- 00:16:09,866
and we also look at other jurisdictions and we know
00:16:09,933 -- 00:16:13,537
at least anecdotally in Ontario, that claims are a huge issue.
00:16:13,537 -- 00:16:16,073
Now a lot of that is because of natural disasters,
00:16:16,073 -- 00:16:19,209
basically people flooding, wind, storm damage.
00:16:19,509 -- 00:16:24,014
And so we want to be on top of that issue because it is in every jurisdiction
00:16:24,014 -- 00:16:25,082
around the world right now.
00:16:25,082 -- 00:16:29,119
A big focus are claims being adjusted fairly fast
00:16:29,653 -- 00:16:33,056
payments timely, are consumers getting the coverage that they want?
00:16:33,357 -- 00:16:36,827
Exceptions and policies tend to be coming more fine tuned
00:16:36,827 -- 00:16:39,429
because insurers are paying out more on claims.
00:16:39,429 -- 00:16:43,900
So is there knowledge in the information that people understand what their policy
00:16:43,900 -- 00:16:47,504
actually covers, like water damage, whether it's flood or sewer backups?
00:16:48,338 -- 00:16:50,307
It's a very complicated area.
00:16:50,307 -- 00:16:54,144
And so we just think looking at claims, because this is obviously going
00:16:54,144 -- 00:16:58,849
to be a landmark event in someone's life when their house is severely damaged
00:16:59,816 -- 00:17:03,086
by something that's an insurable or potentially insurable event.
00:17:03,353 -- 00:17:05,021
So we want to get on top of that.
00:17:05,021 -- 00:17:08,024
We have a workplan we've put out publicly.
00:17:08,058 -- 00:17:10,727
We're very transparent about what we're going to do in this area.
00:17:10,727 -- 00:17:15,132
We think we have good support from the insurance community.
00:17:15,132 -- 00:17:17,567
They realize that this is an area we need to look at.
00:17:17,567 -- 00:17:20,303
We'll work very closely with RIBO, which is the
00:17:20,303 -- 00:17:23,340
Registered Insurance Brokers of Ontario.
00:17:23,840 -- 00:17:25,208
I think I've got that acronym right.
00:17:25,208 -- 00:17:28,812
So I have to get my $5 back if I say what it is right after I use the acronym.
00:17:28,812 -- 00:17:29,412
Okay, good.
00:17:29,412 -- 00:17:33,416
But anyway, we work because they regulate brokers
00:17:33,617 -- 00:17:36,253
and we actually supervise RIBO in that activity.
00:17:36,253 -- 00:17:39,389
So we're looking at that unfair, deceptive acts and practices.
00:17:39,389 -- 00:17:41,024
How that all fits in.
00:17:41,024 -- 00:17:42,526
It is a big area,
00:17:42,526 -- 00:17:45,996
but it's one that we realize we have to build capabilities to look at.
00:17:46,563 -- 00:17:48,632
First of all, by understanding the business practices
00:17:48,632 -- 00:17:51,334
and the consumer issues that we think might be out there.
00:17:51,334 -- 00:17:52,102
Great.
00:17:52,102 -- 00:17:55,105
I'm going to jump over to pensions because I'm watching my clock ticked down.
00:17:55,438 -- 00:17:59,209
And just quickly on pensions, you know, why is FSRA focusing its time
00:17:59,209 -- 00:18:02,979
and energy and money on jointly sponsored pension plans?
00:18:04,014 -- 00:18:04,414
Yeah, So
00:18:04,414 -- 00:18:07,417
these are the big guys, the seven large plans,
00:18:07,450 -- 00:18:12,656
but they represent about $560 billion of assets,
00:18:12,922 -- 00:18:16,426
two thirds of the assets in the pension system in Ontario.
00:18:16,693 -- 00:18:18,361
It's massive.
00:18:18,361 -- 00:18:21,998
There's close to 2 million members and beneficiaries in these plans.
00:18:22,599 -- 00:18:25,535
And so that's why we have to look at it.
00:18:25,535 -- 00:18:29,639
We have a statutory object that says we have to protect the rights
00:18:29,639 -- 00:18:32,642
and benefits of plan members
00:18:32,642 -- 00:18:35,178
that include joint sponsored pension plans.
00:18:35,178 -- 00:18:37,681
Yes, they are government sponsored organizations.
00:18:37,681 -- 00:18:39,549
They are well-run organizations.
00:18:39,549 -- 00:18:42,719
They have complicated but important governance
00:18:42,719 -- 00:18:45,722
that provides representation from their members as well.
00:18:45,789 -- 00:18:47,390
But our job under
00:18:47,390 -- 00:18:50,727
the law is to make sure that those rights and benefits are protected.
00:18:51,361 -- 00:18:53,396
And so they're complicated organizations.
00:18:53,396 -- 00:18:56,733
When you're into that many billions of dollars, those seven large plans,
00:18:56,733 -- 00:19:00,603
$560 billion, some are larger than others, but they're all very sizable.
00:19:01,671 -- 00:19:03,773
It is complex what they do.
00:19:03,773 -- 00:19:07,043
They are doing some of the most complicated investment strategies
00:19:07,043 -- 00:19:10,814
in the world private equity infrastructure, derivatives
00:19:10,814 -- 00:19:13,950
strategies, you name it, private credit.
00:19:14,617 -- 00:19:15,618
They're in it.
00:19:15,618 -- 00:19:18,955
And we don't doubt that they know what they're doing,
00:19:18,955 -- 00:19:20,323
but we know they do different things.
00:19:20,323 -- 00:19:23,560
And we also know that also sophisticated
00:19:23,560 -- 00:19:26,563
pensions have made mistakes and gotten in trouble.
00:19:26,830 -- 00:19:30,200
And they almost come back almost always come back to breakdowns
00:19:30,700 -- 00:19:32,735
in risk management and governance.
00:19:32,735 -- 00:19:36,472
And so we're going to be focusing on is that the fiduciary is in the plan.
00:19:36,472 -- 00:19:38,808
We want to be there to support them, to make sure
00:19:38,808 -- 00:19:42,612
that we form an independent view on their risk management and governance.
00:19:42,879 -- 00:19:46,449
And we think that will be of value to those fiduciaries in the plans.
00:19:46,916 -- 00:19:50,787
I know it will be of value to the members who are relying on those plans
00:19:50,987 -- 00:19:53,990
and the government sponsors, because if losses occur,
00:19:54,691 -- 00:19:59,395
either benefits go down or the sponsors or the members contributions have to go up.
00:19:59,929 -- 00:20:03,533
And we think that we want to make sure avoidable risks are avoided.
00:20:04,100 -- 00:20:06,069
Great. And I do want to remind the audience, you are able
00:20:06,069 -- 00:20:09,372
to submit your questions this year and we will have them pop up
00:20:09,372 -- 00:20:12,375
for us to ask Mark at the end of the of the session.
00:20:12,742 -- 00:20:16,179
Jumping over to Credit Unions, you know, we started off this morning
00:20:16,179 -- 00:20:18,448
with some great comments from Joanne about Credit Union,
00:20:18,448 -- 00:20:19,849
the work that you've been doing
00:20:19,849 -- 00:20:23,219
and Credit Unions are similar to banks and have bank like risks.
00:20:23,219 -- 00:20:25,988
And we have seen the recent bank failures elsewhere.
00:20:25,988 -- 00:20:29,292
But can you talk a little bit about what worries you about our Credit Unions?
00:20:30,059 -- 00:20:30,693
Well, first of all,
00:20:30,693 -- 00:20:34,797
in the context of the issues that happened in the Silicon Valley bank
00:20:34,797 -- 00:20:38,234
and the regional banks in the US, we have looked at those carefully.
00:20:38,735 -- 00:20:41,304
They essentially had fairly unique business
00:20:41,304 -- 00:20:45,141
models focused on certain sectors, technology and Silicon Valley banks.
00:20:45,141 -- 00:20:50,613
They had large uninsured deposits that weren't actually sticky,
00:20:50,613 -- 00:20:53,616
they wouldn't they didn't have reasons to stay with the business
00:20:53,883 -- 00:20:57,086
and they had liquidity management practices that were suspect,
00:20:57,420 -- 00:21:00,523
including holding, yes, what looked like very high
00:21:00,523 -- 00:21:03,626
quality securities, but they weren't marking them to market.
00:21:04,293 -- 00:21:07,163
So then when they actually had to sell those securities to get money
00:21:07,163 -- 00:21:09,265
to pay the deposits, which were starting to run
00:21:09,265 -- 00:21:12,268
because the tech companies wanted their money, then
00:21:12,268 -- 00:21:15,271
they incurred losses and all of a sudden then they had capital problems.
00:21:15,771 -- 00:21:18,174
Silicon Valley Bank didn't even have a CIRO, I don't think,
00:21:18,174 -- 00:21:21,410
for like months and months they weren't addressing regulatory issues.
00:21:21,711 -- 00:21:24,413
So there was all kinds of things that went wrong there.
00:21:24,413 -- 00:21:28,651
And I can say with confidence those issues do not exist in our credit union system.
00:21:29,018 -- 00:21:31,821
So we can park that to one side.
00:21:31,821 -- 00:21:34,056
We have stable deposits in our Credit Unions.
00:21:34,056 -- 00:21:36,459
Their business models are tried and true.
00:21:36,459 -- 00:21:38,761
Now what does worry about them?
00:21:38,761 -- 00:21:42,031
You know, it's obviously a prudential regulator at heart.
00:21:42,098 -- 00:21:45,434
I'm a worrier, but I'll just hit four quickly.
00:21:45,534 -- 00:21:48,838
One is we'd like to see profitability increase
00:21:49,205 -- 00:21:51,240
and there has been margin compression.
00:21:51,240 -- 00:21:55,177
And normally when interest rates go up, margins should go up.
00:21:55,478 -- 00:21:58,447
That hasn't happened universally across the sector.
00:21:58,447 -- 00:22:02,652
And that's troubling sometimes because we think it is because of Treasury
00:22:02,685 -- 00:22:07,189
and asset liability matching principles, what an acronym there.
00:22:08,557 -- 00:22:10,960
We're also focused on that
00:22:10,960 -- 00:22:15,264
they need to continue to invest and that creates overhead.
00:22:15,531 -- 00:22:18,801
And that sometimes is a problem if you don't have sufficient scale.
00:22:19,335 -- 00:22:21,237
And so they are competing against the banks.
00:22:21,237 -- 00:22:23,973
And so if they're going to have products and services compete,
00:22:23,973 -- 00:22:26,208
they have to invest in that.
00:22:26,208 -- 00:22:28,177
The third thing we focus on
00:22:28,177 -- 00:22:32,581
is the adequacy of the Deposit Insurance Reserve Fund and ensuring
00:22:32,581 -- 00:22:36,485
that there's access to liquidity, particularly emergency liquidity,
00:22:37,286 -- 00:22:40,823
because that is the type of thing that you actually have to have to stop
00:22:40,823 -- 00:22:43,592
a small problem from becoming a big problem
00:22:43,592 -- 00:22:47,129
that the deposit insurance reserve fund to provide confidence to depositors
00:22:47,129 -- 00:22:48,864
that they don't have to worry
00:22:48,864 -- 00:22:49,665
and the liquidity
00:22:49,665 -- 00:22:53,502
to make sure that the credit union remains open and honours obligations,
00:22:53,869 -- 00:22:57,039
even though it has illiquid assets on one side and might have
00:22:57,773 -- 00:23:00,876
demands for the deposits which far exceeds their ability
00:23:00,876 -- 00:23:03,679
to get those assets into a liquid position.
00:23:03,679 -- 00:23:06,715
And the final thing we worry about this part based on our PACE Credit
00:23:06,715 -- 00:23:09,818
Union experience is we want to make sure we have the right resolution.
00:23:09,818 -- 00:23:13,489
Authorities, our regime right now does not have all the tools
00:23:13,489 -- 00:23:17,259
that most modern resolution regimes have, and that, frankly,
00:23:17,259 -- 00:23:20,729
was an issue and delayed our ability to act with respect to PACE.
00:23:21,630 -- 00:23:23,799
So we do have some worries.
00:23:23,799 -- 00:23:26,869
I'd call those normal course of business worries for a regulator.
00:23:27,136 -- 00:23:30,139
And we're always focused on, you know, that the things can go wrong.
00:23:30,406 -- 00:23:31,574
Joanne alluded to it, though.
00:23:31,574 -- 00:23:35,544
One of the things we're not worried about is the residential mortgage portfolios,
00:23:35,844 -- 00:23:38,647
Even though they have much more flexibility than the federally
00:23:38,647 -- 00:23:41,650
regulated banks, they seem to be using that wisely.
00:23:41,917 -- 00:23:45,955
And we're not seeing lending practices which are exposing
00:23:45,955 -- 00:23:48,958
their organizations to, you know, any out of line risk.
00:23:49,091 -- 00:23:50,993
So that's a great, great news story.
00:23:50,993 -- 00:23:53,529
With the Deposit Insurance Reserve Fund last year,
00:23:53,529 -- 00:23:57,032
you said you wanted to keep a close eye on whether the fund was at the right size.
00:23:57,700 -- 00:23:59,068
Is that something you're still monitoring?
00:23:59,068 -- 00:24:01,303
Are you happy with where that is?
00:24:01,303 -- 00:24:05,240
So there's been as Credit Unions get bigger, their deposit bases get bigger.
00:24:05,240 -- 00:24:07,643
And so there has been a historic 100
00:24:07,643 -- 00:24:11,313
basis points of deposit target for the DIRF.
00:24:11,447 -- 00:24:15,217
We've applied some very, I think, good statistical analysis
00:24:15,217 -- 00:24:17,953
to that based upon some of that data that Joanne was talking about,
00:24:17,953 -- 00:24:19,822
where we actually get into the large Credit Unions,
00:24:19,822 -- 00:24:23,325
We actually can we can stress their loan portfolios.
00:24:23,659 -- 00:24:24,727
So that's really remarkable.
00:24:24,727 -- 00:24:27,229
I think that's even better than they can do at the federal level.
00:24:27,229 -- 00:24:30,466
And so based upon that, we believe and we what we're having,
00:24:30,499 -- 00:24:32,668
we're just starting a discussion now with the sector
00:24:32,668 -- 00:24:34,703
that the DIRF it's in the interest of the sector
00:24:34,703 -- 00:24:36,605
because they are obviously co-insure each other.
00:24:36,605 -- 00:24:39,608
We believe there are a different DIRF target is appropriate.
00:24:39,908 -- 00:24:41,343
We have some external advice on that.
00:24:41,343 -- 00:24:43,612
We're sharing with the sector and we're going to work through that
00:24:43,612 -- 00:24:45,047
and hopefully come to a consensus
00:24:45,047 -- 00:24:48,050
with the sector and then go to the government together.
00:24:48,050 -- 00:24:48,717
Great.
00:24:48,717 -- 00:24:53,355
Moving on to Life and Health Insurance, as pointed out this morning as well,
00:24:53,355 -- 00:24:56,358
we have seen FSRA take some enforcement action in this sector.
00:24:56,558 -- 00:24:59,661
Now, how serious is FSRA about taking sufficient measures
00:24:59,661 -- 00:25:03,432
to prevent misselling and other consumer harms in this channel?
00:25:03,432 -- 00:25:06,535
And I do want to point out something that that was raised last year,
00:25:06,535 -- 00:25:11,139
and this is around what we call orphan Life Insurance policyholders.
00:25:11,340 -- 00:25:15,978
And this is where policyholders won't be serviced by their life agents
00:25:15,978 -- 00:25:18,814
because they've either retired or left the industry.
00:25:18,814 -- 00:25:23,151
And so they're orphaned because they're not able to track down their policies
00:25:23,151 -- 00:25:26,154
or they're not able to their families can't get a payout.
00:25:26,188 -- 00:25:27,155
So maybe you can talk a little bit
00:25:27,155 -- 00:25:30,158
about how that kind of comes into consumer harm as well.
00:25:30,659 -- 00:25:34,863
So I alluded earlier to our review of distribution channels and Life and Health,
00:25:35,297 -- 00:25:39,201
which made us realize that MGA is managing generally agents are playing
00:25:39,201 -- 00:25:44,106
a very important role and there's multiple levels of agents between the insurer
00:25:44,106 -- 00:25:47,109
and the agent who actually is the sales agent to the customer.
00:25:47,709 -- 00:25:52,214
We also identified through that that there were practices where complex
00:25:52,214 -- 00:25:56,018
products like Universal Life, which are great for a sophisticated,
00:25:56,018 -- 00:25:59,554
wealthy individual who used up their all their existing tax advantages
00:25:59,888 -- 00:26:02,958
and is doing estate planning, were being sold to people
00:26:02,958 -- 00:26:07,029
who were in lower socioeconomic situations and could not sustain that.
00:26:07,329 -- 00:26:09,631
And then when the policy lapses,
00:26:09,631 -- 00:26:12,634
all the upfront money they paid basically goes to fees.
00:26:13,235 -- 00:26:17,305
We consider that to be an unacceptable practice and I think most insurers do too.
00:26:18,039 -- 00:26:21,610
And so we realized that we need to use the tools that we have.
00:26:21,943 -- 00:26:25,046
We've put out guidance on what is suitable.
00:26:25,046 -- 00:26:29,584
If you are an agent, and that's the sales agent as well as the MGA,
00:26:29,618 -- 00:26:34,389
who is a type of agent, recognizing the insurers have an obligation.
00:26:34,489 -- 00:26:37,492
The phrase in the law is a reasonable system of compliance
00:26:37,692 -- 00:26:41,830
to make sure that they know what's happening in their channels.
00:26:42,497 -- 00:26:46,401
And our view is where an MGA takes on delegated functions
00:26:46,401 -- 00:26:50,305
such as the recruitment, the training, the oversight of agents, that they then
00:26:50,305 -- 00:26:51,640
should have the same obligation
00:26:51,640 -- 00:26:54,643
to make sure that they have a reasonable system of compliance,
00:26:54,643 -- 00:26:59,648
not that it relieves the insurer their responsibility, but a delegated function.
00:26:59,648 -- 00:27:02,050
They need to make sure that the marketplace is working
00:27:02,050 -- 00:27:04,653
and those agents are properly trained and supervised.
00:27:05,720 -- 00:27:06,288
There's also a
00:27:06,288 -- 00:27:10,125
discussion which we're happy to have comments on, is
00:27:10,358 -- 00:27:14,162
Can you be a suitable agent or suitable MGA overseeing agents?
00:27:14,362 -- 00:27:16,798
If you're selling unsuitable products?
00:27:16,798 -- 00:27:18,533
And so even though we don't have
00:27:18,533 -- 00:27:21,536
quite the suitability regime that exists in some other jurisdictions,
00:27:22,337 -- 00:27:25,240
I think there is an argument to be made that you can't be a suitable agent
00:27:25,240 -- 00:27:29,177
or a suitable MGA if you are in the business of selling unsuitable products.
00:27:29,611 -- 00:27:32,314
So that is something we're going to work on
00:27:32,314 -- 00:27:34,416
with effect to orphan policies.
00:27:34,416 -- 00:27:38,453
There's I think about $4.6 million life policies in Ontario.
00:27:39,788 -- 00:27:43,725
Most of the incentives are upfront, so the fees are paid upfront.
00:27:44,059 -- 00:27:45,560
And yes, that does lead to
00:27:45,560 -- 00:27:48,763
what they call orphan policies where someone leaves the business.
00:27:49,631 -- 00:27:52,600
Now, there is actually tremendous value in that book of business,
00:27:52,600 -- 00:27:55,603
and so we don't actually get a lot of complaints about orphan policies.
00:27:56,137 -- 00:27:58,907
And I believe that's because generally the book of business has value
00:27:58,907 -- 00:28:00,308
and gets sold to somebody.
00:28:00,308 -- 00:28:03,478
So it actually is picked up by an agent who wants to basically contact
00:28:03,478 -- 00:28:05,880
that customer and see if their needs have changed.
00:28:05,880 -- 00:28:08,883
So there's more insurance that could be purchased.
00:28:09,217 -- 00:28:13,188
And also, we think insurers do try to if there is an orphan client,
00:28:13,188 -- 00:28:15,924
they try to get an agent that will cover it. They use their own
00:28:17,225 -- 00:28:18,126
call centers to
00:28:18,126 -- 00:28:21,129
provide some basic advice on policy administration.
00:28:21,196 -- 00:28:24,732
And ultimately the insurer is in that contract with the customer.
00:28:24,933 -- 00:28:28,636
And the loss of the agent actually doesn't change the terms of the policy.
00:28:28,736 -- 00:28:30,638
So all the benefits are still there.
00:28:30,638 -- 00:28:33,441
So it is something that the market does not function well.
00:28:33,441 -- 00:28:37,412
If agents are leave and are not replaced.
00:28:37,812 -- 00:28:41,115
But the reason they don't is because then the advice is not provided.
00:28:41,115 -- 00:28:43,651
Life Insurance is complicated.
00:28:43,651 -- 00:28:46,421
That's why agents get compensation.
00:28:46,421 -- 00:28:50,592
And so, it leads to what is the right incentive commission model.
00:28:50,992 -- 00:28:54,395
And the ideal one would be one where the advisor has an incentive
00:28:54,562 -- 00:28:55,730
and this could be you
00:28:55,730 -- 00:28:58,733
pay a fee for financial advice generally to a planner
00:28:58,866 -- 00:29:00,635
where you have a continuing relationship with them.
00:29:00,635 -- 00:29:02,170
That is the Cadillac.
00:29:02,170 -- 00:29:04,839
The truth is that that model probably doesn't work
00:29:04,839 -- 00:29:08,109
for people who aren't willing to pay that type of fee upfront or don't have
00:29:08,376 -- 00:29:11,412
the size of portfolio insurance needs to justify that.
00:29:11,746 -- 00:29:14,048
So we watch that part of the market very carefully.
00:29:14,048 -- 00:29:17,051
But as they say, it's surprising we don't get that many complaints
00:29:17,051 -- 00:29:20,288
in the area because I was going to bring up the compensation of
00:29:21,422 -- 00:29:22,357
the commissions that are paid
00:29:22,357 -- 00:29:25,360
because you're right, these are sort of policies are sold,
00:29:26,461 -- 00:29:29,230
the commissions are paid out when they sell it
00:29:29,230 -- 00:29:31,099
and it's not really paid out to service.
00:29:31,099 -- 00:29:33,634
And so I have spoken to a lot of financial advisors.
00:29:33,634 -- 00:29:38,172
To your point, they service these clients as a courtesy
00:29:38,406 -- 00:29:41,743
and then they kind of hope that maybe they'll be able to cross-sell.
00:29:42,210 -- 00:29:46,047
So do you think the industry would ever take a look at the way
00:29:46,047 -- 00:29:49,117
and this is a huge thing to change the way that you're compensated
00:29:49,117 -- 00:29:50,752
on a life insurance policy.
00:29:50,752 -- 00:29:52,587
But, you know, do you think it's right that commissions are paid
00:29:52,587 -- 00:29:56,991
to the agent who sold it and the residuals continue to be sold to that person,
00:29:57,258 -- 00:30:00,428
whether they're retired unless an insurance company intervenes and
00:30:00,928 -- 00:30:01,929
can collect those.
00:30:01,929 -- 00:30:03,731
But as far as I'm concerned, it
00:30:03,731 -- 00:30:06,734
there's a lot of retired people who still collect those small residuals.
00:30:06,934 -- 00:30:10,905
Is there a way the industry could perhaps redirect those residuals?
00:30:11,839 -- 00:30:15,109
Well, I think that is an important issue.
00:30:15,109 -- 00:30:19,547
And there is incentives guidance that we're looking at with our
00:30:20,314 -- 00:30:21,616
Canadian Council of Insurance Regulators.
00:30:21,616 -- 00:30:26,721
So it is an active topic for discussion, but it is very important that we allow
00:30:26,721 -- 00:30:31,559
for a sufficient upfront incentive so that people get the advice
00:30:31,559 -- 00:30:35,863
so they can know what their insurance needs are as well as the second piece.
00:30:35,863 -- 00:30:36,697
What you're getting at
00:30:36,697 -- 00:30:40,401
is making sure that there's the incentive to provide ongoing advice.
00:30:40,535 -- 00:30:43,871
And so that is a careful balancing act when you actually want
00:30:43,871 -- 00:30:46,974
to also minimize in the consumer interests our number one objective.
00:30:47,308 -- 00:30:49,944
You want to minimize the amount of fees that they're paying.
00:30:51,078 -- 00:30:53,147
So there's some balancing there.
00:30:53,147 -- 00:30:54,415
It's a tough one.
00:30:54,415 -- 00:30:56,951
And just finally, to jump back to the MGA channel,
00:30:56,951 -- 00:31:00,187
if MGAs have increased conduct requirements
00:31:00,187 -- 00:31:03,958
such as becoming a license class, will that let insurers off the hook?
00:31:04,759 -- 00:31:07,728
Well, I don't think it ever can, because the contract is
00:31:07,728 -- 00:31:10,731
between the insurer and the end customer.
00:31:10,798 -- 00:31:14,335
It's not like a securities where it is a different a separate instrument
00:31:14,669 -- 00:31:18,739
that is basically created by an issuer or sold by a distributor.
00:31:19,006 -- 00:31:21,242
And then it actually has sort of life outside.
00:31:21,242 -- 00:31:22,977
This is an ongoing contract,
00:31:22,977 -- 00:31:25,980
a contract of utmost good faith between the insurer and the customer.
00:31:26,380 -- 00:31:31,419
And so I think insurers always have to be responsible for their contract
00:31:31,752 -- 00:31:35,690
and through for how it's distributed and how they administer it over the term.
00:31:36,457 -- 00:31:39,760
That reasonable system of compliance doesn't have any exception for that.
00:31:40,161 -- 00:31:44,665
I will say that if to the extent we get more tools over MGAs,
00:31:45,066 -- 00:31:49,336
we'll actually have another way to regulate and get to the conduct
00:31:49,336 -- 00:31:52,673
that we want to see, and then obviously we won't have to put
00:31:52,673 -- 00:31:57,478
maybe as much pressure on insurers because if the MGA is the one
00:31:57,478 -- 00:32:01,415
supervising the agent where we see issues and we can go to that MGA
00:32:01,449 -- 00:32:05,319
and we can get that remedied, that'll be probably more effective than us
00:32:05,319 -- 00:32:07,755
go to the insurer who then
00:32:07,755 -- 00:32:10,825
uses its influence on the MGA and say there could be multiple tiers of MGA.
00:32:10,825 -- 00:32:14,462
So we it's much better if we can do that directly.
00:32:14,462 -- 00:32:17,431
But no, I think it's always going to be appropriate for the insurer
00:32:17,431 -- 00:32:19,099
to have that continuing obligation
00:32:19,099 -- 00:32:22,503
for its sales channels, because if it is the one in the contract.
00:32:23,070 -- 00:32:27,174
Great. Moving over to financial planners and financial advisers,
00:32:27,441 -- 00:32:30,444
also an area that I have been keeping a close eye on,
00:32:30,711 -- 00:32:33,480
many in the investment community is watching it closely, and this is around
00:32:33,480 -- 00:32:39,220
Ontario's Financial Professionals Title Protection Act that was passed in 2019,
00:32:39,220 -- 00:32:42,223
and that requires anyone in the province that wants to use a title,
00:32:42,256 -- 00:32:46,060
financial adviser or financial planner to obtain appropriate credentials
00:32:46,293 -- 00:32:47,695
from an approved provider.
00:32:47,695 -- 00:32:49,029
And since the bill passed,
00:32:49,029 -- 00:32:52,333
you know, FSRA has approved several credentialing bodies,
00:32:52,600 -- 00:32:55,402
and most recently they approved the Canadian Investment
00:32:55,402 -- 00:32:58,672
Regulatory Organization, which I'm going to refer to as CIRO.
00:32:59,006 -- 00:33:02,409
And that's caused a lot of concern for investor advocates,
00:33:02,409 -- 00:33:04,511
particularly around mutual fund licensed advisors.
00:33:04,511 -- 00:33:09,116
So why is FSRA allowing tens of thousands of individuals who are registered by CIRO
00:33:09,116 -- 00:33:12,820
but many considered to be salespeople to use the financial advisor title?
00:33:13,821 -- 00:33:14,722
We're doing it because it
00:33:14,722 -- 00:33:17,725
is demonstrably in the consumer interest
00:33:17,825 -- 00:33:21,762
and it is completely aligned with the regime that exists in law
00:33:21,762 -- 00:33:24,998
and the one that we heavily consulted on in our rules and our guidance.
00:33:25,632 -- 00:33:26,533
So let me take you back.
00:33:26,533 -- 00:33:29,536
Before this regime existed,
00:33:29,737 -- 00:33:32,773
anyone could use the title Financial Advisor, a Planner,
00:33:33,407 -- 00:33:37,077
no education, no credentials, no complaint, no discipline.
00:33:37,878 -- 00:33:40,114
Anybody could use that.
00:33:40,114 -- 00:33:43,117
So everyone agrees that's not good.
00:33:43,150 -- 00:33:46,153
Then let me take you before we had CIRO approved,
00:33:46,420 -- 00:33:49,990
so we now had credentialing bodies and they would basically say,
00:33:50,290 -- 00:33:52,593
we have a course, we have a program we're going to supervise.
00:33:52,593 -- 00:33:55,362
We're going to give it a title credential to this person,
00:33:55,362 -- 00:33:58,365
and they can become a financial advisor or a financial planner.
00:33:58,432 -- 00:34:02,636
But CIRO also had a huge body,
00:34:02,769 -- 00:34:05,772
a larger body of financial advisors than we had.
00:34:06,206 -- 00:34:09,009
They were using sometimes using a Financial Advisor title
00:34:09,009 -- 00:34:12,179
because they were grandfathered or they had a separate credential,
00:34:12,479 -- 00:34:15,849
but in many cases they could also just use the term investment advisors.
00:34:16,350 -- 00:34:18,252
So then we'd have consumers out there going
00:34:18,252 -- 00:34:20,020
Financial Advisor, Investment Advisor.
00:34:20,020 -- 00:34:22,523
What's the difference? They go to our credential check.
00:34:22,523 -- 00:34:25,192
If CIRO is not there, they're not able to find out that
00:34:25,192 -- 00:34:28,228
this person is a mutual fund
00:34:29,396 -- 00:34:31,331
salesperson,
00:34:31,331 -- 00:34:31,732
right?
00:34:31,732 -- 00:34:34,101
And get that knowledge, just go. It's an investment, right?
00:34:34,101 -- 00:34:36,436
There's and they're regulated by CIRO.
00:34:36,436 -- 00:34:37,638
But why CIRO?
00:34:37,638 -- 00:34:38,639
Will CIRO is actually
00:34:38,639 -- 00:34:41,875
the gold standard for many of the things we want to see in credentialing bodies.
00:34:42,409 -- 00:34:46,013
They're overseen by the OSC and the Canadian Securities Administrators.
00:34:46,546 -- 00:34:50,917
They have a very highly developed conduct and discipline framework.
00:34:51,551 -- 00:34:54,421
So the people that are in the CIRO framework,
00:34:54,421 -- 00:34:57,324
yes, they are well overseen, well regulated.
00:34:57,324 -- 00:35:00,394
The issue that some of the consumer advocates have and this is kind of
00:35:00,394 -- 00:35:04,398
like when you give something somebody and they always want more, I understand it.
00:35:05,365 -- 00:35:08,368
They're concerned that some CIRO
00:35:08,802 -- 00:35:11,004
basically licensees
00:35:11,004 -- 00:35:14,007
are basically looking at mutual funds as a sole product.
00:35:14,341 -- 00:35:17,344
But by being in our regime, they have a professional
00:35:17,577 -- 00:35:21,048
code of conduct, of ethics, minimum standards of competency.
00:35:21,048 -- 00:35:24,051
They have to not only understand their product that they sell,
00:35:24,184 -- 00:35:27,421
but they have a responsibility to understand alternative products.
00:35:28,021 -- 00:35:30,624
And I actually think that this is a good sign that CIRO
00:35:30,624 -- 00:35:31,391
the fact that they're willing
00:35:31,391 -- 00:35:34,394
to come into our regime knowing that that is the case,
00:35:34,761 -- 00:35:38,398
there's an opportunity for everybody to bring up the bottom
00:35:38,398 -- 00:35:42,302
end of that competency so that maybe you are only selling mutual funds,
00:35:42,636 -- 00:35:46,139
but you are supposed to be able to say, you know, in your circumstances,
00:35:46,139 -- 00:35:48,074
maybe you need to start buying ETFs
00:35:48,074 -- 00:35:51,077
or stocks or bonds or seek other diversification.
00:35:51,144 -- 00:35:54,147
So we want to get the marketplace to that point in time.
00:35:54,447 -- 00:35:57,918
By having CIRO in, we remove the consumer confusion.
00:35:58,318 -- 00:36:00,787
We have the ability now to get the best out of CIRO
00:36:00,787 -- 00:36:04,491
and bring the other credential bodies up to their standards where they're higher.
00:36:04,891 -- 00:36:06,960
And we'll bring worked with CIRO
00:36:06,960 -- 00:36:08,395
to bring its standards up
00:36:08,395 -- 00:36:10,564
to the higher standards of the other credentialing bodies,
00:36:10,564 -- 00:36:11,665
where they're greater.
00:36:11,665 -- 00:36:14,801
So I think it's to everyone's advantage and it also
00:36:15,535 -- 00:36:18,405
dramatically reduces the startup costs that are being charged
00:36:18,405 -- 00:36:21,808
to credentialing bodies, which I also think is in the interest of those bodies.
00:36:21,975 -- 00:36:23,143
And of course, all their members,
00:36:23,143 -- 00:36:26,947
because their members are the ones who ultimately pay is their concern,
00:36:27,414 -- 00:36:32,419
because CIRO does oversee two different types of advisors is a security license
00:36:32,419 -- 00:36:35,422
and what used to be known as the IROC channel.
00:36:35,455 -- 00:36:38,792
And there's a mutual fund channel concerned that someone may think they're
00:36:38,792 -- 00:36:43,363
talking to a securities licensed adviser, which is very different type of advice.
00:36:44,130 -- 00:36:46,232
Well, that concern exists today, though.
00:36:46,232 -- 00:36:50,337
And so by being in our regime now, because we consulted on this
00:36:50,337 -- 00:36:53,340
and this was broadly supported, is that, yes,
00:36:53,406 -- 00:36:57,877
the MFDA level should be qualified for financial advisors,
00:36:58,378 -- 00:37:01,548
but whenever they're using their credential
00:37:01,981 -- 00:37:03,850
or they're using the title Financial Adviser,
00:37:03,850 -- 00:37:06,386
they also have to say what their credential is.
00:37:06,386 -- 00:37:09,389
It will be apparent through the credential check tool we give
00:37:09,589 -- 00:37:14,094
so that that a consumer can easily find out that that person is different
00:37:14,094 -- 00:37:15,695
than someone who can give a full advice on
00:37:15,695 -- 00:37:19,399
stocks and bonds and investments versus the mutual fund channel only.
00:37:19,666 -- 00:37:22,669
And so that consumer transparency is very important.
00:37:22,702 -- 00:37:26,740
I could do a whole panel on this, so I'll flip over to mortgage
00:37:26,740 -- 00:37:29,976
brokers and then we're going to see if we can get to some audience questions.
00:37:30,210 -- 00:37:33,680
Obviously, a big topic in Canada right now is with housing prices,
00:37:33,947 -- 00:37:36,783
mortgage affordability and availability is a big issue.
00:37:36,783 -- 00:37:40,386
Are you concerned that this will cause increased risks and conduct
00:37:40,386 -- 00:37:43,389
issues in residential mortgages?
00:37:43,456 -- 00:37:45,158
Yeah, well, it always does.
00:37:45,158 -- 00:37:45,492
Every time
00:37:45,492 -- 00:37:49,529
there's stress in the marketplace, there's incentive for aberrant behaviors
00:37:49,896 -- 00:37:52,265
and also part of it is like Warren Buffett said,
00:37:52,265 -- 00:37:54,834
“when the tide goes out, you see who's been swimming naked.”
00:37:54,834 -- 00:37:59,172
So there will be people who will do fraud for mortgage
00:37:59,172 -- 00:38:02,342
because that's the only way they can get their house or keep their house.
00:38:03,042 -- 00:38:06,479
And so they will shade the information to try
00:38:06,479 -- 00:38:09,482
and do what they have to do and what we're concerned.
00:38:09,549 -- 00:38:12,252
about is the mortgage brokers that we supervise.
00:38:12,252 -- 00:38:15,154
Their volumes are always going to go down and they also
00:38:15,154 -- 00:38:18,191
will want to try and help that person who's having trouble getting a mortgage.
00:38:18,625 -- 00:38:19,659
And so it may even
00:38:19,659 -- 00:38:23,463
be out of good intentions, but they may not they may cut some corners
00:38:23,463 -- 00:38:26,766
in not providing the full information package to the financial institution.
00:38:27,200 -- 00:38:29,269
So we are concerned about from that perspective.
00:38:29,269 -- 00:38:30,803
We're also concerned about it
00:38:30,803 -- 00:38:34,374
from the increasing amount we're seeing in the private mortgage market.
00:38:34,974 -- 00:38:36,576
And we've put an education on that.
00:38:36,576 -- 00:38:39,045
A private mortgage is not a long term solution.
00:38:39,045 -- 00:38:41,848
They're shorter term, they're higher cost.
00:38:41,848 -- 00:38:45,218
They are not a way that you're going to end up owning a house after 25 years.
00:38:45,885 -- 00:38:49,022
It is a if it's a bridge to somewhere to a sale,
00:38:49,355 -- 00:38:52,725
to basically establishing your income so that you can get a more
00:38:52,725 -- 00:38:55,762
routine mortgage at better rates, longer terms.
00:38:56,229 -- 00:38:59,265
It is a viable alternative and so we've put out
00:38:59,399 -- 00:39:02,535
information for that for users of private mortgages.
00:39:02,802 -- 00:39:06,939
We've created a private mortgage agent licensing tier
00:39:06,939 -- 00:39:09,942
because they should have extras skills and experience,
00:39:09,942 -- 00:39:11,644
because you have to remember they're also dealing with
00:39:11,644 -- 00:39:14,647
not a sophisticated institution that protects themselves.
00:39:14,947 -- 00:39:17,250
They're dealing then with private investors.
00:39:17,250 -- 00:39:19,419
And so those private investors are also at risk.
00:39:19,419 -- 00:39:20,887
There's been some things in the paper
00:39:20,887 -- 00:39:23,890
you can see how quickly that some of these deals can go bad.
00:39:23,990 -- 00:39:25,158
And there is a history of that.
00:39:25,158 -- 00:39:28,628
So we've worked very hard to make sure that not only are we helping
00:39:28,961 -- 00:39:33,099
borrowers get access, private mortgages as well as institutional mortgages,
00:39:33,666 -- 00:39:38,137
but investors can protect themselves if they're going to participate in that
00:39:38,137 -- 00:39:41,474
because it is a higher yield but higher risk.
00:39:42,742 -- 00:39:43,509
And we end it
00:39:43,509 -- 00:39:47,780
exactly on the zero we're going to see I'm assuming it's going to pop up here.
00:39:47,780 -- 00:39:49,682
The questions.
00:39:49,682 -- 00:39:52,685
there we go.
00:39:52,885 -- 00:39:57,924
Is FSRA are working with the Ministry of Finance to modernize the Insurance Act.
00:39:57,924 -- 00:40:01,527
And this includes regulating unlicensed insurance intermediaries
00:40:01,527 -- 00:40:04,530
and updating the fire part of the act
00:40:05,965 -- 00:40:08,968
fire part of the act.
00:40:09,368 -- 00:40:11,203
I'm not quite sure what that is.
00:40:11,203 -- 00:40:13,973
If it's about the fire mutuals.
00:40:13,973 -- 00:40:16,976
That could be what it's about.
00:40:17,076 -- 00:40:19,812
I never thought that out of the fire part of the act.
00:40:19,812 -- 00:40:22,682
So the decision on
00:40:22,682 -- 00:40:26,285
what legislation will be amended is a government decision.
00:40:26,419 -- 00:40:30,556
We provide our advice to the ministry on where we think it is appropriate
00:40:30,556 -- 00:40:32,491
that there should be action taken.
00:40:32,491 -- 00:40:36,062
I do think that the Insurance Act in Ontario, when it compared
00:40:36,062 -- 00:40:39,498
to some of our provincial peers or federal, there it is.
00:40:39,565 -- 00:40:42,068
There are sections that are in need of an update.
00:40:42,068 -- 00:40:45,037
For example, we talked about the absence of an MGA licensing class
00:40:45,037 -- 00:40:48,040
when most insurance is now distributed through MGAs.
00:40:48,307 -- 00:40:52,044
So we do think that, you know, we're on record saying that, yes,
00:40:52,044 -- 00:40:55,681
this is something we should look at, but we do have existing regulatory tools
00:40:55,681 -- 00:40:58,150
and we will use those existing regulatory tools
00:40:58,150 -- 00:41:01,754
regardless of whether the Insurance Act is updated, because we have
00:41:01,754 -- 00:41:04,156
we have to protect the consumers and make the market function.
00:41:04,156 -- 00:41:05,658
But yes, I,
00:41:05,658 -- 00:41:07,660
I certainly think the minister wouldn't
00:41:07,660 -- 00:41:12,098
be shocked if I was on record saying that the Insurance Act is a piece
00:41:12,098 -- 00:41:15,201
of legislation that could probably use a review in the near future.
00:41:16,836 -- 00:41:19,772
Our next question is can a Credit Union access
00:41:19,772 -- 00:41:24,810
emergency liquidity through the Deposit Insurance Relief Fund?
00:41:24,810 -- 00:41:26,912
I read that out. It was an acronym.
00:41:26,912 -- 00:41:31,016
If there was a very short term crisis, this person is asking for a friend.
00:41:31,584 -- 00:41:34,620
Well, let's hope
00:41:34,620 -- 00:41:37,623
that friend isn't a Credit Union.
00:41:38,357 -- 00:41:42,394
So we do actually have an incredible amount of flexibility
00:41:42,394 -- 00:41:46,498
under the Credit Union Cassie Populaire Act to use the DIRF to provide
00:41:46,498 -- 00:41:50,336
financial assistance where we think it's in the overall interest.
00:41:50,569 -- 00:41:53,572
So our objects are to minimize loss to the DIRF.
00:41:53,572 -- 00:41:55,841
So basically, if it's a little bit of money now
00:41:55,841 -- 00:41:57,776
will avoid a bigger problem later.
00:41:57,776 -- 00:42:01,747
Our objects are also good financial stability, strong, stable sector.
00:42:02,114 -- 00:42:05,718
So we will actually use the DIRF we have we're empowered to do that
00:42:05,718 -- 00:42:07,253
in a creative way.
00:42:07,253 -- 00:42:11,857
In the PACE Credit Union, for example, we actually did provide a backstop
00:42:11,857 -- 00:42:15,527
liquidity facility so that the members of PACE Credit Union,
00:42:15,527 -- 00:42:17,229
even when it was going through its turmoil,
00:42:17,229 -- 00:42:21,200
we put $500 million on the line for a, you know, less than $1,000,000,000
00:42:21,200 -- 00:42:21,700
Credit Union.
00:42:21,700 -- 00:42:23,135
So that's a lot of money.
00:42:23,135 -- 00:42:24,903
But we wanted to know that there was
00:42:26,372 -- 00:42:28,574
a big gun there if it was ever necessary,
00:42:28,574 -- 00:42:31,577
so they didn't have to worry that there was going to be a liquidity problem.
00:42:31,644 -- 00:42:34,980
So we are willing to use the DIRF we also it's a matter of public record,
00:42:35,014 -- 00:42:38,951
have a 2 billion line of credit from the provincial government
00:42:39,184 -- 00:42:42,187
that we could also use that to supplement if we needed more funds.
00:42:42,254 -- 00:42:45,324
You know, it's just one of those things you want to have the trucks
00:42:45,324 -- 00:42:49,128
in the firehouse and we are looking at getting
00:42:50,062 -- 00:42:54,500
proper access to emergency liquidity with the Bank of Canada through its
00:42:54,500 -- 00:42:59,805
lending programs, including emergency lending or liquidity assistance.
00:42:59,805 -- 00:43:01,874
And that is something that has been facilitated
00:43:01,874 -- 00:43:05,477
by the federal government by recent changes to the Payments Canada Act.
00:43:05,878 -- 00:43:09,348
So we do care very deeply about these issues and we
00:43:09,348 -- 00:43:12,351
but we do think that there is adequate liquidity and we do have the
00:43:12,851 -- 00:43:16,555
legal tools to be able to use it to provide that short term funding.
00:43:17,556 -- 00:43:18,757
And the next question is
00:43:18,757 -- 00:43:22,327
the regulatory response to AI may take some time to finalize.
00:43:22,594 -- 00:43:25,898
Many businesses will make large investments over the next short time
00:43:26,131 -- 00:43:27,799
into these types of technologies.
00:43:27,799 -- 00:43:31,403
How we're financial service businesses expected to make these investments
00:43:31,670 -- 00:43:36,308
while moderating concerns over moderating concerns that technology or features
00:43:36,308 -- 00:43:40,512
will eventually be prohibited subsequent to investment or implementation.
00:43:41,580 -- 00:43:44,650
Well, the issue of investment in technology
00:43:44,816 -- 00:43:48,086
will be prohibited it is a difficult one for us to manage
00:43:48,086 -- 00:43:51,623
because a lot of that prohibition will not be by us as a regulator.
00:43:51,623 -- 00:43:56,495
It is possible, but most of that's probably in what is a fair use of data.
00:43:56,495 -- 00:43:59,531
What types of algorithms are, let's say, discriminatory.
00:43:59,898 -- 00:44:05,537
And so it gets into things that we may not be the person prohibiting it.
00:44:06,371 -- 00:44:09,374
So it is up to the financial institutions to basically
00:44:09,608 -- 00:44:12,577
go down the AI and the data path wisely.
00:44:13,178 -- 00:44:16,281
A few years ago, I was actually responsible at
00:44:16,448 -- 00:44:18,784
one of the big banks here for overseeing all their models.
00:44:18,784 -- 00:44:20,919
So this isn't really new.
00:44:20,919 -- 00:44:24,823
I know it's in the press a lot now, but models that learned from themselves
00:44:24,823 -- 00:44:27,693
and from data and information have been around for years.
00:44:27,693 -- 00:44:31,430
And models based upon consumer information were being used
00:44:31,463 -- 00:44:35,033
and by large financial institutions in this country for many years.
00:44:35,467 -- 00:44:38,470
So these are not new issues.
00:44:38,904 -- 00:44:41,907
What is new is the breadth of the application
00:44:41,907 -- 00:44:45,577
and how in-your-face it is when you're seeing things like, you know,
00:44:45,644 -- 00:44:49,714
ChatGPT, just sort of those things that have learned from learning
00:44:49,714 -- 00:44:51,483
from huge databases.
00:44:51,483 -- 00:44:54,052
So I think these issues will continue to evolve,
00:44:54,052 -- 00:44:57,556
but I think it's mostly not the conduct and prudential regulator,
00:44:57,589 -- 00:45:00,592
although we would have concerns if we thought were privacy abuses,
00:45:00,725 -- 00:45:03,962
but we'll be the privacy regulator that the consumer data regulators,
00:45:04,262 -- 00:45:08,166
they're going to be the ones that are most creating the boundaries.
00:45:08,166 -- 00:45:12,070
And it is true there is uncertainty because people will need protection
00:45:12,070 -- 00:45:15,340
from issues which we probably haven't fully appreciated at this point.
00:45:16,208 -- 00:45:19,744
We're following the MGA thematic review, did FSRA
00:45:19,744 -- 00:45:23,582
conclude that additional reviews were required of the insurers involved?
00:45:25,016 -- 00:45:28,420
Yes. So we actually went through a couple different stages.
00:45:28,420 -- 00:45:31,423
This the first one was more just learning about the channels and MGAS.
00:45:31,690 -- 00:45:35,827
And then we did start to drill down on particular insurers and MGAs.
00:45:36,127 -- 00:45:39,130
And that's also been complemented by a great innovation
00:45:39,130 -- 00:45:41,766
which our insurance conduct team has led along.
00:45:41,766 -- 00:45:45,670
We call it cooperative supervisor reviews, where we go to major insurers
00:45:46,104 -- 00:45:47,672
involving the other provinces.
00:45:47,672 -- 00:45:48,573
We want to participate.
00:45:48,573 -- 00:45:50,976
The MF in particular is a great partner with this,
00:45:50,976 -- 00:45:52,410
and we go out and we do these reviews.
00:45:52,410 -- 00:45:58,049
So, yes, there are multiple layers to this and we are now building the conduct,
00:45:58,049 -- 00:46:02,020
supervision, resources in Life and Health that this isn't a one off.
00:46:02,520 -- 00:46:05,390
This is going to be a permanent feature of how we're going
00:46:05,390 -- 00:46:08,827
to basically supervise those insurers and manage that marketplace.
00:46:09,527 -- 00:46:12,564
I'm going to squeeze a question in about the Financial Planners
00:46:12,564 -- 00:46:15,567
Protection Act around Advocis.
00:46:15,934 -- 00:46:19,237
So what is the status of Advocis as a credentialing body in light of its
00:46:19,237 -- 00:46:23,274
financial situation and the legal troubles that have been reported in the media?
00:46:23,541 -- 00:46:26,444
You know, how does FSRA ensure the viability of credentialing bodies?
00:46:26,444 -- 00:46:28,813
And are you monitoring the legal outcome of that? Because
00:46:30,014 -- 00:46:32,751
while it is a credentialing body and so we have an obligation
00:46:32,751 -- 00:46:36,588
to watch what's going on there, they've been very forthcoming.
00:46:36,588 -- 00:46:40,792
The new management has been engaging with us whenever we've asked.
00:46:40,792 -- 00:46:44,996
They've been even proactive that they are a credentialing body in good standing.
00:46:44,996 -- 00:46:46,865
Their fees are fully paid.
00:46:46,865 -- 00:46:50,935
So there are you know, the people are using titles through them,
00:46:51,035 -- 00:46:54,038
should have confidence that that continues to exist.
00:46:54,038 -- 00:46:56,374
We have no reason to believe that they won't continue to do this.
00:46:56,374 -- 00:46:59,244
We think it is an important part of their business.
00:46:59,244 -- 00:47:04,048
They were an early adopter in wanting to be a credentialing body,
00:47:04,048 -- 00:47:06,651
they were very helpful through the process.
00:47:06,651 -- 00:47:08,286
Like all credentialing bodies
00:47:08,286 -- 00:47:10,288
I talked about, CIRO had some great strengths,
00:47:10,288 -- 00:47:12,757
but also some areas that maybe they aren't strong as other credential bodies.
00:47:12,757 -- 00:47:17,228
Advocis also has its weaknesses, and so we continue to be focused
00:47:17,228 -- 00:47:18,730
on supervising those.
00:47:18,730 -- 00:47:22,834
And of course, any organization that's going through change at the top,
00:47:23,234 -- 00:47:26,170
we're making sure that they're not cutting back on necessary resources
00:47:26,170 -- 00:47:29,173
that's still providing governance, that their eye isn't off the ball.
00:47:29,407 -- 00:47:33,611
And so we'll deal with that if we have to, through the normal supervisory tools.
00:47:34,178 -- 00:47:35,780
And we do keep an eye though, out.
00:47:35,780 -- 00:47:38,816
So, you know, we do have we work on plans
00:47:38,816 -- 00:47:41,819
that if a credential body ever does go away, what will we do?
00:47:41,819 -- 00:47:43,087
Because we will want to see that
00:47:43,087 -- 00:47:46,624
their title holders have a pathway to continued use of the title,
00:47:46,925 -- 00:47:49,360
even if the credentialing body that there are issues.
00:47:49,360 -- 00:47:52,363
But Advocis, it's all in good standing right now.
00:47:52,697 -- 00:47:57,035
Going back to an audience question is on the topic of climate change
00:47:57,035 -- 00:48:01,039
has been top of mind for other Canadian regulators, such as OSFI and the CSA,
00:48:01,506 -- 00:48:05,009
and these regulators have been requiring climate related disclosures from their
00:48:05,009 -- 00:48:08,680
regulated entities, such as disclosing information about financed emissions.
00:48:08,946 -- 00:48:11,149
Is FSRA headed in this direction as well?
00:48:13,584 -- 00:48:15,453
I don't want to disagree with the regulators,
00:48:15,453 -- 00:48:20,558
but most financial institutions that climate risk is derived risk
00:48:21,159 -- 00:48:24,228
because there are these they do have their own heating
00:48:24,228 -- 00:48:28,299
of their buildings, for example, but they're not actually producing
00:48:29,467 -- 00:48:32,170
things that generate carbon.
00:48:32,170 -- 00:48:35,173
They do provide financing, which can.
00:48:35,673 -- 00:48:37,608
So that's why I say it's a derived risk.
00:48:37,608 -- 00:48:41,579
And so their business activities have an influence on
00:48:43,614 -- 00:48:45,817
environmental issues we're dealing with.
00:48:45,817 -- 00:48:48,286
We're very concerned about it from a perspective of
00:48:48,286 -- 00:48:52,757
are they understanding climate change and environmental concerns as a risk.
00:48:53,558 -- 00:48:56,527
So if you're a Pension, for example,
00:48:56,627 -- 00:48:58,162
and you're investing some of those hundreds
00:48:58,162 -- 00:49:01,165
of billions of dollars I talked about, where are you investing them?
00:49:01,265 -- 00:49:04,335
And is there a risk that you are not diversified
00:49:04,635 -- 00:49:07,939
sufficiently and that you actually may end up with stranded assets?
00:49:08,406 -- 00:49:11,409
So that's from a good investment risk policy point of view
00:49:11,909 -- 00:49:15,947
we do leave it to others to take a perspective on climate
00:49:15,947 -- 00:49:18,950
that there should be no investment in oil and gas.
00:49:19,250 -- 00:49:23,321
We want to see the organizations being prudent in what they're doing.
00:49:23,554 -- 00:49:26,057
And so we're not against an institution that, let's say,
00:49:26,057 -- 00:49:29,060
a pension fund that says we don't want to invest in oil and gas anymore.
00:49:29,060 -- 00:49:32,697
But that's we don't see that as our role to tell them whether they should
00:49:32,697 -- 00:49:33,998
or should not do that.
00:49:33,998 -- 00:49:36,968
Our role is to make sure that they're protecting that.
00:49:36,968 -- 00:49:39,937
We're seeing that they're protecting the rights and benefits of their members.
00:49:40,171 -- 00:49:43,174
So obviously, if someone has too much exposure,
00:49:43,240 -- 00:49:47,278
unmanaged exposure and diversified exposure, that would be our primary concern.
00:49:49,413 -- 00:49:50,381
This is a great question.
00:49:50,381 -- 00:49:54,618
Does FSRA intend on modernizing PNC in Life Agent Licensing?
00:49:54,752 -- 00:49:58,689
This would include introducing CE continuing education requirements
00:49:58,689 -- 00:50:02,093
and licensing levels like mortgage brokers recently.
00:50:03,060 -- 00:50:04,528
Yeah, that is a great comment.
00:50:04,528 -- 00:50:09,300
It is something that we do look across our different regimes.
00:50:09,900 -- 00:50:12,069
I would say
00:50:12,069 -- 00:50:14,972
in the insurance area, yes, we could do more
00:50:14,972 -- 00:50:18,409
potentially at the licensing level, but I alluded to that
00:50:18,409 -- 00:50:22,113
we actually don't have true product suitability requirements.
00:50:22,546 -- 00:50:25,516
And so maybe so you have to kind of pick your battles
00:50:25,516 -- 00:50:28,519
as to where you think your biggest impact is going to be.
00:50:30,321 -- 00:50:32,790
I think we might be done.
00:50:32,790 -- 00:50:33,724
I lied.
00:50:33,724 -- 00:50:35,626
What are you doing to raise FSRA's awareness
00:50:35,626 -- 00:50:38,662
among consumers in Ontario, particularly the most vulnerable,
00:50:38,696 -- 00:50:43,400
whose first language is not English and who may not have easy online access?
00:50:44,768 -- 00:50:47,571
Yeah, FSRA awareness actually is a bit of a concern.
00:50:47,571 -- 00:50:50,407
Some of the consumer research I talked about in the first question,
00:50:50,407 -- 00:50:53,410
most people don't know who we are,
00:50:54,178 -- 00:50:56,814
which is of course, a little upsetting to me.
00:50:56,814 -- 00:50:58,916
My kids kind of know who I am, but they don't
00:50:58,916 -- 00:51:00,918
watch the videos on our website.
00:51:00,918 -- 00:51:02,152
They don't really know what I do.
00:51:02,152 -- 00:51:04,455
I think most regulators would fall into that bucket.
00:51:04,455 -- 00:51:07,458
Yes. So
00:51:07,691 -- 00:51:10,461
we think and that's why something like the public registry,
00:51:10,461 -- 00:51:13,430
we're trying to focus on credential check.
00:51:13,430 -- 00:51:17,268
And we actually have targeted strategies which don't cost a lot of money.
00:51:17,268 -- 00:51:20,271
So we don't we're not going to run ads on the Super Bowl,
00:51:20,537 -- 00:51:24,074
but we do things in media and particularly search related
00:51:24,308 -- 00:51:26,944
so that where we do have some information out there,
00:51:26,944 -- 00:51:30,247
if someone does a search on getting a private mortgage
00:51:30,247 -- 00:51:34,585
or buying a life insurance policy or finding a financial adviser,
00:51:34,918 -- 00:51:38,055
we want our information to come up quickly.
00:51:38,322 -- 00:51:38,989
Right.
00:51:38,989 -- 00:51:41,959
So whether it's top or not, I never know whether we're the ones who are going
00:51:41,959 -- 00:51:45,295
to pay enough to get to the top billing, but we want it to be on that front page
00:51:45,896 -- 00:51:48,232
and we think that that will make us more accessible.
00:51:48,232 -- 00:51:52,269
And it isn't, even though personally, I'd love people to know who FSRA is, it's
00:51:52,269 -- 00:51:52,569
not really
00:51:52,569 -- 00:51:56,140
that important to me as long as they find the information that they need.
00:51:56,840 -- 00:51:59,943
Think about the financial services that people are buying.
00:52:00,444 -- 00:52:02,279
They're often very episodic in their life.
00:52:02,279 -- 00:52:03,547
So they're event driven.
00:52:03,547 -- 00:52:05,249
You know, you're getting married.
00:52:05,249 -- 00:52:08,218
And so you're thinking about another person in your life or having a child.
00:52:08,218 -- 00:52:09,720
So you think about Life Insurance.
00:52:09,720 -- 00:52:11,321
You're buying a house for the first time.
00:52:11,321 -- 00:52:12,856
So you're thinking about a Mortgage.
00:52:12,856 -- 00:52:16,393
You're starting to think about your kids going to school or your retirement,
00:52:16,393 -- 00:52:17,795
so you're starting to save.
00:52:17,795 -- 00:52:20,197
So those are all big life changes.
00:52:20,197 -- 00:52:23,934
And so our information has to be there when you need it.
00:52:24,301 -- 00:52:27,371
I do think there's a great role for educating people,
00:52:27,371 -- 00:52:30,374
even if those are coming through school, giving them some basic grounding.
00:52:30,407 -- 00:52:34,178
But the truth is, if you don't use knowledge, it tends to atrophy.
00:52:34,444 -- 00:52:37,447
And so hopefully, though, we can give them enough
00:52:37,714 -- 00:52:40,517
basic knowledge through their education that then they at least know
00:52:40,517 -- 00:52:43,520
how to look for it when one of those life events is happening.
00:52:43,520 -- 00:52:47,558
And so our goal at FSRA is and we're doing some very simple things,
00:52:47,858 -- 00:52:50,827
it's like, if you're going to get a mortgage,
00:52:50,961 -- 00:52:53,964
here's what you need to ask about a Life Insurance policy.
00:52:53,997 -- 00:52:55,732
Here's what you need to ask.
00:52:55,732 -- 00:52:57,501
What's the value of a pension?
00:52:57,501 -- 00:53:00,971
And so that type of information where it's targeted and,
00:53:01,672 -- 00:53:04,074
you know, in a way that people can easily consume.
00:53:04,074 -- 00:53:07,477
So on a on a page basically, not something that's long and complicated.
00:53:07,744 -- 00:53:10,147
So it's very different when we're dealing with consumers,
00:53:10,147 -- 00:53:12,115
then we're dealing with the regulated sectors
00:53:12,115 -- 00:53:15,786
where the level of language, the complexity, we have to have to deal
00:53:15,786 -- 00:53:20,290
with that. So we're very optimistic that we will get our name out increasingly.
00:53:20,724 -- 00:53:23,994
We'll get our information out.
00:53:23,994 -- 00:53:26,496
And regardless of whether it's our name and our brand,
00:53:26,496 -- 00:53:29,900
even only the sectors know who we are, that's fine as long as the
00:53:29,900 -- 00:53:30,968
consumers get what they need.
00:53:31,969 -- 00:53:34,504
So I think we have enough time to end on Credit Unions.
00:53:34,504 -- 00:53:37,341
And I'm going to ask sort of a multi-pronged question here
00:53:37,341 -- 00:53:38,608
to the Credit Unions.
00:53:38,608 -- 00:53:42,379
So what's your position on Credit Unions moving to the federal regime?
00:53:42,813 -- 00:53:45,849
As well does FSRA want to continue regulating Credit Unions?
00:53:45,849 -- 00:53:48,852
And do you see any further consolidation among the Credit Unions?
00:53:49,753 -- 00:53:52,756
So credit unions, it all comes back to our objects,
00:53:53,190 -- 00:53:56,093
our objects, our basically about making sure
00:53:56,093 -- 00:53:59,930
the stability in the sector is strong, innovative, competitive,
00:54:01,231 -- 00:54:04,601
the DIRF and Credit Unions because it's a co-insurance plan and not exposed to
00:54:04,601 -- 00:54:08,338
loss members are protected, you know, from a conduct perspective.
00:54:08,772 -- 00:54:12,709
And so we look at those objects and they really drive the answer
00:54:12,709 -- 00:54:14,244
to all those questions.
00:54:14,244 -- 00:54:17,013
So if a Credit Union
00:54:17,013 -- 00:54:20,016
does want to go federal, that's a choice for its members.
00:54:20,750 -- 00:54:21,485
But we have
00:54:22,419 -- 00:54:25,422
a say in it because we have to think about the stability
00:54:25,489 -- 00:54:29,359
of the overall Credit Union sector in Ontario.
00:54:29,993 -- 00:54:32,529
And so we will have
00:54:32,529 -- 00:54:37,100
you know, an interesting debate about what does it mean if major Credit Unions
00:54:37,367 -- 00:54:40,370
do start to go federal for the stability of the sector.
00:54:40,637 -- 00:54:44,407
So I'm not precluding that discussion, but it is important for us
00:54:44,407 -- 00:54:47,811
to take our object very seriously when we're reviewing those decisions.
00:54:48,578 -- 00:54:50,814
What I think is really important, though, is we're trying
00:54:50,814 -- 00:54:53,817
to create what I call the Ontario advantage.
00:54:53,950 -- 00:54:58,321
The Ontario advantages that we believe we are developing a world class system
00:54:58,655 -- 00:55:01,658
for the regulation and supervision of Credit Unions in Ontario.
00:55:01,791 -- 00:55:05,595
It will be data based, it will be principles based, risk based supervision.
00:55:05,929 -- 00:55:08,798
It's going to make sure that we're not in there just checking loan files,
00:55:08,798 -- 00:55:12,636
that we're looking at the policies and processes within a Credit Union about
00:55:12,869 -- 00:55:14,971
they do their business, that they're members,
00:55:14,971 -- 00:55:16,740
they have codes of conduct that they're following.
00:55:16,740 -- 00:55:19,075
So the members are honored and well protected.
00:55:19,075 -- 00:55:20,710
We think that with that,
00:55:20,710 -- 00:55:22,712
some of the things I talked about with the Deposit Insurance
00:55:22,712 -- 00:55:26,282
Reserve Fund, making sure that there's good liquidity in the system, good regulatory
00:55:26,282 -- 00:55:29,719
tools that we do have to resolve a Credit Union, all that will give us
00:55:29,719 -- 00:55:34,157
a great Credit Union system and I think it will the Ontario advantage
00:55:34,591 -- 00:55:38,828
and the Credit Unions will want to stay so we're not inundated.
00:55:38,828 -- 00:55:41,798
I don't even know if we've ever received an application to go federal.
00:55:41,831 -- 00:55:46,870
Interestingly, most of the Credit Union to get to that size,
00:55:47,170 -- 00:55:49,005
they've realize that they can create a bank sub
00:55:49,005 -- 00:55:52,409
which gives them a federal charter, and so it gives them all the advantages
00:55:52,409 -- 00:55:55,779
if they need to go to provincial without actually changing
00:55:56,012 -- 00:55:57,914
their jurisdiction of incorporation.
00:55:57,914 -- 00:55:59,215
That's different than some of the B.C.
00:55:59,215 -- 00:56:01,251
Credit Unions where they have went federal.
00:56:01,251 -- 00:56:04,354
So you know, we're not against going federal,
00:56:04,354 -- 00:56:07,323
but we will always view it through our objects.
00:56:07,323 -- 00:56:10,193
What is the best for that credit union and for the system
00:56:11,327 -- 00:56:11,961
that also.
00:56:11,961 -- 00:56:13,897
So do we want to continue regulating Credit Unions?
00:56:13,897 -- 00:56:15,932
Yeah, it's our job.
00:56:15,932 -- 00:56:17,467
I mean, those are our objects.
00:56:17,467 -- 00:56:20,470
It's not a choice. You don't get a choice.
00:56:21,037 -- 00:56:22,372
You sign up to be a regulator.
00:56:22,372 -- 00:56:24,607
You look at your statute, you have objects.
00:56:24,607 -- 00:56:26,276
We do that. That's what we do for a living.
00:56:26,276 -- 00:56:29,479
So want is not it doesn't come into it.
00:56:29,913 -- 00:56:34,050
As to consolidation, sure, there's been a ton of consolidation
00:56:34,050 -- 00:56:37,053
of Credit Union sector and we do expect it's going to continue.
00:56:37,353 -- 00:56:41,090
But we don't have a view on what is the right number of Credit Unions
00:56:41,090 -- 00:56:43,159
or what is the right size of a Credit Union.
00:56:43,159 -- 00:56:46,796
We think obviously is a trend to larger because they can offer more products
00:56:46,796 -- 00:56:49,799
and services that can average down overhead costs.
00:56:49,899 -- 00:56:54,404
So there's there are advantages, but let's face it, there are many smaller
00:56:54,404 -- 00:56:57,407
and mid-sized Credit Unions that have very successful business models.
00:56:57,574 -- 00:56:59,642
They serve their communities.
00:56:59,642 -- 00:57:04,280
Credit Unions are very important source of competition to other financial
00:57:04,280 -- 00:57:07,317
institutions and understanding the needs of their members.
00:57:07,317 -- 00:57:09,018
That is probably their most unique
00:57:09,018 -- 00:57:11,287
selling proposition that I've seen over the years
00:57:11,287 -- 00:57:14,290
is that they work harder to understand their member needs
00:57:14,290 -- 00:57:15,858
and how they serve them.
00:57:15,858 -- 00:57:19,595
And so with that, yeah, we may continue with some smaller Credit Unions
00:57:19,595 -- 00:57:23,766
for forever, but yes, more consolidation.
00:57:23,933 -- 00:57:26,936
Yeah, I do think that that is probably going to happen.
00:57:27,136 -- 00:57:31,641
But we want the marketplace to essentially try and decide that sometimes we may
00:57:32,241 -- 00:57:34,544
of course we have to be involved in the decisions on mergers,
00:57:34,544 -- 00:57:37,313
but that's something that we're not out there advocating for.
00:57:37,313 -- 00:57:41,617
We're not going to try and centrally plan this like we have an industrial policy
00:57:41,617 -- 00:57:45,321
and we're going to decide that it should be 15 Credit Unions in Ontario or 50.
00:57:45,855 -- 00:57:49,892
We want to let the marketplace decide that what we supervise and we regulate it,
00:57:50,093 -- 00:57:51,994
always keeping our objects in mind.
00:57:51,994 -- 00:57:52,728
Right.
00:57:52,728 -- 00:57:55,164
And we are officially out of time.
00:57:55,164 -- 00:57:56,799
I appreciate all the comments.
00:57:56,799 -- 00:57:58,201
If you didn't get your question answered,
00:57:58,201 -- 00:58:00,002
I think we're just going to be holding on to them
00:58:00,002 -- 00:58:02,605
and we'll look to get a response and post them online.
00:58:02,605 -- 00:58:05,475
You can also reach out to me as well [email protected]
00:58:05,475 -- 00:58:08,845
Mark, thank you so much for joining me on stage today.
00:58:08,978 -- 00:58:10,112
It's been fantastic.
00:58:10,112 -- 00:58:13,483
Thank you Clara I’ve enjoyed it.
00:00:05,171 -- 00:00:05,605
All right.
00:00:05,605 -- 00:00:08,174
Welcome back everyone.
00:00:08,174 -- 00:00:09,676
As many of you know today,
00:00:09,676 -- 00:00:11,611
you can't really turn on the news
00:00:11,611 -- 00:00:15,482
without seeing the impact of climate change.
00:00:15,482 -- 00:00:19,586
And it has massive impacts across financial services.
00:00:20,320 -- 00:00:23,623
So today, facilitating our expert panel for climate
00:00:23,623 -- 00:00:26,726
discussion is the Head of Financial Institutions
00:00:26,726 -- 00:00:27,727
and Mortgage Broker
00:00:27,727 -- 00:00:31,698
Conduct and Media Superstar, Antoinette Leung.
00:00:32,298 -- 00:00:34,667
Introduce your panel.
00:00:34,667 -- 00:00:37,303
Sure. Thank you Judy.
00:00:37,303 -- 00:00:41,307
I'm very excited and delighted to moderate this panel.
00:00:41,608 -- 00:00:44,244
As a consumer protection agency,
00:00:44,244 -- 00:00:46,146
FSRA vision is financial
00:00:46,146 -- 00:00:48,648
safety, fairness and choice for consumers.
00:00:48,648 -- 00:00:51,684
And we know that climate is impacting
00:00:51,684 -- 00:00:54,287
everyone as consumers as well as business.
00:00:54,287 -- 00:00:56,789
So I'm excited that we have two experts
00:00:56,789 -- 00:00:58,358
with us today to talk about
00:00:58,358 -- 00:01:02,262
how businesses can adapt their business model,
00:01:02,262 -- 00:01:05,498
to continue to provide services for consumers.
00:01:05,498 -- 00:01:09,369
And, I'd like to introduce our two experts.
00:01:09,369 -- 00:01:09,836
Dr.
00:01:09,836 -- 00:01:10,169
Blair
00:01:10,169 -- 00:01:12,405
Feltmate is the Head of the Intact Centre
00:01:12,405 -- 00:01:15,808
on Climate Adaptation at the University of Waterloo.
00:01:15,808 -- 00:01:19,412
And Paul Kovacs is the Founder and Executive Director
00:01:19,412 -- 00:01:21,281
of the Institute for Catastrophic
00:01:21,281 -- 00:01:23,783
Loss Reduction at Western University.
00:01:23,783 -- 00:01:26,352
Their full bios is on our conference website.
00:01:26,352 -- 00:01:30,056
So I want to jump right into our discussion.
00:01:30,056 -- 00:01:31,758
So maybe before we start,
00:01:31,758 -- 00:01:33,192
I would like to ask each of
00:01:33,192 -- 00:01:35,228
you to set the stage for us,
00:01:36,362 -- 00:01:38,631
about what is physical climate risk?
00:01:38,631 -- 00:01:39,565
What are some of the things
00:01:39,565 -- 00:01:41,467
that we're currently facing?
00:01:41,467 -- 00:01:43,903
Maybe I'll start with you, Blair. Sure.
00:01:43,903 -- 00:01:44,871
Thank you very much.
00:01:44,871 -- 00:01:47,073
And I am, pleased to be here this morning
00:01:47,073 -- 00:01:49,208
to talk about, climate change.
00:01:49,208 -- 00:01:50,343
And I thought I'd start out
00:01:50,343 -- 00:01:51,711
with something that, quite frankly,
00:01:51,711 -- 00:01:52,612
I can tell you right now
00:01:52,612 -- 00:01:53,746
for the first
00:01:53,746 -- 00:01:54,747
couple of minutes is going to be
00:01:54,747 -- 00:01:56,249
a little bit depressing,
00:01:56,249 -- 00:01:58,017
and it's not going to put you in a good mood,
00:01:58,017 -- 00:01:59,685
but I just want to really profile
00:01:59,685 -- 00:02:01,320
the formidability of the challenge
00:02:01,320 -- 00:02:03,156
we're facing with climate change.
00:02:03,156 -- 00:02:04,657
Extreme weather risk,
00:02:04,657 -- 00:02:07,860
emphasizing the point that it is irreversible.
00:02:07,860 -- 00:02:10,196
Period. Climate change is here to stay.
00:02:10,196 -- 00:02:12,198
We're not going backwards on climate change.
00:02:12,198 -- 00:02:14,801
We can slow down the rate of climate change
00:02:14,801 -- 00:02:16,803
by lowering the discharge
00:02:16,803 -- 00:02:19,839
of greenhouse gas emissions into the atmosphere.
00:02:19,839 -- 00:02:21,908
But we're not going backwards.
00:02:21,908 -- 00:02:24,644
And this is not my cavalier opinion.
00:02:24,644 -- 00:02:27,146
This is an opinion expressed by
00:02:27,146 -- 00:02:29,348
a variety of authoritative agencies,
00:02:29,348 -- 00:02:33,085
both at the national level and internationally.
00:02:33,085 -- 00:02:35,021
And if you allow me, I'm just going to read 1 or 2
00:02:35,021 -- 00:02:36,489
sentences from
00:02:36,489 -- 00:02:37,390
various agencies
00:02:37,390 -- 00:02:40,059
talking about the irreversibility of climate change.
00:02:41,194 -- 00:02:43,362
For example, in
00:02:43,362 -- 00:02:45,431
2019, the
00:02:45,431 -- 00:02:46,866
federal government of Canada,
00:02:46,866 -- 00:02:49,268
through Environment and Climate Change Canada,
00:02:49,268 -- 00:02:50,770
they wrote a report called
00:02:50,770 -- 00:02:53,206
Canada's Changing Climate Report.
00:02:53,206 -- 00:02:54,340
And this was authored
00:02:54,340 -- 00:02:55,241
by, more
00:02:55,241 -- 00:02:57,176
or less about a dozen climate scientists
00:02:57,176 -- 00:02:59,378
from Environment and Climate Change Canada.
00:02:59,378 -- 00:03:00,479
So they had the
00:03:00,479 -- 00:03:02,548
proper authority to
00:03:02,548 -- 00:03:04,884
pay attention to what they're saying in this report.
00:03:04,884 -- 00:03:06,385
And in that report,
00:03:06,385 -- 00:03:08,187
they state, and I'm quoting,
00:03:08,187 -- 00:03:10,122
“Canada's climate has warmed
00:03:10,122 -- 00:03:11,324
and will warm further
00:03:11,324 -- 00:03:14,093
in the future, driven by human influence,”
00:03:14,093 -- 00:03:16,028
which is the burning of fossil fuels
00:03:16,028 -- 00:03:19,065
that puts CO2 in the atmosphere and traps energy
00:03:19,065 -- 00:03:20,833
that would otherwise escape into space.
00:03:20,833 -- 00:03:23,636
It stays in the system and causes warming,
00:03:23,636 -- 00:03:25,504
driven by human influence.
00:03:25,504 -- 00:03:28,374
This warming is effectively irreversible,
00:03:28,374 -- 00:03:30,609
and this is the first time that I'm aware of that.
00:03:30,609 -- 00:03:32,211
The federal government of Canada
00:03:32,211 -- 00:03:35,414
recognized the irreversibility of climate change.
00:03:35,414 -- 00:03:39,652
And then in 2022, from the intergovernmental Panel
00:03:39,652 -- 00:03:40,686
on Climate Change,
00:03:40,686 -- 00:03:42,488
they wrote a report called, “Climate Change
00:03:42,488 -- 00:03:46,492
2022 Impacts Adaptation and Vulnerability.”
00:03:47,059 -- 00:03:49,028
And this is a group of several
00:03:49,028 -- 00:03:50,229
hundred climate scientists
00:03:50,229 -- 00:03:51,964
that all they do seven days
00:03:51,964 -- 00:03:53,766
a week to study climate science.
00:03:53,766 -- 00:03:56,235
And they wrote, and I quote,
00:03:56,235 -- 00:03:58,838
“it is indisputable that human activities,
00:03:58,838 -- 00:04:00,639
the burning of fossil fuels
00:04:00,639 -- 00:04:01,373
are causing
00:04:01,373 -- 00:04:04,076
climate change, making extreme climate events
00:04:04,076 -- 00:04:06,278
including heatwaves, heavy rainfall
00:04:06,278 -- 00:04:09,248
and droughts more frequent and severe.”
00:04:09,248 -- 00:04:10,149
And then,
00:04:10,149 -- 00:04:11,350
just a few months back,
00:04:11,350 -- 00:04:13,886
the United Nations Environmental Program,
00:04:13,886 -- 00:04:16,055
released a report called, “Broken Report.”
00:04:16,055 -- 00:04:20,559
And they said there's no credible pathway to 1.5°C.
00:04:20,926 -- 00:04:24,663
So, point number one is we're not going backwards on
00:04:24,663 -- 00:04:25,397
climate change.
00:04:25,397 -- 00:04:26,866
It's here to stay. Extreme weather
00:04:26,866 -- 00:04:29,235
will get more extreme as a function of time.
00:04:29,235 -- 00:04:30,836
Sometimes you'll hear in the media
00:04:30,836 -- 00:04:33,305
they talk about the new normal of climate change.
00:04:33,305 -- 00:04:34,840
There is no new normal.
00:04:34,840 -- 00:04:37,142
There's just evolving risk.
00:04:37,142 -- 00:04:38,777
We can slow down the rate of change,
00:04:38,777 -- 00:04:41,213
but it's going to get more challenging over time.
00:04:41,213 -- 00:04:42,515
And I'll leave it at that
00:04:42,515 -- 00:04:45,284
and maybe turn to Paul’s thoughts. Sure, Paul.
00:04:47,319 -- 00:04:47,653
Thank you
00:04:47,653 -- 00:04:49,154
for including climate change
00:04:49,154 -- 00:04:52,191
in the conversation today.
00:04:52,191 -- 00:04:54,593
From the research that I have been doing
00:04:54,593 -- 00:04:57,696
and the research that I've been following,
00:04:57,696 -- 00:05:00,299
our climate has changed.
00:05:00,299 -- 00:05:04,303
There's significant further change coming.
00:05:04,436 -- 00:05:08,674
And this is going to profoundly change the business
00:05:08,874 -- 00:05:11,110
of all of the financial institutions
00:05:11,110 -- 00:05:14,847
being monitored by FSRA.
00:05:14,847 -- 00:05:18,851
As a consumer of financial services living in Ontario,
00:05:18,884 -- 00:05:22,888
I'm counting on regulators, supervisors
00:05:23,255 -- 00:05:24,556
to assure me
00:05:24,556 -- 00:05:26,358
that the financial institutions
00:05:26,358 -- 00:05:30,362
are properly managing these risks.
00:05:30,696 -- 00:05:33,132
The failure of policymakers to deal with
00:05:33,132 -- 00:05:35,000
climate change
00:05:35,000 -- 00:05:37,970
has resulted in two fundamental risks
00:05:37,970 -- 00:05:40,372
for financial institutions.
00:05:40,372 -- 00:05:42,341
One being transitional risk
00:05:42,341 -- 00:05:45,878
and the other being physical risk.
00:05:45,878 -- 00:05:49,782
So it's the supervision of how financial institutions
00:05:49,782 -- 00:05:53,786
across all the sectors are handling transition risk
00:05:54,219 -- 00:05:57,489
and handling physical risks. That I'm concerned about.
00:05:59,825 -- 00:06:00,225
It's my
00:06:00,225 -- 00:06:04,229
opinion that on the physical risk area,
00:06:04,296 -- 00:06:05,164
you've got,
00:06:05,164 -- 00:06:07,366
Property Insurance companies that are about ten years
00:06:07,366 -- 00:06:09,134
ahead of all the other financial companies
00:06:09,134 -- 00:06:13,405
that have been
working on this file for more than a decade
00:06:14,039 -- 00:06:18,510
and doing some very prominent things
00:06:18,510 -- 00:06:22,014
and really trying to manage these risks.
00:06:22,014 -- 00:06:23,382
But on the physical risk side,
00:06:23,382 -- 00:06:25,551
outside of the Property Insurance Industry,
00:06:25,551 -- 00:06:27,219
there's very little going on.
00:06:27,219 -- 00:06:30,022
There's a lot that needs to be done.
00:06:30,022 -- 00:06:31,757
Some headlines in Québec
00:06:31,757 -- 00:06:33,292
Desjardins made some announcements
00:06:33,292 -- 00:06:36,628
about their lending for people living in floodplains.
00:06:36,628 -- 00:06:38,997
Some common sense stuff that
00:06:38,997 -- 00:06:40,432
I think should have happened years ago.
00:06:40,432 -- 00:06:42,634
So it's
great to see some changes starting to happen
00:06:42,634 -- 00:06:45,537
outside of the insurance industry.
00:06:45,537 -- 00:06:47,639
But they're way behind.
00:06:47,639 -- 00:06:50,309
The leadership that's been in the insurance industry
00:06:51,376 -- 00:06:52,344
on the,
00:06:52,344 -- 00:06:53,712
transition risk side,
00:06:53,712 -- 00:06:56,949
as Mark touched on earlier today,
00:06:56,949 -- 00:06:59,918
knowing how financial institutions are investing,
00:06:59,918 -- 00:07:02,587
knowing how financial institutions are lending,
00:07:02,587 -- 00:07:03,121
who they lend
00:07:03,121 -- 00:07:05,123
to, it's a lot more complicated
00:07:05,123 -- 00:07:05,824
with the change
00:07:05,824 -- 00:07:06,858
that's happening in the climate
00:07:06,858 -- 00:07:10,062
about the right investments to make
00:07:10,062 -- 00:07:13,532
and OSFI’s leadership to look for disclosure
00:07:13,532 -- 00:07:16,268
about how financial institutions
00:07:16,268 -- 00:07:19,237
are thinking about these risks.
00:07:19,237 -- 00:07:20,972
And thinking about this transition
00:07:20,972 -- 00:07:23,709
that's taking place, for me is very exciting.
00:07:23,709 -- 00:07:27,212
It's great to see the change that is starting to come.
00:07:27,212 -- 00:07:28,947
Anyway, so for me, setting
00:07:28,947 -- 00:07:31,383
the context, the climate is changing.
00:07:31,383 -- 00:07:32,818
It's going to have a profound impact
00:07:32,818 -- 00:07:34,419
on the financial sector.
00:07:34,419 -- 00:07:39,224
Having leadership from FSRA and OSFI to oversee
00:07:39,224 -- 00:07:42,160
how financial institutions are thinking about
00:07:42,160 -- 00:07:43,929
imagining this is incredibly important.
00:07:44,996 -- 00:07:45,664
And I
00:07:45,664 -- 00:07:49,668
think, within the sector, the regulatory sector,
00:07:49,868 -- 00:07:53,338
terms like,
00:07:53,338 -- 00:07:55,841
transmission risk and physical risk
00:07:55,841 -- 00:07:57,776
are going to become really commonplace,
00:07:57,776 -- 00:07:59,444
like prudential risk
00:07:59,444 -- 00:08:03,181
and Market Conduct risk, has been for many years.
00:08:03,181 -- 00:08:05,050
So understanding what those terms mean
00:08:05,050 -- 00:08:06,985
and how to properly act upon that,
00:08:06,985 -- 00:08:09,488
I think will be really important going forward.
00:08:09,488 -- 00:08:10,255
That's great.
00:08:10,255 -- 00:08:11,823
So that's actually a great segue
00:08:11,823 -- 00:08:15,160
into our first question, which is what do you think?
00:08:15,160 -- 00:08:16,995
You know,
each of our regulated sector
00:08:16,995 -- 00:08:20,999
can do to better prepare for extreme weather
00:08:21,099 -- 00:08:22,200
that is to come.
00:08:22,200 -- 00:08:23,168
And I know that, you know,
00:08:23,168 -- 00:08:24,369
you've both mentioned
00:08:24,369 -- 00:08:26,004
that on the P&C side,
00:08:26,004 -- 00:08:27,372
Property and Casualty side,
00:08:27,372 -- 00:08:29,007
there has been a lot of thinking about it.
00:08:29,007 -- 00:08:31,576
What about our other regulated sectors?
00:08:31,576 -- 00:08:34,079
Blair, do you have any thoughts on those?
00:08:34,079 -- 00:08:34,946
Yeah, I think
00:08:36,748 -- 00:08:38,917
there's good news here by the way.
00:08:38,917 -- 00:08:41,152
You know, we actually know what to do
00:08:41,152 -- 00:08:42,420
before turning to the sectors.
00:08:42,420 -- 00:08:43,955
We actually know what to do
00:08:43,955 -- 00:08:45,523
if we're talking particularly about Property
00:08:45,523 -- 00:08:47,092
Casualty Insurance and Life
00:08:47,092 -- 00:08:47,892
and Health Insurance
00:08:47,892 -- 00:08:51,963
because people's houses and basement flooding,
00:08:52,197 -- 00:08:54,566
we now know quantitatively that this adds
00:08:54,566 -- 00:08:57,669
psychosocial mental health stress to people.
00:08:57,669 -- 00:08:59,671
It affects long time lost time from work
00:08:59,671 -- 00:09:01,272
when their houses are flooded.
00:09:01,272 -- 00:09:03,608
It's not just a P&C issue now.
00:09:03,608 -- 00:09:05,944
It's also a Life and Health issue.
00:09:05,944 -- 00:09:09,481
But for example, for
00:09:09,481 -- 00:09:13,251
flooding and wildfire, which are the two most costly
00:09:13,251 -- 00:09:16,087
physical climate risks realized in the country.
00:09:16,087 -- 00:09:18,156
And flooding being the number one peril.
00:09:18,156 -- 00:09:20,225
And then out of that residential being,
00:09:20,225 -- 00:09:22,127
residential basement flooding
00:09:22,127 -- 00:09:24,029
being the most costly expression
00:09:24,029 -- 00:09:26,631
of climate change in the country.
00:09:26,631 -- 00:09:28,032
That's the bad news.
00:09:28,032 -- 00:09:31,536
The good news is that, over,
00:09:31,536 -- 00:09:34,506
about maybe the last ten years or so
00:09:34,506 -- 00:09:36,040
working with organizations
00:09:36,040 -- 00:09:38,176
like the Standards Council of Canada,
00:09:38,176 -- 00:09:40,345
the National Research Council,
00:09:40,345 -- 00:09:44,682
Canadian Standards Association, I think ICLR.
00:09:44,682 -- 00:09:47,185
And I like to think the INTACT Center and others...
00:09:47,185 -- 00:09:48,319
What we've developed over
00:09:48,319 -- 00:09:50,722
the last ten years for the country
00:09:50,722 -- 00:09:52,557
is very good,
00:09:52,557 -- 00:09:55,794
practical, meaningful, cost effective Guidance
00:09:55,794 -- 00:09:58,696
as actions that can be taken or implemented
00:09:58,696 -- 00:10:01,666
to mitigate flood risk at the level of the home
00:10:01,666 -- 00:10:03,968
and at the level of the community.
00:10:03,968 -- 00:10:05,336
And the same for wildfire.
00:10:05,336 -- 00:10:07,305
We know what to do to mitigate wildfire
00:10:07,305 -- 00:10:09,307
risk for homes, businesses and communities
00:10:09,307 -- 00:10:10,975
and forested and grassland regions
00:10:10,975 -- 00:10:12,043
to make it such that
00:10:12,043 -- 00:10:13,278
when a fire comes through,
00:10:13,278 -- 00:10:14,846
it doesn't burn down every home
00:10:14,846 -- 00:10:16,848
or burn down the community.
00:10:16,848 -- 00:10:20,885
Now for Property and Casualty Insurers, for example,
00:10:20,885 -- 00:10:23,888
one of the rather deeply involved in, the
00:10:23,888 -- 00:10:26,524
one of the areas that they're pushing,
00:10:26,524 -- 00:10:27,625
very aggressively
00:10:27,625 -- 00:10:28,226
and the Insurance
00:10:28,226 -- 00:10:32,630
Bureau of Canada and others is giving direction
00:10:32,964 -- 00:10:34,232
to homeowners
00:10:34,232 -- 00:10:37,969
as to actions they can take around their property.
00:10:37,969 -- 00:10:40,204
Generally speaking, over a long weekend
00:10:40,204 -- 00:10:43,408
without special expertise for very little money
00:10:43,408 -- 00:10:44,409
in the hundreds,
00:10:44,409 -- 00:10:46,411
maybe the low thousands of dollars,
00:10:46,411 -- 00:10:48,579
that on a scale of 0 to 100, 100
00:10:48,579 -- 00:10:50,181
being the worst for basement flooding.
00:10:50,181 -- 00:10:53,284
You can take a home from an 80 down to a 20
00:10:53,284 -- 00:10:54,218
just like that,
00:10:54,218 -- 00:10:56,554
by providing the appropriate information
00:10:56,554 -- 00:10:58,556
to people to act upon to protect their homes.
00:10:58,556 -- 00:10:59,390
The reason
00:10:59,390 -- 00:11:01,459
they're not protecting their home for most homeowners
00:11:01,459 -- 00:11:02,894
is, is not that they won't do it, it's
00:11:02,894 -- 00:11:04,095
because they don't know what to do.
00:11:04,095 -- 00:11:07,298
But when you actually give them the information,
00:11:07,298 -- 00:11:11,269
simple diagrammatic infographic style information,
00:11:11,269 -- 00:11:12,170
we find that,
00:11:13,337 -- 00:11:16,174
70% of people will take two actions to
00:11:16,174 -- 00:11:17,108
protect their homes
00:11:17,108 -- 00:11:19,310
from basement flooding within a six month
00:11:19,310 -- 00:11:21,479
period that they otherwise wouldn't have done.
00:11:21,479 -- 00:11:22,513
Now, let's see,
00:11:22,513 -- 00:11:24,816
with the Credit Unions, a role that they can play.
00:11:24,816 -- 00:11:26,751
And I'll give you one tangible example.
00:11:26,751 -- 00:11:28,019
So I'm going to mention Meridian.
00:11:28,019 -- 00:11:30,354
And this is positive news for Meridian,
00:11:30,354 -- 00:11:32,290
just in case Meridian’s here are getting nervous.
00:11:32,290 -- 00:11:38,463
On Meridian's website now they list infographics.
00:11:38,463 -- 00:11:40,932
They present infographics on their website
00:11:40,932 -- 00:11:42,900
to their customers that they can,
00:11:42,900 -- 00:11:45,903
or members, I think they call them, that
00:11:45,903 -- 00:11:47,305
that give them guidance on
00:11:47,305 -- 00:11:50,107
how to protect their home from basement flooding.
00:11:50,107 -- 00:11:52,109
The Property and Casualty insurers
00:11:52,109 -- 00:11:54,278
are doing exactly the same thing,
00:11:54,278 -- 00:11:56,180
rolling this stuff out in simple language
00:11:56,180 -- 00:11:57,882
to help people help themselves.
00:11:57,882 -- 00:11:58,816
And now also,
00:11:58,816 -- 00:12:01,919
we have the Life and Health Insurers on board doing
00:12:01,919 -- 00:12:04,255
the same thing. So the
00:12:05,323 -- 00:12:07,258
formability of the challenge,
00:12:07,258 -- 00:12:08,526
it almost can't be overstated.
00:12:08,526 -- 00:12:10,795
But the good news is we know what to do
00:12:10,795 -- 00:12:13,264
to counter the negative effects.
00:12:13,264 -- 00:12:13,698
That's great.
00:12:13,698 -- 00:12:14,799
So it's helping
00:12:14,799 -- 00:12:16,000
consumers help themselves
00:12:16,000 -- 00:12:19,837
so that businesses can continue to offer services.
00:12:19,837 -- 00:12:21,572
And just so everyone knows that
00:12:21,572 -- 00:12:22,974
a lot of these resources
00:12:22,974 -- 00:12:25,076
are actually included in the conference website.
00:12:25,076 -- 00:12:27,245
You can take a look at that. Paul,
00:12:27,245 -- 00:12:28,913
what about,
00:12:28,913 -- 00:12:29,947
are there anything else
00:12:29,947 -- 00:12:33,918
that we're missing that you think the regulated sector
00:12:34,018 -- 00:12:35,319
should be thinking about
00:12:35,319 -- 00:12:39,290
as we encounter more and more extreme weather events?
00:12:41,826 -- 00:12:44,261
We know the change that's coming to the climate
00:12:44,261 -- 00:12:46,030
the next 25 years or so,
00:12:46,030 -- 00:12:48,299
there will be more large storms,
00:12:48,299 -- 00:12:51,535
the kind of storms that can cause damage.
00:12:51,535 -- 00:12:54,772
About 90% of the damage in Ontario
00:12:54,772 -- 00:12:56,173
over the last 50 years
00:12:56,173 -- 00:12:59,710
or so has been for different kinds of risks.
00:12:59,710 -- 00:13:01,078
As Blair has touched on basement
00:13:01,078 -- 00:13:03,748
flooding and flooding, wildfires,
00:13:03,748 -- 00:13:06,217
also severe wind and hail.
00:13:06,217 -- 00:13:09,887
And for each of those four climate related risks,
00:13:09,887 -- 00:13:12,556
we know how to protect our buildings
00:13:12,556 -- 00:13:13,491
and our infrastructure.
00:13:13,491 -- 00:13:16,093
All of the protective actions are known.
00:13:17,661 -- 00:13:18,329
Critical
00:13:18,329 -- 00:13:20,030
thing for the financial services
00:13:20,030 -- 00:13:22,433
sector is to encourage people
00:13:22,433 -- 00:13:26,437
to start to bring those features into effect.
00:13:26,737 -- 00:13:28,773
My home is 130 years old.
00:13:28,773 -- 00:13:30,341
Most of the modern ideas
00:13:30,341 -- 00:13:33,010
weren't put into the home when it was built.
00:13:33,010 -- 00:13:34,044
They have to be added.
00:13:34,044 -- 00:13:36,180
And so I've added it to my home.
00:13:36,180 -- 00:13:39,517
But, the data shows for most of the homes in Ontario,
00:13:39,517 -- 00:13:41,418
the most
00:13:41,418 -- 00:13:45,089
fundamental protective measures are not yet in place.
00:13:45,089 -- 00:13:45,489
And that's
00:13:45,489 -- 00:13:47,124
why the losses have been getting up
00:13:47,124 -- 00:13:49,960
to the billions of dollars a year.
00:13:49,960 -- 00:13:51,996
That's why,
00:13:51,996 -- 00:13:54,865
the financial services industry is struggling because,
00:13:54,865 -- 00:13:56,500
you have our housing sector
00:13:56,500 -- 00:13:57,801
spending billions of dollars
00:13:57,801 -- 00:13:59,003
just to fix
00:13:59,003 -- 00:13:59,603
the damage
00:13:59,603 -- 00:14:00,337
that's been occurring
00:14:00,337 -- 00:14:03,607
because of flooding, a wildfire and wind.
00:14:03,607 -- 00:14:05,609
And until we start making the investments
00:14:05,609 -- 00:14:07,411
to protect ourselves,
00:14:07,411 -- 00:14:09,346
we're going to have these problems
00:14:09,346 -- 00:14:11,315
grow with climate change.
00:14:11,315 -- 00:14:12,683
But as Blair touched on,
00:14:12,683 -- 00:14:15,319
the exciting news is that we do know what to do.
00:14:15,319 -- 00:14:18,155
We've got proven solutions that are affordable.
00:14:18,155 -- 00:14:19,023
Our research shows
00:14:19,023 -- 00:14:20,891
you spend a dollar and you save 5 to 10.
00:14:21,992 -- 00:14:24,028
So the economic case is very, very strong.
00:14:24,028 -- 00:14:25,095
We just need to get more people
00:14:25,095 -- 00:14:28,098
to act upon the known science.
00:14:28,098 -- 00:14:29,099
That's great.
00:14:29,099 -- 00:14:30,934
So we talked about Insurance.
00:14:30,934 -- 00:14:33,203
We talked about Credit Unions.
00:14:33,203 -- 00:14:34,338
What about,
00:14:34,338 -- 00:14:36,974
Pension Plans that have an obligation
00:14:36,974 -- 00:14:40,077
towards their investors or the beneficiaries?
00:14:40,077 -- 00:14:43,047
Any thoughts on that front?
00:14:43,047 -- 00:14:44,581
Yes.
00:14:44,581 -- 00:14:48,886
So the Pension Plans in the country to date
00:14:49,253 -- 00:14:51,288
in talking about climate change
00:14:51,288 -- 00:14:54,158
have almost been looking exclusively
00:14:54,158 -- 00:14:55,993
at transition risk.
00:14:55,993 -- 00:14:56,560
What does it mean
00:14:56,560 -- 00:14:58,328
to portfolios for companies
00:14:58,328 -- 00:15:01,565
they invest in to as they have to
00:15:01,565 -- 00:15:02,800
move towards net zero
00:15:02,800 -- 00:15:04,768
and lowering their carbon footprint
00:15:04,768 -- 00:15:06,036
and realizing the costs
00:15:06,036 -- 00:15:07,404
associated with a carbon price.
00:15:07,404 -- 00:15:11,708
So there's lots of good thinking around that, largely
00:15:11,708 -- 00:15:15,679
driven by SFAC, the sustainable
00:15:16,146 -- 00:15:16,947
financial...
00:15:16,947 -- 00:15:19,349
I forgot what SFAC stands for now
00:15:19,349 -- 00:15:21,118
because I'm trying to think about it. Doesn't matter.
00:15:21,118 -- 00:15:23,287
The point is, there's been a lot of work
00:15:26,290 -- 00:15:29,426
on transition risk factoring into pension funds.
00:15:29,426 -- 00:15:33,430
But what's now also happening is, is we're looking at
00:15:34,998 -- 00:15:36,266
physical climate risk
00:15:36,266 -- 00:15:37,935
and the incorporation of physical climate
00:15:37,935 -- 00:15:40,737
risk into investment decision making,
00:15:40,737 -- 00:15:42,306
such that,
00:15:42,306 -- 00:15:44,208
and across different industry
00:15:44,208 -- 00:15:46,443
sectors, mining, forestry, petroleum,
00:15:46,443 -- 00:15:47,811
utilities, hospitality,
00:15:47,811 -- 00:15:51,448
telecommunications, financial services.
00:15:51,448 -- 00:15:54,451
We are making fairly good strides
00:15:54,451 -- 00:15:55,185
forward,
00:15:55,185 -- 00:15:58,555
saying under each one of these industry sectors,
00:15:58,555 -- 00:16:00,157
what are the key perils
00:16:00,157 -- 00:16:02,793
flooding, wildfire, ice storm, snow storm,
00:16:02,793 -- 00:16:03,427
whatever it might be,
00:16:03,427 -- 00:16:04,861
that are most problematic
00:16:04,861 -- 00:16:06,830
for the continuity of business operations
00:16:06,830 -- 00:16:09,099
on all these different industry sectors?
00:16:09,099 -- 00:16:13,003
And then below each one of these,
00:16:13,003 -- 00:16:15,339
impacts, perils,
00:16:15,339 -- 00:16:17,541
what are the top 1 or 2 impacts
00:16:17,541 -- 00:16:20,310
that if you are a portfolio manager,
00:16:20,310 -- 00:16:22,179
you should be zeroing in on
00:16:22,179 -- 00:16:23,614
to see if the company
00:16:23,614 -- 00:16:25,582
you're about to invest in or hold
00:16:25,582 -- 00:16:27,250
or divest the degree
00:16:27,250 -- 00:16:29,319
to which they're actually embracing actions
00:16:29,319 -- 00:16:31,188
to respond to the risk
00:16:31,188 -- 00:16:34,591
associated with that peril hitting this impact.
00:16:34,591 -- 00:16:36,660
So right now, on an industry
00:16:36,660 -- 00:16:39,730
specific basis, we're incorporating,
00:16:39,730 -- 00:16:40,998
physical climate risk
00:16:40,998 -- 00:16:42,532
into institutional investment
00:16:42,532 -- 00:16:44,534
decision making because otherwise,
00:16:44,534 -- 00:16:48,538
and by the way, every industry sector is impacted by
00:16:48,839 -- 00:16:49,973
physical climate risk.
00:16:49,973 -- 00:16:52,209
There is no sector that's immune.
00:16:52,209 -- 00:16:53,477
I had a graduate student
00:16:53,477 -- 00:16:55,879
sit down a little while ago and I said,
00:16:55,879 -- 00:16:58,014
I just want you to go through the headlines
00:16:58,014 -- 00:17:01,184
of the major newspapers for the last 5 to 8 years
00:17:01,184 -- 00:17:03,820
and write down any headline pertaining to physical
00:17:03,820 -- 00:17:05,789
climate risk, a flood or wildfire,
00:17:05,789 -- 00:17:07,991
ice storm, whatever it might be
00:17:07,991 -- 00:17:11,795
and link to a particular industry sector.
00:17:11,795 -- 00:17:13,029
And I thought,
00:17:13,029 -- 00:17:16,099
in this case, he would come back with a few headlines.
00:17:16,099 -- 00:17:18,301
Well, we could have actually, we could wallpaper,
00:17:18,301 -- 00:17:19,870
you know, the walls of this building
00:17:19,870 -- 00:17:21,538
with all the different headlines
00:17:21,538 -- 00:17:23,340
pertaining to everything from,
00:17:23,340 -- 00:17:26,576
fisheries to ice wine making, to you name it,
00:17:26,576 -- 00:17:29,346
a sector is being hit by physical climate risk.
00:17:29,346 -- 00:17:34,050
So for portfolio managers in institutional investing,
00:17:34,217 -- 00:17:36,553
they should be really looking seriously at
00:17:38,989 -- 00:17:40,190
preparing themselves to
00:17:40,190 -- 00:17:41,324
ask the right questions
00:17:41,324 -- 00:17:43,293
pertaining to physical climate risk for companies
00:17:43,293 -- 00:17:44,327
they invest in.
00:17:44,327 -- 00:17:48,331
And the tools are largely being developed to do that.
00:17:49,132 -- 00:17:52,168
That's great. So it's helping
00:17:52,168 -- 00:17:57,073
Pension Fund Managers to look at how they're invested
00:17:57,073 -- 00:17:59,409
companies are risk managing.
00:17:59,409 -- 00:18:00,277
And then from there.
00:18:00,277 -- 00:18:02,579
By the way, it's Sustainable Finance Action Council –
00:18:02,579 -- 00:18:05,215
that's SFAC. Yeah. That's great.
00:18:05,215 -- 00:18:06,483
I'm going to change gears a little bit.
00:18:06,483 -- 00:18:10,487
Just keep being very mindful of the time here.
00:18:10,754 -- 00:18:13,757
Board of Directors, you know,
00:18:13,757 -- 00:18:15,759
anything that you think
00:18:15,759 -- 00:18:17,160
a Board of Directors can do
00:18:17,160 -- 00:18:18,395
so that they're better equipped
00:18:18,395 -- 00:18:19,596
to give
00:18:19,596 -- 00:18:21,264
oversight over their management
00:18:21,264 -- 00:18:24,868
when it comes to physical climate risk.
00:18:24,868 -- 00:18:26,469
What needs to change?
00:18:26,469 -- 00:18:29,372
What advice would you have for them?
00:18:29,372 -- 00:18:30,340
Maybe I'll start with Paul.
00:18:31,941 -- 00:18:32,375
I'm really
00:18:32,375 -- 00:18:35,345
excited by the leadership that OSFI is showing to,
00:18:35,345 -- 00:18:39,616
promote disclosure by companies about how companies
00:18:39,616 -- 00:18:42,852
in the financial sector that are supervised federally
00:18:42,852 -- 00:18:47,057
are thinking about transition risk and physical risk.
00:18:47,824 -- 00:18:50,293
And some of the disclosure involves
00:18:50,293 -- 00:18:51,895
describing the management plans
00:18:51,895 -- 00:18:53,830
to deal with these risks.
00:18:53,830 -- 00:18:56,166
As management is documenting this,
00:18:56,166 -- 00:19:00,170
this is bringing the Board into the conversation.
00:19:00,236 -- 00:19:01,471
This is a new conversation,
00:19:01,471 -- 00:19:03,440
I think, for most financial institutions,
00:19:03,440 -- 00:19:06,276
as they're engaging the Board.
00:19:06,276 -- 00:19:08,311
I do believe that there's a lot of Board Members
00:19:08,311 -- 00:19:09,913
realizing that they don't feel ready
00:19:09,913 -- 00:19:11,681
for this conversation.
00:19:11,681 -- 00:19:12,749
They don't have the background,
00:19:12,749 -- 00:19:15,952
they don't have the training.
00:19:15,952 -- 00:19:18,855
You have a lot of experts that Blair and I work
00:19:18,855 -- 00:19:21,424
with in the climate community,
00:19:21,424 -- 00:19:24,160
not great communicators.
00:19:24,160 -- 00:19:25,228
So,
00:19:25,228 -- 00:19:26,229
climate can be made
00:19:26,229 -- 00:19:28,731
into a very complicated conversation.
00:19:28,731 -- 00:19:30,633
So who are the right people to have on the Board?
00:19:30,633 -- 00:19:33,036
It's not always a climate specialist
00:19:33,036 -- 00:19:34,437
who can
00:19:34,437 -- 00:19:35,371
give that guidance
00:19:35,371 -- 00:19:38,841
about what the right practices are for industry.
00:19:38,841 -- 00:19:40,143
So it's a real art to find out
00:19:40,143 -- 00:19:41,244
who should be on the Board
00:19:41,244 -- 00:19:42,212
and what kind of training
00:19:42,212 -- 00:19:44,013
the Board Members should have.
00:19:44,013 -- 00:19:48,251
But, having the overwhelming evidence
00:19:48,718 -- 00:19:49,586
that climate change
00:19:49,586 -- 00:19:51,554
is one of the most profound impacts
00:19:51,554 -- 00:19:54,190
that's happening for all the financial sectors,
00:19:54,190 -- 00:19:55,992
having Boards think about
00:19:55,992 -- 00:19:58,227
who are the right people to have on the Board
00:19:58,227 -- 00:19:59,262
and what's the right training
00:19:59,262 -- 00:20:00,797
so that they can support management,
00:20:00,797 -- 00:20:02,699
make decisions about investments
00:20:02,699 -- 00:20:05,335
with divisions, about loans,
00:20:05,335 -- 00:20:07,103
decisions about where to ensure
00:20:08,137 -- 00:20:10,340
is a really big need.
00:20:10,340 -- 00:20:12,342
And, the push going on
00:20:12,342 -- 00:20:14,477
within the prudential side
00:20:14,477 -- 00:20:17,046
through OSFI has been really exciting.
00:20:17,046 -- 00:20:18,881
It's great. Blair anything to add?
00:20:18,881 -- 00:20:19,949
Yeah, I, I would say
00:20:19,949 -- 00:20:22,385
because we're asked to be in front of a lot of Boards
00:20:22,385 -- 00:20:23,553
talking about this stuff.
00:20:23,553 -- 00:20:25,555
And I find for Boards, by and large,
00:20:25,555 -- 00:20:28,191
you know, very competent people sitting on Boards.
00:20:28,191 -- 00:20:29,959
And I don't know if it's by luck or design
00:20:29,959 -- 00:20:31,027
or a combination of both,
00:20:31,027 -- 00:20:33,062
but I find they tend to have
00:20:33,062 -- 00:20:35,765
people on the Board who know about cybersecurity
00:20:35,765 -- 00:20:37,600
or artificial intelligence
00:20:37,600 -- 00:20:38,901
or, you know, where long term
00:20:38,901 -- 00:20:39,936
interest rates are going to head
00:20:39,936 -- 00:20:43,706
at a global or national level, whatever it might be.
00:20:43,706 -- 00:20:47,744
But by and large, there's a real paucity of expertise
00:20:47,744 -- 00:20:51,747
at the Board level in reference to climate change.
00:20:51,747 -- 00:20:52,648
And I think they need
00:20:52,648 -- 00:20:54,383
to take a more conservative effort
00:20:54,383 -- 00:20:59,288
to find people who are fluent in that discussion and,
00:20:59,288 -- 00:21:01,257
and bring their expertise to the table.
00:21:01,257 -- 00:21:04,594
It's sort of like having a pharmaceutical company
00:21:04,594 -- 00:21:06,496
that has nobody on the Board
00:21:06,496 -- 00:21:09,031
of Directors, who's a pharmacist or a medical doctor,
00:21:09,031 -- 00:21:09,899
you know,
00:21:09,899 -- 00:21:10,833
it would leap,
00:21:10,833 -- 00:21:13,536
it would stand out as a void in knowledge.
00:21:13,536 -- 00:21:15,838
But for Boards to give appropriate
00:21:15,838 -- 00:21:18,641
oversight to management on this file,
00:21:18,641 -- 00:21:20,109
I think they need someone
00:21:20,109 -- 00:21:22,745
who's taken more than a weekend course
00:21:22,745 -- 00:21:23,980
on climate change.
00:21:25,548 -- 00:21:25,982
It's great.
00:21:25,982 -- 00:21:29,418
So education and seeking expert advice,
00:21:29,418 -- 00:21:30,486
that's what it is.
00:21:30,486 -- 00:21:32,288
So let's switch a little bit.
00:21:32,288 -- 00:21:35,458
Let's talk about the role of financial regulators.
00:21:35,458 -- 00:21:38,895
What are some immediate and mid-term actions
00:21:38,895 -- 00:21:41,397
that a financial regulator like FSRA
00:21:41,397 -- 00:21:43,199
should consider to make sure
00:21:43,199 -- 00:21:44,533
that we have a healthy market
00:21:44,533 -- 00:21:48,537
and consumers are continued to be offering choices.
00:21:49,639 -- 00:21:53,476
Mark shared with us in the conversation earlier today
00:21:53,476 -- 00:21:57,480
just how broad a mandate FSRA has
00:21:57,680 -- 00:22:01,584
and how specific some of the questions are as you move
00:22:01,584 -- 00:22:03,252
from one financial sector
00:22:03,252 -- 00:22:06,288
to another, to another, to another, to another.
00:22:06,288 -- 00:22:08,658
Climate change is cutting across all of that.
00:22:08,658 -- 00:22:12,361
And and there's not many issues like climate change
00:22:12,361 -- 00:22:14,330
that are affecting
00:22:14,330 -- 00:22:17,666
all aspects of what's happening here.
00:22:17,666 -- 00:22:20,770
So that's distinct and special here.
00:22:23,105 -- 00:22:24,040
And so for me
00:22:24,040 -- 00:22:25,708
that's quite intriguing that
00:22:25,708 -- 00:22:28,477
bringing climate change into this conversation,
00:22:28,477 -- 00:22:30,746
despite some nuances about how it affects
00:22:30,746 -- 00:22:32,114
individual sectors different,
00:22:32,114 -- 00:22:34,216
it is definitely cutting across all the sectors.
00:22:34,216 -- 00:22:35,785
So it's having a very
00:22:35,785 -- 00:22:38,654
profound impact on all of the sectors.
00:22:38,654 -- 00:22:42,658
So there is an opportunity for FSRA to get involved.
00:22:43,759 -- 00:22:46,529
It will certainly include a lot of the information
00:22:46,529 -- 00:22:50,466
type role that FSRA has regularly been playing.
00:22:50,466 -- 00:22:52,501
How all of the different groups
00:22:52,501 -- 00:22:53,702
that are being supervised
00:22:53,702 -- 00:22:55,871
can be informed with common information
00:22:55,871 -- 00:22:58,440
about some things that are happening,
00:22:58,440 -- 00:23:01,043
and that can happen quickly.
00:23:01,043 -- 00:23:03,279
The fact that as Blair and I are sharing
00:23:03,279 -- 00:23:05,614
on the physical damage side, the solutions are known.
00:23:05,614 -- 00:23:06,515
Let's get on with them.
00:23:06,515 -- 00:23:09,251
I mean, some of these things can be done today.
00:23:09,251 -- 00:23:10,886
They don't need time to develop.
00:23:10,886 -- 00:23:12,254
They can be put out very quickly.
00:23:13,289 -- 00:23:15,057
There are other elements that
00:23:15,057 -- 00:23:18,027
definitely spread over the multi-year focus
00:23:18,027 -- 00:23:18,994
that you're asking about
00:23:18,994 -- 00:23:19,728
and what
00:23:19,728 -- 00:23:21,230
the supervisors need to do
00:23:21,230 -- 00:23:23,999
over a longer period of time.
00:23:23,999 -- 00:23:27,069
OSFI monitored this file for many years
00:23:27,069 -- 00:23:28,837
and it's just recently decided
00:23:28,837 -- 00:23:31,240
to become very proactive,
00:23:31,240 -- 00:23:34,343
focusing primarily on disclosure,
00:23:34,343 -- 00:23:37,413
requiring companies to disclose.
00:23:37,413 -- 00:23:40,983
That's a really powerful thought process
00:23:40,983 -- 00:23:44,820
that forces the thinking within companies
00:23:44,820 -- 00:23:47,856
and getting that out to the supervisor,
00:23:47,856 -- 00:23:49,725
but to others about how
00:23:49,725 -- 00:23:52,261
these are being managed within the companies
00:23:52,261 -- 00:23:56,332
and frankly, their commitment at OSFI to always deal
00:23:56,332 -- 00:23:57,399
with prudential matters.
00:23:57,399 -- 00:23:59,134
They're pushing some limits here.
00:23:59,134 -- 00:24:01,070
Some of the way they're approaching this issue,
00:24:01,070 -- 00:24:04,306
I find that exciting. And I think that's helpful.
00:24:04,306 -- 00:24:06,608
So how FSRA can move around
00:24:06,608 -- 00:24:09,078
some of the leadership coming from OSFI,
00:24:09,078 -- 00:24:11,313
there are many institutions
00:24:11,313 -- 00:24:12,948
that are not federally supervised.
00:24:12,948 -- 00:24:16,652
And to expect similar expectations about disclosure,
00:24:17,686 -- 00:24:19,221
to make sure that they have access
00:24:19,221 -- 00:24:21,356
to similar type of information
00:24:21,356 -- 00:24:22,391
so that the messaging
00:24:22,391 -- 00:24:24,827
coming from one regulator in Canada
00:24:24,827 -- 00:24:26,495
about how the risk is
00:24:26,495 -- 00:24:28,697
evolving is not contradictory
00:24:28,697 -- 00:24:30,599
to what would come from FSRA.
00:24:30,599 -- 00:24:33,035
So coordinating some of the messaging going out
00:24:33,035 -- 00:24:34,303
are just a couple examples
00:24:34,303 -- 00:24:38,107
of some things that FSRA can do. Great, Blair.
00:24:38,107 -- 00:24:40,476
I like it very much like FSRA's mandate
00:24:40,476 -- 00:24:42,644
to serve the interests of consumers.
00:24:42,644 -- 00:24:45,214
And just a very practical example,
00:24:45,214 -- 00:24:47,649
and I'm not quite sure where FSRA’s
00:24:47,649 -- 00:24:49,218
authority stops and starts.
00:24:49,218 -- 00:24:53,222
But for example, here's a simple action item
00:24:53,589 -- 00:24:56,492
anybody who's getting a mortgage in this country
00:24:56,492 -- 00:24:57,993
with the closing package
00:24:57,993 -- 00:25:00,596
and then twice a year as a mail out, as a reminder,
00:25:00,596 -- 00:25:01,630
it should follow.
00:25:01,630 -- 00:25:03,365
They should be receiving direction
00:25:03,365 -- 00:25:04,900
on how to protect that home
00:25:04,900 -- 00:25:06,668
from basement flooding, period.
00:25:06,668 -- 00:25:08,737
If you own a home somewhere where it rains,
00:25:08,737 -- 00:25:11,473
your house is subject to flood risk, period.
00:25:11,473 -- 00:25:13,275
And some areas more than others.
00:25:13,275 -- 00:25:15,010
But that's the way it is.
00:25:15,010 -- 00:25:17,212
So when somebody gets a mortgage
00:25:17,212 -- 00:25:18,680
in that closing package
00:25:18,680 -- 00:25:20,048
and this is now, you know,
00:25:20,048 -- 00:25:21,216
the thing that they're going to get up
00:25:21,216 -- 00:25:21,583
and work
00:25:21,583 -- 00:25:23,819
for 25 years of their life to pay for it,
00:25:23,819 -- 00:25:25,954
it's probably going to be their retirement plan.
00:25:25,954 -- 00:25:27,956
You want to protect that investment.
00:25:27,956 -- 00:25:30,659
So I would make sure that in that closing package,
00:25:30,659 -- 00:25:32,794
there are simple, straightforward information.
00:25:32,794 -- 00:25:35,230
And it exists that any organization
00:25:35,230 -- 00:25:36,531
can put their logo on
00:25:36,531 -- 00:25:36,932
that says
00:25:36,932 -- 00:25:38,767
and by the way, for you, the homeowner,
00:25:38,767 -- 00:25:41,003
and we're now a partner in this deal with you,
00:25:41,003 -- 00:25:43,639
here's how you protect this property
00:25:43,639 -- 00:25:45,040
from basement flooding.
00:25:45,040 -- 00:25:45,607
And the average
00:25:45,607 -- 00:25:46,875
cost of a flooded basement
00:25:46,875 -- 00:25:49,277
on Ontario right now is $43,000.
00:25:49,277 -- 00:25:51,380
So if you have the average flood,
00:25:51,380 -- 00:25:52,748
that's not the place you want to be.
00:25:52,748 -- 00:25:55,017
If you could avoid it, avoid it.
00:25:55,017 -- 00:25:56,918
That's great. Thank you.
00:25:56,918 -- 00:26:01,023
So we may have some time for questions from
00:26:01,023 -- 00:26:01,690
the audience.
00:26:04,226 -- 00:26:05,360
And we'll see.
00:26:05,360 -- 00:26:08,530
I think the questions will be popping up
00:26:08,530 -- 00:26:12,501
on the monitor.
00:26:15,404 -- 00:26:15,771
Right.
00:26:15,771 -- 00:26:21,910
So this is a question on how do P&C Insurers
00:26:22,344 -- 00:26:27,549
best educate, inform and incentivize policy holders
00:26:27,549 -- 00:26:28,683
to take more action
00:26:28,683 -- 00:26:32,687
to mitigate exposure to extreme weather?
00:26:33,955 -- 00:26:35,724
Okay.
00:26:35,724 -- 00:26:37,826
I'll go quickly and...
00:26:37,826 -- 00:26:41,830
Up to about maybe 4 or 5 years ago,
00:26:41,830 -- 00:26:43,365
even when you talk to the Presidents
00:26:43,365 -- 00:26:45,634
and CEOs of the major P&C companies,
00:26:45,634 -- 00:26:47,969
they said themselves that the direction
00:26:47,969 -- 00:26:49,237
they gave to policyholders
00:26:49,237 -- 00:26:51,573
on how to protect properties from flooding or wildfire
00:26:51,573 -- 00:26:54,242
and so forth or what even their coverage
00:26:54,242 -- 00:26:56,211
was very poor and confusing.
00:26:56,211 -- 00:26:57,946
So one of the things they're doing now is,
00:26:57,946 -- 00:26:59,047
first of all, just in terms
00:26:59,047 -- 00:27:00,715
of what you're covered for versus
00:27:00,715 -- 00:27:01,783
what you're not covered for
00:27:01,783 -- 00:27:04,386
for overland flooding, for sewer backup,
00:27:04,386 -- 00:27:06,988
for just conventional flood risk in a basement.
00:27:08,123 -- 00:27:09,758
They're doing a much, much better job.
00:27:09,758 -- 00:27:11,860
Most of the insurers now explaining this stuff
00:27:11,860 -- 00:27:13,261
in plain, simple language
00:27:13,261 -- 00:27:16,331
that people can read and understand. That's good.
00:27:16,331 -- 00:27:19,901
But also, the insurers are now very much
00:27:19,901 -- 00:27:22,170
on the leading edge of the curve in Canada
00:27:22,170 -- 00:27:27,042
as to supporting better understanding of the actions
00:27:27,042 -- 00:27:28,310
to be to be taken
00:27:28,310 -- 00:27:29,344
to mitigate
00:27:29,344 -- 00:27:30,979
risk in the country from flooding,
00:27:30,979 -- 00:27:33,348
wildfire, extreme heat, wind.
00:27:33,348 -- 00:27:34,883
They're supporting that research.
00:27:34,883 -- 00:27:37,018
And then
00:27:37,018 -- 00:27:39,554
helping to deploy the inculcation
00:27:39,554 -- 00:27:41,923
of that research into day to day operations
00:27:41,923 -- 00:27:44,326
to actually get risk out of the system.
00:27:44,326 -- 00:27:46,494
What we want to do is get all the risk
00:27:46,494 -- 00:27:47,162
out of the system.
00:27:47,162 -- 00:27:47,929
You can
00:27:47,929 -- 00:27:49,297
and then deal
00:27:49,297 -- 00:27:51,266
with the pricing of what's ever left over.
00:27:52,534 -- 00:27:53,134
The small part.
00:27:53,134 -- 00:27:55,403
I that is,
00:27:55,403 -- 00:27:57,572
the longer answer is I've written a book.
00:27:57,572 -- 00:28:00,375
So if you'd like to read my book, I have,
00:28:00,375 -- 00:28:02,711
laid it all out in detail.
00:28:02,711 -- 00:28:04,179
“Climate Risks Implications
00:28:04,179 -- 00:28:07,382
for the Insurance Industry in Canada.”
00:28:07,382 -- 00:28:08,683
Call our institute,
00:28:08,683 -- 00:28:11,119
we have 120 companies that support our work.
00:28:11,119 -- 00:28:13,321
And we give to them materials
00:28:13,321 -- 00:28:17,225
to give out to policyholders. We give to them...
00:28:17,225 -- 00:28:19,828
We have showcases, displays,
00:28:19,828 -- 00:28:22,096
videos, all kinds of materials.
00:28:22,096 -- 00:28:25,934
Any insurer in Ontario who would like to
00:28:25,934 -- 00:28:26,501
use members,
00:28:26,501 -- 00:28:28,403
I think 90 whatever percent
00:28:28,403 -- 00:28:29,504
are members of our institute.
00:28:29,504 -- 00:28:31,940
So we give our materials out and
00:28:31,940 -- 00:28:33,074
we're delighted to help them
00:28:33,074 -- 00:28:35,376
promote it to policyholders. Right.
00:28:35,376 -- 00:28:36,711
So we have another question.
00:28:36,711 -- 00:28:38,680
Very similar question.
00:28:38,680 -- 00:28:41,783
This is not about educating policyholders,
00:28:41,783 -- 00:28:45,019
but what insurance companies can do to prepare,
00:28:45,019 -- 00:28:46,688
since physical climate change
00:28:46,688 -- 00:28:48,056
is just going to increase.
00:28:49,123 -- 00:28:50,959
So this is where insurance companies
00:28:50,959 -- 00:28:52,927
are way ahead of the rest of the financial sector.
00:28:52,927 -- 00:28:54,762
They have models.
00:28:54,762 -- 00:28:57,165
They have actuarial data on actual losses
00:28:57,165 -- 00:28:58,766
that they've experienced.
00:28:58,766 -- 00:29:01,502
They understand which are territories,
00:29:01,502 -- 00:29:03,738
which regions have the greatest risk.
00:29:03,738 -- 00:29:05,540
They know the features of a home
00:29:05,540 -- 00:29:06,641
that we've been providing them,
00:29:06,641 -- 00:29:08,142
saying this home has higher risk.
00:29:08,142 -- 00:29:10,478
This home has lower risk.
00:29:10,478 -- 00:29:12,580
That's hard
00:29:12,580 -- 00:29:15,883
evidence that's available to all insurance companies.
00:29:15,883 -- 00:29:17,318
It's part of their practices.
00:29:17,318 -- 00:29:18,353
It's part of their pricing.
00:29:18,353 -- 00:29:21,889
It's part of their product design.
00:29:21,889 -- 00:29:22,924
Part of their choices
00:29:22,924 -- 00:29:25,059
about where insurance is available, not available.
00:29:25,059 -- 00:29:28,629
Whatever...There's just a lot of science available.
00:29:28,629 -- 00:29:30,031
Insurance companies are using it.
00:29:30,031 -- 00:29:31,699
I'm always surprised when I talk to people
00:29:31,699 -- 00:29:32,934
who are in the insurance industry
00:29:32,934 -- 00:29:34,869
why they don't use the same information
00:29:34,869 -- 00:29:36,537
to decide where to give a mortgage
00:29:36,537 -- 00:29:37,839
and where to make investments.
00:29:37,839 -- 00:29:40,808
But, insurance companies have a lot of data
00:29:40,808 -- 00:29:42,143
to do this.
00:29:42,143 -- 00:29:43,611
Maybe I can add one here. Sure.
00:29:43,611 -- 00:29:45,480
Where we spend a lot of time,
00:29:45,480 -- 00:29:47,081
now, I spend a lot more of my time with,
00:29:47,081 -- 00:29:49,117
I don't need more climate scientists
00:29:49,117 -- 00:29:51,452
tell me that the climate is, you know, things are bad.
00:29:51,452 -- 00:29:53,755
Or documenting
00:29:53,755 -- 00:29:54,756
by the way,
00:29:54,756 -- 00:29:56,457
the catastrophic loss insurable claims
00:29:56,457 -- 00:29:58,593
data in the country, it's not just going up,
00:29:58,593 -- 00:30:00,228
it's going up curvilinearly.
00:30:00,228 -- 00:30:01,929
Things are getting worse, faster.
00:30:01,929 -- 00:30:03,698
But we have known solutions.
00:30:03,698 -- 00:30:06,267
So where I spend my time now is much more with,
00:30:06,267 -- 00:30:08,903
behavioral economists, behavioral psychologists
00:30:08,903 -- 00:30:09,403
to look at
00:30:09,403 -- 00:30:10,838
how do you motivate the masses
00:30:10,838 -- 00:30:12,640
to behave in a particular way?
00:30:12,640 -- 00:30:13,674
We've got the tools
00:30:13,674 -- 00:30:15,543
but we're not utilizing the tools.
00:30:15,543 -- 00:30:17,578
So the trick is one of now
00:30:17,578 -- 00:30:19,680
if human psychology to a certain extent.
00:30:19,680 -- 00:30:21,549
So that's where we're spending
00:30:21,549 -- 00:30:22,450
more and more of our time.
00:30:23,451 -- 00:30:25,353
Thinking about how consumers
00:30:25,353 -- 00:30:26,454
use the information
00:30:26,454 -- 00:30:27,722
and then providing it to
00:30:27,722 -- 00:30:30,458
in a way that is, that resonate with them.
00:30:30,458 -- 00:30:31,726
So I think we probably have time
00:30:31,726 -- 00:30:33,661
for one more question because,
00:30:33,661 -- 00:30:37,131
because we'll have to move on to the next session.
00:30:37,131 -- 00:30:39,166
So, this one came from
00:30:39,166 -- 00:30:40,268
what do you think
00:30:40,268 -- 00:30:41,969
would be the right training for Boards
00:30:41,969 -- 00:30:43,971
regarding climate risk?
00:30:43,971 -- 00:30:47,975
And with so many regulators and bodies involved,
00:30:48,075 -- 00:30:52,079
who should the Boards be following?
00:30:53,347 -- 00:30:54,615
Blair and I spent a lot of time
00:30:54,615 -- 00:30:58,019
talking to boards in the insurance sector
00:30:58,019 -- 00:30:59,553
and so I have lots of experience.
00:30:59,553 -- 00:31:01,255
I could talk about,
00:31:01,255 -- 00:31:02,623
some of the particular questions
00:31:02,623 -- 00:31:03,691
that insurance companies
00:31:03,691 -- 00:31:07,929
give about product design pricing,
00:31:08,629 -- 00:31:12,466
use of models, avoiding solvency risk.
00:31:12,466 -- 00:31:13,267
We've had
00:31:13,267 -- 00:31:15,069
no property companies
00:31:15,069 -- 00:31:17,438
go insolvent in decades in this country
00:31:17,438 -- 00:31:19,440
because they've thought through all these things.
00:31:21,008 -- 00:31:23,744
And so getting the Board Members
00:31:23,744 -- 00:31:28,849
in insurance informed is sort of common.
00:31:31,052 -- 00:31:33,421
Occasionally, I've been invited to some Boards
00:31:33,421 -- 00:31:36,424
that are not in insurance, and
00:31:36,424 -- 00:31:38,392
I don't get good questions.
00:31:38,392 -- 00:31:41,529
I mean there was a time in insurance,
00:31:41,529 -- 00:31:43,564
I've been doing this stuff for 30 years.
00:31:43,564 -- 00:31:44,965
The insurance people didn't know what to ask.
00:31:44,965 -- 00:31:47,301
20, 30 years ago...but
00:31:47,301 -- 00:31:48,803
the conversations outside of insurance
00:31:48,803 -- 00:31:53,707
that I occasionally get invited to are very early and
00:31:55,142 -- 00:31:57,111
basic questions.
00:31:57,111 -- 00:31:59,380
Insurance companies would never give insurance
00:31:59,380 -- 00:31:59,947
to somebody
00:31:59,947 -- 00:32:02,216
who's been designated by the province of Ontario
00:32:02,216 -- 00:32:04,018
at extreme or high risk of flooding.
00:32:04,018 -- 00:32:07,555
You just can't get insurance from an insurance company,
00:32:07,555 -- 00:32:10,024
but you can get a loan.
00:32:10,024 -- 00:32:12,693
I mean.
00:32:12,693 -- 00:32:14,228
There you go.
00:32:14,228 -- 00:32:17,565
So the process, some of the knowledge that
00:32:17,565 -- 00:32:19,967
is available for Boards
00:32:21,235 -- 00:32:24,405
Management as well has to get going more on
00:32:24,405 -- 00:32:25,172
these issues.
00:32:25,172 -- 00:32:26,841
I'm more familiar with physical risk.
00:32:26,841 -- 00:32:30,177
That's what I work on. But Boards,
00:32:30,177 -- 00:32:31,579
yeah, but
00:32:31,579 -- 00:32:33,314
Management and Boards
00:32:33,314 -- 00:32:35,749
really need to get working on this.
00:32:35,749 -- 00:32:37,117
And also not, you know,
00:32:37,117 -- 00:32:38,819
Not to go back to the depressing stuff,
00:32:38,819 -- 00:32:41,488
but I don't think we've mentioned this yet,
00:32:41,488 -- 00:32:43,357
but we now have,
00:32:43,357 -- 00:32:46,560
10% of homes in Canada are no longer insurable
00:32:46,560 -- 00:32:47,595
relative to flood risk.
00:32:47,595 -- 00:32:48,362
That's 1.5
00:32:48,362 -- 00:32:50,030
million people in Canada
00:32:50,030 -- 00:32:52,933
can't get insurance coverage for their homes for
00:32:52,933 -- 00:32:54,001
basement flooding.
00:32:54,001 -- 00:32:55,970
They can still get it for theft and fire,
00:32:55,970 -- 00:32:58,205
but not for basement flooding.
00:32:58,205 -- 00:33:00,741
The good thing is,
00:33:00,741 -- 00:33:02,176
given that reality,
00:33:02,176 -- 00:33:06,013
you can still get a mortgage without flood insurance.
00:33:06,013 -- 00:33:09,350
However, we're starting to head into a direction
00:33:09,350 -- 00:33:12,252
where for wildfire risk in this country is becoming
00:33:12,252 -- 00:33:14,455
so prominent in certain regions
00:33:14,455 -- 00:33:16,724
that it's just a matter of time,
00:33:16,724 -- 00:33:18,726
as has already happened in California,
00:33:18,726 -- 00:33:20,427
with Allstate and State Farm.
00:33:20,427 -- 00:33:21,695
They're not writing new house
00:33:21,695 -- 00:33:23,797
insurance for fire risk in California.
00:33:23,797 -- 00:33:26,233
Well, Canada isn't immune to that either.
00:33:26,233 -- 00:33:28,369
So what happens if it just,
00:33:28,369 -- 00:33:30,537
you know, let's go beyond Ontario for the moment.
00:33:30,537 -- 00:33:32,139
If you're in, northern
00:33:32,139 -- 00:33:33,941
Alberta or parts of British Columbia
00:33:33,941 -- 00:33:34,908
where you can no longer
00:33:34,908 -- 00:33:36,543
get fire insurance for your home,
00:33:36,543 -- 00:33:37,811
because without fire insurance,
00:33:37,811 -- 00:33:39,346
you can't get a mortgage.
00:33:39,346 -- 00:33:41,582
I spent a lot of time with CMHC
00:33:41,582 -- 00:33:42,983
and brought this question up
00:33:42,983 -- 00:33:45,152
just a little while ago to the lenders
00:33:45,152 -- 00:33:46,553
working group of CMHC,
00:33:46,553 -- 00:33:48,222
which is basically the big banks
00:33:48,222 -- 00:33:50,290
that hold the mortgages in the country
00:33:50,290 -- 00:33:51,325
and said, you know,
00:33:51,325 -- 00:33:52,693
what is the plan
00:33:52,693 -- 00:33:55,395
if fire insurance isn't available?
00:33:55,395 -- 00:33:55,929
What is that?
00:33:55,929 -- 00:33:57,297
What are the repercussions of that?
00:33:57,297 -- 00:33:58,298
And how are we going to handle this
00:33:58,298 -- 00:34:00,400
from a mortgage perspective?
00:34:00,400 -- 00:34:02,136
And the room just goes dead quiet.
00:34:02,136 -- 00:34:03,537
You know, there was no plan.
00:34:03,537 -- 00:34:07,541
So this is the direction we're heading.
00:34:07,808 -- 00:34:11,378
And as bad as it may seem now, it's just.
00:34:11,378 -- 00:34:12,980
I'm not trying to be dramatic.
00:34:12,980 -- 00:34:14,615
Actually, I'm trying to be dramatic.
00:34:14,615 -- 00:34:17,851
We need to prepare for a more formidable future
00:34:17,851 -- 00:34:19,286
that's coming at us.
00:34:19,286 -- 00:34:22,322
And, we're starting to see these expressions
00:34:22,322 -- 00:34:23,457
with
00:34:23,457 -- 00:34:24,625
Desjardins talked about we're now
00:34:24,625 -- 00:34:26,627
not going to hold mortgages for certain communities going back.
00:34:27,594 -- 00:34:29,096
That's just the tip of the iceberg.
00:34:29,096 -- 00:34:30,998
It's going to keep coming, coming and coming.
00:34:30,998 -- 00:34:33,767
So, Canada has been sleepwalking
00:34:33,767 -- 00:34:34,902
in terms of preparedness
00:34:34,902 -- 00:34:36,536
for climate change and extreme weather risks.
00:34:36,536 -- 00:34:37,537
We need to pick up the pace.
00:34:37,537 -- 00:34:39,139
And here's a question to the audience.
00:34:40,207 -- 00:34:42,809
Canada now has...
00:34:42,809 -- 00:34:43,210
no...
00:34:43,210 -- 00:34:44,111
I'm going to ask the question
00:34:44,111 -- 00:34:45,145
and then I'll explain it.
00:34:45,145 -- 00:34:46,346
How many people here,
00:34:46,346 -- 00:34:47,514
by way of show of hands
00:34:47,514 -- 00:34:51,018
and by show of hands, I mean, like show of hands,
00:34:51,018 -- 00:34:51,718
are familiar
00:34:51,718 -- 00:34:55,722
with Canada's National Adaptation Strategy.
00:34:56,657 -- 00:34:58,525
Okay, so there's more or less
00:34:58,525 -- 00:34:59,926
600 people in this room,
00:34:59,926 -- 00:35:02,095
and there's about seven people have heard of Canada's
00:35:02,095 -- 00:35:04,131
National Adaptation Strategy.
00:35:04,131 -- 00:35:05,565
Get familiar with it.
00:35:05,565 -- 00:35:06,333
Canada now
00:35:06,333 -- 00:35:07,868
launched its national adaptation
00:35:07,868 -- 00:35:10,937
strategy of June, July of last year.
00:35:10,937 -- 00:35:13,040
The primary minister on it as Minister
00:35:13,040 -- 00:35:14,741
Guilbeault from Minister of Environment
00:35:14,741 -- 00:35:16,176
and Climate Change.
00:35:16,176 -- 00:35:17,844
In that strategy,
00:35:17,844 -- 00:35:19,579
there are 26 targets in it
00:35:19,579 -- 00:35:22,749
that Canada's to meet from an adaptation perspective.
00:35:22,749 -- 00:35:25,952
Ten of which are to be realized or success realized.
00:35:25,952 -- 00:35:29,956
And meeting those targets in 2024, 25 and 26.
00:35:30,123 -- 00:35:32,025
A multiplicity of them
00:35:32,025 -- 00:35:34,861
have applicability to financial services.
00:35:34,861 -- 00:35:36,763
So, FSRA, I would say
00:35:36,763 -- 00:35:37,898
this is an area
00:35:37,898 -- 00:35:39,900
that it should become part of your DNA
00:35:39,900 -- 00:35:43,270
almost and say for those 26 targets,
00:35:43,270 -- 00:35:45,672
are there seven of them where we can make
00:35:45,672 -- 00:35:49,409
a material contribution or something like that?
00:35:49,409 -- 00:35:49,943
That's great.
00:35:49,943 -- 00:35:52,412
We're going to go to our very last question,
00:35:52,412 -- 00:35:53,713
and then we'll have to wrap up.
00:35:54,714 -- 00:35:56,016
This is from our CEO.
00:35:56,016 -- 00:35:56,917
So is
00:35:56,917 -- 00:35:58,318
there a potential conflict
00:35:58,318 -- 00:36:00,954
between prudential regulation,
00:36:00,954 -- 00:36:04,357
which is about solvency and reducing payouts
00:36:04,357 -- 00:36:05,892
and conduct regulation
00:36:05,892 -- 00:36:09,796
that focus on consumer protection, consumer choice?
00:36:09,796 -- 00:36:13,767
Yes.
00:36:13,767 -- 00:36:15,535
Would you like to elaborate a little bit.
00:36:15,535 -- 00:36:17,470
Slightly longer answer is to move away
00:36:17,470 -- 00:36:18,872
from our climate conversation.
00:36:18,872 -- 00:36:21,541
Talk about earthquake.
00:36:21,541 -- 00:36:23,176
And on the earthquake file,
00:36:23,176 -- 00:36:25,278
there are a very large number of people in Canada
00:36:25,278 -- 00:36:26,846
who don't have earthquake protection.
00:36:26,846 -- 00:36:29,616
It's available for sale, but they don't buy it
00:36:29,616 -- 00:36:33,620
because the cost of achieving our prudential
00:36:33,787 -- 00:36:36,623
expectations are really high.
00:36:36,623 -- 00:36:40,393
And, and makes the product being offered,
00:36:40,393 -- 00:36:41,328
for anybody who has it,
00:36:41,328 -- 00:36:42,262
they're under-insured
00:36:42,262 -- 00:36:44,230
because they have enormous deductibles
00:36:44,230 -- 00:36:45,865
and other things brought in anyway.
00:36:45,865 -- 00:36:50,470
So there is absolutely contradictory objectives
00:36:51,037 -- 00:36:53,306
on some of these issues.
00:36:53,306 -- 00:36:54,674
And earthquake is the one where
00:36:54,674 -- 00:36:56,543
if you want to do any homework, you'll find it
00:36:56,543 -- 00:36:57,811
in your face fairly quickly.
00:36:59,079 -- 00:37:00,947
So it's really about working with
00:37:00,947 -- 00:37:03,450
consumers, educating them, helping them.
00:37:03,450 -- 00:37:04,718
They need to do both.
00:37:04,718 -- 00:37:07,387
Prudential is really important
00:37:07,387 -- 00:37:10,857
and Market Conduct is incredibly important.
00:37:10,857 -- 00:37:14,361
So how do you get that balance.
00:37:14,361 -- 00:37:15,495
It's a challenge.
00:37:15,495 -- 00:37:17,263
Something for us to think about.
00:37:17,263 -- 00:37:18,832
We have to wrap
00:37:18,832 -- 00:37:21,134
because, we have another session coming up,
00:37:21,134 -- 00:37:24,904
but thank you for sharing your perspective on how
00:37:24,904 -- 00:37:25,905
the financial services
00:37:25,905 -- 00:37:27,941
sector can prudently manage the risk,
00:37:27,941 -- 00:37:32,712
but also keeping consumers in mind. Before we close
00:37:33,480 -- 00:37:35,048
20 seconds each,
00:37:35,048 -- 00:37:37,050
what are your final thoughts that you want to leave
00:37:37,050 -- 00:37:37,884
with the audience
00:37:37,884 -- 00:37:39,385
about specific actions
00:37:39,385 -- 00:37:43,389
that they can take to manage this risk going forward?
00:37:43,656 -- 00:37:45,592
Start with you, Blair.
00:37:45,592 -- 00:37:46,793
Everybody in this audience,
00:37:46,793 -- 00:37:49,929
relative to their area of work, should be doing
00:37:49,929 -- 00:37:51,998
sort of a deep dive self-examination
00:37:51,998 -- 00:37:54,000
on how physical climate risk
00:37:54,000 -- 00:37:56,669
may bear relevance to their work.
00:37:56,669 -- 00:38:00,240
And then the last thought is just the
00:38:00,240 -- 00:38:01,341
biggest limitation
00:38:01,341 -- 00:38:02,742
of forward movement in Canada
00:38:02,742 -- 00:38:03,409
on preparedness
00:38:03,409 -- 00:38:04,444
for climate change
00:38:04,444 -- 00:38:06,212
is lack of sense of appreciation
00:38:06,212 -- 00:38:08,414
for the need to act with urgency.
00:38:08,414 -- 00:38:09,883
We've got to we've got to,
00:38:09,883 -- 00:38:11,284
urgency has got to come fire up
00:38:11,284 -- 00:38:12,385
higher up on the food chain.
00:38:13,453 -- 00:38:15,388
The change that's happened to the climate
00:38:15,388 -- 00:38:17,223
is very small compared to the change
00:38:17,223 -- 00:38:20,093
that's going to happen to our climate,
00:38:20,093 -- 00:38:24,697
and the implications for making good investments
00:38:24,697 -- 00:38:27,600
by financial institutions, making good loans,
00:38:27,600 -- 00:38:28,868
providing insurance
00:38:28,868 -- 00:38:31,070
are going to get much more difficult
00:38:31,070 -- 00:38:33,139
as the climate changes.
00:38:33,139 -- 00:38:34,741
And so the supervision
00:38:34,741 -- 00:38:36,909
for those of us who are consumers,
00:38:36,909 -- 00:38:39,278
counting on our supervisors,
00:38:39,278 -- 00:38:41,347
the supervision of financial institutions
00:38:41,347 -- 00:38:41,781
to make sure
00:38:41,781 -- 00:38:42,882
they're making good choices
00:38:42,882 -- 00:38:46,352
about loans and investments and
00:38:46,352 -- 00:38:49,288
insurance is just going to get more challenging.
00:38:49,288 -- 00:38:50,790
It'll become more critical
00:38:50,790 -- 00:38:52,859
for proper supervision
00:38:52,859 -- 00:38:55,428
over time as things move forward.
00:38:55,428 -- 00:38:57,530
So, think about climate change,
00:38:57,530 -- 00:38:58,898
get to understand climate change,
00:38:58,898 -- 00:39:00,366
don't have to get all the science.
00:39:00,366 -- 00:39:01,901
You just need to understand
00:39:01,901 -- 00:39:05,038
how financial institutions are making choices.
00:39:05,038 -- 00:39:06,572
And are they doing their homework?
00:39:06,572 -- 00:39:08,374
Do you see them thinking about this?
00:39:08,374 -- 00:39:09,375
Well, that's
00:39:09,375 -- 00:39:10,076
what I'm looking
00:39:10,076 -- 00:39:13,479
for, is the core message back to those in FSRA
00:39:13,479 -- 00:39:15,281
and those in the regulatory sector.
00:39:15,281 -- 00:39:15,915
That's great.
00:39:15,915 -- 00:39:16,449
Thank you.
00:39:16,449 -- 00:39:17,717
I know we had a very short time,
00:39:17,717 -- 00:39:19,352
but thank you for sharing your insights.
00:00:05,171 -- 00:00:06,172
I am Judy Pfeifer,
00:00:06,172 -- 00:00:11,177
Chief Public Affairs Officer, and I love my AI tools,
00:00:11,578 -- 00:00:13,413
and I'm sure many of you are using
00:00:13,413 -- 00:00:14,948
AI tools in your business
00:00:14,948 -- 00:00:17,717
and is rapidly changing our environment.
00:00:17,717 -- 00:00:21,488
So I am pleased to introduce my colleague Jordan Solway,
00:00:21,488 -- 00:00:23,656
EVP of Legal Enforcement,
00:00:23,656 -- 00:00:28,661
and he's going to lead this great panel on AI.
00:00:28,828 -- 00:00:31,297
Thanks, Judy. Good morning, everybody.
00:00:31,297 -- 00:00:33,466
Before I introduce the panelists,
00:00:33,466 -- 00:00:36,069
I want to just put a scenario out there.
00:00:36,069 -- 00:00:37,871
Imagine if you can
00:00:37,871 -- 00:00:40,840
a artificial general intelligence computer
00:00:40,840 -- 00:00:43,476
that can perform many, many functions, human functions,
00:00:43,476 -- 00:00:45,678
even better than most humans.
00:00:45,678 -- 00:00:47,413
It's slowly
00:00:47,413 -- 00:00:50,049
and very gradually begins to malfunction
00:00:50,049 -- 00:00:54,287
in very subtle ways through effective AI governance.
00:00:54,287 -- 00:00:56,523
I got advice from Carole.
00:00:56,523 -- 00:00:59,759
The errors are recognized by the human oversight.
00:00:59,759 -- 00:01:00,493
However,
00:01:01,728 -- 00:01:04,430
the AI computer that uses,
00:01:04,430 -- 00:01:07,600
what's called Sentient AI, it's effectively
00:01:07,600 -- 00:01:09,669
consciousness awareness
00:01:09,669 -- 00:01:10,603
has now determined
00:01:10,603 -- 00:01:12,005
that it may be shut down,
00:01:12,005 -- 00:01:17,010
and it preemptively shuts down the human oversight.
00:01:17,110 -- 00:01:19,712
Susan, from today's Globe and Mail.
00:01:19,712 -- 00:01:23,049
But it really is a scenario that existed over 50 years ago
00:01:23,049 -- 00:01:26,919
in Stanley Kubrick's classic, 2001, A Space Odyssey.
00:01:26,919 -- 00:01:29,922
If you really want to scare yourself, imagine
00:01:29,922 -- 00:01:32,925
an AI run by Air Canada Rouge.
00:01:32,925 -- 00:01:35,962
And then you'll understand what I'm talking about.
00:01:35,962 -- 00:01:38,398
Where 50 years after,
00:01:38,398 -- 00:01:42,201
Goldberg's masterpiece in AI is no longer science fiction,
00:01:42,201 -- 00:01:44,437
it's actually science fact.
00:01:44,437 -- 00:01:45,672
It's often described
00:01:45,672 -- 00:01:48,741
as, you know, is the next industrial revolution,
00:01:48,741 -- 00:01:50,109
and has even been compared
00:01:50,109 -- 00:01:52,178
to how the discovery of electricity
00:01:52,178 -- 00:01:56,215
transformed the economy and society at large.
00:01:56,215 -- 00:01:57,683
There's no question
00:01:57,683 -- 00:01:59,385
that AI will be transformative,
00:01:59,385 -- 00:02:01,754
but the extent to which is not clear,
00:02:01,754 -- 00:02:04,791
which is why I'm very pleased to have this expert panel
00:02:04,791 -- 00:02:06,192
who have agreed to share their views.
00:02:07,827 -- 00:02:10,930
Before I do that, I just quickly want to
00:02:10,930 -- 00:02:14,767
to sort of set the, set some parameters.
00:02:14,767 -- 00:02:15,435
Bill gates
00:02:15,435 -- 00:02:16,936
once famously said that we always
00:02:16,936 -- 00:02:18,237
overestimate the change
00:02:18,237 -- 00:02:19,739
that will occur in the next two years,
00:02:19,739 -- 00:02:22,809
but underestimate the change in the next ten years.
00:02:22,809 -- 00:02:24,310
If you look at what's going to happen
00:02:24,310 -- 00:02:26,579
in the next two years, it's estimated that over
00:02:26,579 -- 00:02:31,584
70% of businesses will start to use data driven AI,
00:02:32,251 -- 00:02:33,452
machine learning,
00:02:33,452 -- 00:02:34,921
or even a blockchain
00:02:34,921 -- 00:02:37,957
as critical components of their business operations.
00:02:37,957 -- 00:02:39,725
And the investment in AI
00:02:39,725 -- 00:02:44,630
by 2025 is estimated to be in the range of $200 billion.
00:02:44,630 -- 00:02:46,999
So it's pretty staggering.
00:02:46,999 -- 00:02:49,802
I'm very pleased to have a panel
00:02:49,802 -- 00:02:51,270
of really leading experts.
00:02:51,270 -- 00:02:53,806
To my immediate left is Josh Teichman.
00:02:53,806 -- 00:02:55,408
He's the Vice President of Legal
00:02:55,408 -- 00:02:57,610
and Corporate Affairs for Radical Ventures.
00:02:57,610 -- 00:03:00,213
And if you've never heard of Radical Ventures, you should.
00:03:00,213 -- 00:03:01,547
It is a leading venture capital
00:03:01,547 -- 00:03:03,349
fund right here in Toronto
00:03:03,349 -- 00:03:06,852
that's focused on businesses that use transformational AI.
00:03:07,820 -- 00:03:10,923
Radical Ventures has close to $1 billion in capital
00:03:10,923 -- 00:03:13,793
to invest in entrepreneurs who apply technology
00:03:13,793 -- 00:03:16,762
to transform massive industries.
00:03:16,762 -- 00:03:18,331
What's interesting about Radical Ventures
00:03:18,331 -- 00:03:20,399
is it's both a product of the Canadian
00:03:20,399 -- 00:03:23,069
AI ecosystem, and it's also one of its architects.
00:03:23,069 -- 00:03:25,004
So welcome, Josh.
00:03:25,004 -- 00:03:29,041
To Josh's left, parden me, is Abdi Aidid.
00:03:29,041 -- 00:03:30,376
He is an Assistant Professor
00:03:30,376 -- 00:03:32,445
at the University of Toronto Law School,
00:03:32,445 -- 00:03:34,947
and he is also the legal innovation strategist
00:03:34,947 -- 00:03:37,016
at Blue J Legal. Another company,
00:03:37,016 -- 00:03:39,218
if you haven't heard of, you're going to hear of.
00:03:39,218 -- 00:03:40,820
It's a leading AI platform
00:03:40,820 -- 00:03:42,288
that uses machine learning to predict
00:03:42,288 -- 00:03:44,757
tax law outcomes and recommendations.
00:03:44,757 -- 00:03:46,559
You can see Abdi during the break
00:03:46,559 -- 00:03:49,028
to get a tax refund from CRA.
00:03:49,028 -- 00:03:50,496
And lastly,
00:03:50,496 -- 00:03:53,265
but not least is Carole Piovesan,
00:03:53,265 -- 00:03:56,102
who is the Managing Partner of INQ Law,
00:03:56,102 -- 00:03:57,570
a leading boutique
00:03:57,570 -- 00:03:59,004
law firm and consulting business
00:03:59,004 -- 00:03:59,572
which provides
00:03:59,572 -- 00:04:02,274
legal advice to businesses in the area of privacy,
00:04:02,274 -- 00:04:04,910
data governance, cybersecurity and AI,
00:04:04,910 -- 00:04:06,412
along with multi-disciplinary
00:04:06,412 -- 00:04:08,080
services and law policy data
00:04:09,081 -- 00:04:10,116
and technology.
00:04:10,116 -- 00:04:11,717
So welcome.
00:04:11,717 -- 00:04:14,753
I'm going to start, Josh, with you.
00:04:14,753 -- 00:04:16,422
And if you don't mind,
00:04:16,422 -- 00:04:18,157
your company is essentially a king
00:04:18,157 -- 00:04:21,527
or queen maker in the AI space and assessing
00:04:21,527 -- 00:04:23,829
which AI business models
00:04:23,829 -- 00:04:26,232
you're going to back and why?
00:04:26,232 -- 00:04:28,868
Can you give us an assessment of how transformative
00:04:28,868 -- 00:04:32,438
you think I will be to financial services in Ontario?
00:04:32,438 -- 00:04:34,573
Can you guys hear me? Okay.
00:04:34,573 -- 00:04:37,576
I've got my mic. Okay.
00:04:37,576 -- 00:04:40,145
I think when Radical Ventures was formed,
00:04:40,145 -- 00:04:42,815
the first institutional fund back in 2017.
00:04:42,815 -- 00:04:45,050
We had a thesis that I was going to replace
00:04:45,050 -- 00:04:47,953
all software over a ten year replacement cycle,
00:04:47,953 -- 00:04:48,754
which actually aligns
00:04:48,754 -- 00:04:51,891
neatly with the George Bush estimate of underestimating
00:04:51,891 -- 00:04:54,126
how much transformation can happen in ten years.
00:04:54,126 -- 00:04:56,228
I think so far, we've seen that timeline play out
00:04:56,228 -- 00:04:57,563
quite accurately.
00:04:57,563 -- 00:04:59,665
And of course, everyone here is familiar with ChatGPT,
00:04:59,665 -- 00:05:01,333
and when it launched a couple years ago,
00:05:01,333 -- 00:05:03,469
it was absolutely transformative.
00:05:03,469 -- 00:05:05,804
I don't expect financial services will be any different.
00:05:05,804 -- 00:05:06,672
I think
00:05:06,672 -- 00:05:08,407
there's a few things about financial services
00:05:08,407 -- 00:05:11,977
that make it uniquely suited to AI adoption.
00:05:11,977 -- 00:05:16,115
There's many of them, but I can touch briefly on,
00:05:16,115 -- 00:05:17,950
just maybe a few.
00:05:17,950 -- 00:05:19,318
I think the first is
00:05:19,318 -- 00:05:22,287
AI is obviously a very data hungry endeavor,
00:05:22,287 -- 00:05:24,223
and you need a lot of high-quality,
00:05:24,223 -- 00:05:25,758
curated and labeled data
00:05:25,758 -- 00:05:27,960
to come up with really powerful AI models.
00:05:30,095 -- 00:05:32,331
the financial services industry has for a long time
00:05:32,331 -- 00:05:35,134
been ahead of the curve in generating,
00:05:35,134 -- 00:05:36,869
collating and aggregating
00:05:36,869 -- 00:05:37,836
high-quality data
00:05:37,836 -- 00:05:40,239
that are going to be really powerful inputs to AI models.
00:05:40,239 -- 00:05:43,008
So they're already got a leg up there.
00:05:43,008 -- 00:05:44,543
I also think financial services sits
00:05:44,543 -- 00:05:49,348
at the intersection of a few different AI core use cases.
00:05:49,348 -- 00:05:52,351
So you guys all know ChatGPT is a large language model,
00:05:52,351 -- 00:05:54,219
but there are also foundation models
00:05:54,219 -- 00:05:56,155
for other applications
00:05:56,155 -- 00:05:58,490
like, you know, pixels with ability
00:05:58,490 -- 00:06:01,427
AI and stable diffusion where you can generate images.
00:06:01,427 -- 00:06:03,262
And there are also now foundation models
00:06:03,262 -- 00:06:06,465
for numbers and math and financial spreadsheets.
00:06:06,465 -- 00:06:08,367
And if you put all three of those together,
00:06:08,367 -- 00:06:09,735
you get some really powerful tools
00:06:09,735 -- 00:06:11,904
where you can use a pixel model
00:06:11,904 -- 00:06:15,607
to extract information out of applicant submissions,
00:06:15,607 -- 00:06:17,109
use a large language model to then
00:06:17,109 -- 00:06:19,111
summarize and analyze that information,
00:06:19,111 -- 00:06:21,580
and then use a mathematical
00:06:21,580 -- 00:06:22,447
and spreadsheet model
00:06:22,447 -- 00:06:26,151
to create some risk analysis and financial planning.
00:06:26,151 -- 00:06:28,120
So you kind of put all three of those together,
00:06:28,120 -- 00:06:28,887
and you have.
00:06:28,887 -- 00:06:30,822
That's one enterprise
00:06:30,822 -- 00:06:33,325
that really can leverage a few different areas
00:06:33,325 -- 00:06:36,695
that are very powerful AI tools on the market today.
00:06:36,695 -- 00:06:38,096
Maybe the last,
00:06:38,096 -- 00:06:39,331
way in which I think financial services
00:06:39,331 -- 00:06:40,666
is uniquely positioned to use
00:06:40,666 -- 00:06:44,269
AI is the fact that it is actually a regulated industry.
00:06:44,269 -- 00:06:45,571
And a lot of people think that might be
00:06:45,571 -- 00:06:47,739
a headwind for adoption of technology.
00:06:47,739 -- 00:06:48,674
I think when it comes to AI,
00:06:48,674 -- 00:06:51,276
I actually is a bit of a tailwind,
00:06:51,276 -- 00:06:53,478
because if you think about some of the problems
00:06:53,478 -- 00:06:54,680
with AI
00:06:54,680 -- 00:06:57,249
in particular, like prone to hallucinations
00:06:57,249 -- 00:06:59,918
and making up information that may not be accurate,
00:06:59,918 -- 00:07:02,487
if you then take that AI tool and stick it in a sandbox
00:07:02,487 -- 00:07:05,324
and say you can only draw on data from this one space,
00:07:05,324 -- 00:07:07,960
and you're bound by these set of rules and constraints,
00:07:07,960 -- 00:07:10,062
it's much less likely to hallucinate.
00:07:10,062 -- 00:07:11,563
I actually think there's a good use case
00:07:11,563 -- 00:07:13,565
for AI, particularly in regulated spaces,
00:07:13,565 -- 00:07:15,801
because it can actually be more accurate
00:07:15,801 -- 00:07:16,802
and highly performant.
00:07:17,836 -- 00:07:21,540
I would say it well regulated space, but anyway.
00:07:21,540 -- 00:07:24,242
Abdi, it's been observed that,
00:07:24,242 -- 00:07:27,079
one of the main impacts of artificial intelligence will be
00:07:27,079 -- 00:07:29,214
it will really force businesses
00:07:29,214 -- 00:07:29,781
to assess
00:07:29,781 -- 00:07:32,017
how the technology impacts their business strategy,
00:07:32,017 -- 00:07:35,787
specifically as it relates to predictive modeling.
00:07:35,787 -- 00:07:36,922
This is really, as I understand
00:07:36,922 -- 00:07:39,491
it, at the core of what Blue J Legal does.
00:07:39,491 -- 00:07:40,525
Can you comment on how
00:07:40,525 -- 00:07:41,960
where sectors need to be thinking
00:07:41,960 -- 00:07:44,629
about the technology for their businesses?
00:07:44,629 -- 00:07:47,132
Sure. Thanks for having me.
00:07:47,132 -- 00:07:50,469
The way that I think about the strategic benefit of using
00:07:50,469 -- 00:07:53,839
AI is really as a professional augmentation tool.
00:07:53,839 -- 00:07:54,739
So, Blue J, we built
00:07:54,739 -- 00:07:56,708
these tools that were supposed to supercharge
00:07:56,708 -- 00:07:57,809
lawyer research.
00:07:57,809 -- 00:08:00,278
And that was really recognizing that there's
00:08:00,278 -- 00:08:01,713
an emerging division of labor
00:08:01,713 -- 00:08:05,150
between human and technology, where we understand that
00:08:05,150 -- 00:08:07,319
computers can synthesize volumes of data
00:08:07,319 -- 00:08:10,589
that I can't begin to, in a shorter period of time. So,
00:08:12,057 -- 00:08:13,225
maybe everyone up here is a lawyer.
00:08:13,225 -- 00:08:15,093
There are a lot of lawyers in the room.
00:08:15,093 -- 00:08:18,597
And let's imagine. I think there's two. There's two.
00:08:18,597 -- 00:08:22,334
Let's imagine you're not yourselves, but your, you know,
00:08:22,334 -- 00:08:24,669
a county lawyer who hangs a shingle somewhere
00:08:24,669 -- 00:08:26,438
and you have an office in a strip mall,
00:08:26,438 -- 00:08:27,806
and someone knocks on your door
00:08:27,806 -- 00:08:28,607
and says,
00:08:28,607 -- 00:08:31,076
I, you know, I've been terminated at work.
00:08:31,076 -- 00:08:33,044
It feels like it was wrong, right?
00:08:33,044 -- 00:08:35,113
The rate limiting factor in the quality of advice
00:08:35,113 -- 00:08:36,681
I can give is,
00:08:36,681 -- 00:08:38,416
you know, I can I can start by shooting from the hip.
00:08:38,416 -- 00:08:40,151
I can tell them a bit
00:08:40,151 -- 00:08:42,053
about my experience of wrongful dismissal.
00:08:42,053 -- 00:08:44,456
But at some point I'm going to have to justify my advice
00:08:44,456 -- 00:08:45,223
with some rigor
00:08:45,223 -- 00:08:47,259
and the rate limiting factor on the quality of advice
00:08:47,259 -- 00:08:49,828
I can give is how many cases can I read in a day, right?
00:08:49,828 -- 00:08:50,795
Well, if you have technology
00:08:50,795 -- 00:08:53,465
that can purport to synthesize
00:08:53,465 -- 00:08:55,133
all of the historical case law in the area,
00:08:55,133 -- 00:08:56,901
and then I can start at a higher floor,
00:08:56,901 -- 00:08:59,204
I can then reconcile that against my experience,
00:08:59,204 -- 00:09:00,105
my understanding,
00:09:00,105 -- 00:09:02,774
my sense of the judge in the local,
00:09:02,774 -- 00:09:05,977
my sense of what the appropriate arguments are.
00:09:05,977 -- 00:09:07,545
And now I have this,
00:09:08,747 -- 00:09:11,182
I've made use of an intelligent high powered assistant.
00:09:11,182 -- 00:09:11,649
And actually,
00:09:11,649 -- 00:09:12,484
when you think about things
00:09:12,484 -- 00:09:14,285
in the context of a division of labor,
00:09:14,285 -- 00:09:15,220
then some of the concerns
00:09:15,220 -- 00:09:17,122
that we have around things like inaccuracy
00:09:17,122 -- 00:09:18,490
start to fall away
00:09:18,490 -- 00:09:20,692
because they're in a familiar template, right?
00:09:20,692 -- 00:09:22,093
If ChatGPT is giving you
00:09:22,093 -- 00:09:23,461
false information,
00:09:23,461 -- 00:09:27,599
well, maybe you treat it the way you treat the,
00:09:27,599 -- 00:09:29,768
eager intern at your office, right?
00:09:29,768 -- 00:09:34,272
It's like they're very, eager to please.
00:09:34,272 -- 00:09:36,007
They can work 24 hours a day.
00:09:36,007 -- 00:09:37,475
They really want to do well by you.
00:09:37,475 -- 00:09:38,710
They have the vocabulary, right,
00:09:38,710 -- 00:09:40,111
but they don't know anything yet.
00:09:40,111 -- 00:09:43,148
So what do you do? You trust but verify, right.
00:09:43,148 -- 00:09:44,749
And so when we start to think about it in the context
00:09:44,749 -- 00:09:47,218
of professional augmentation, supercharging what we do,
00:09:47,218 -- 00:09:49,420
working alongside high powered assistants.
00:09:49,420 -- 00:09:50,221
In that way,
00:09:50,221 -- 00:09:52,190
then it becomes utterly familiar to us
00:09:52,190 -- 00:09:53,458
and we can better navigate the risks.
00:09:53,458 -- 00:09:54,759
And so
00:09:54,759 -- 00:09:57,162
the main strategic benefit for businesses
00:09:57,162 -- 00:10:00,265
right now is to think through the chance of supercharging
00:10:00,265 -- 00:10:00,999
the professional work
00:10:00,999 -- 00:10:01,866
they're already doing
00:10:01,866 -- 00:10:05,003
and recognizing that the technology is just attempting
00:10:05,003 -- 00:10:07,705
to do the thing that you're also attempting to do.
00:10:07,705 -- 00:10:08,373
And so,
00:10:08,373 -- 00:10:09,374
rather than oppose it, work
00:10:09,374 -- 00:10:11,309
harmoniously with it. As lawyers,
00:10:11,309 -- 00:10:13,578
what are we doing except trying to predict outcomes?
00:10:13,578 -- 00:10:16,848
If that person who knocked on my door, my office door,
00:10:16,848 -- 00:10:19,317
said, hey, I've been terminated from my job, what do I do?
00:10:19,317 -- 00:10:20,151
They'd be frustrated
00:10:20,151 -- 00:10:22,153
if I started reciting the multi-part test
00:10:22,153 -- 00:10:23,588
for wrongful dismissal,
00:10:23,588 -- 00:10:25,623
or gave them the contours of the doctrine.
00:10:25,623 -- 00:10:27,225
No, they want to know what's going to happen. Yep.
00:10:27,225 -- 00:10:28,426
And so tech can predict
00:10:28,426 -- 00:10:30,161
and it can work alongside us to predict.
00:10:30,161 -- 00:10:31,529
Then why would we oppose it?
00:10:33,097 -- 00:10:33,998
I guess I was going to
00:10:33,998 -- 00:10:35,066
say the only difference is the law
00:10:35,066 -- 00:10:37,669
firm gets to charge that, person with lack of knowledge.
00:10:37,669 -- 00:10:38,970
But at $500 an hour,
00:10:38,970 -- 00:10:41,139
which they're not gonna be able to do with ChatGPT.
00:10:41,139 -- 00:10:43,975
There's always ways to charge the money.
00:10:43,975 -- 00:10:44,542
Telling you,
00:10:44,542 -- 00:10:47,679
Don't worry about it. Carole.
00:10:47,679 -- 00:10:50,948
You have been, a little bit like a canary in a coal mine
00:10:50,948 -- 00:10:52,850
with AI focusing on the,
00:10:52,850 -- 00:10:56,888
business uses to be both responsible and ethical.
00:10:56,888 -- 00:10:58,389
I was joking about Air Canada Rouge,
00:10:58,389 -- 00:10:59,324
but everyone knows
00:10:59,324 -- 00:11:02,627
a few weeks ago, Air Canada got into trouble,
00:11:02,627 -- 00:11:04,696
and made the news because one of its chat bots
00:11:04,696 -- 00:11:08,099
gave inaccurate advice about its bereavement policy,
00:11:08,099 -- 00:11:09,634
which caused the financial exposure
00:11:09,634 -- 00:11:11,669
and lots of reputational risk.
00:11:11,669 -- 00:11:13,504
It's just isolated.
00:11:13,504 -- 00:11:14,639
Just Air Canada,
00:11:14,639 -- 00:11:17,108
or is this really a harbinger of things to come with AI?
00:11:18,076 -- 00:11:21,279
It's not isolated.
00:11:21,279 -- 00:11:24,048
As you heard,
00:11:24,048 -- 00:11:25,750
there are some really great use cases
00:11:25,750 -- 00:11:27,618
for artificial intelligence and ways
00:11:27,618 -- 00:11:29,454
it can augment productivity.
00:11:29,454 -- 00:11:31,389
It can identify new markets.
00:11:31,389 -- 00:11:32,623
It can help us with,
00:11:32,623 -- 00:11:35,693
you know, predictions and other really valuable uses.
00:11:35,693 -- 00:11:38,329
So there are lots of ways where artificial intelligence
00:11:38,329 -- 00:11:41,799
will be extremely valuable to our businesses.
00:11:41,799 -- 00:11:42,700
At the same time,
00:11:42,700 -- 00:11:45,269
we have to recognize that there are limitations.
00:11:45,269 -- 00:11:47,505
And you heard Josh talk about some of those.
00:11:47,505 -- 00:11:49,640
There are limitations with the technology
00:11:49,640 -- 00:11:51,909
that if you don't appreciate the limitations
00:11:51,909 -- 00:11:55,513
and put in place some reasonable mitigating factors,
00:11:55,513 -- 00:11:59,350
you are at risk of the type of reputational harm
00:11:59,350 -- 00:12:02,687
or more that Air Canada faced as an example.
00:12:02,687 -- 00:12:03,855
And they are not alone.
00:12:03,855 -- 00:12:04,956
There are professionals
00:12:04,956 -- 00:12:07,058
who have used artificial intelligence
00:12:07,058 -- 00:12:09,227
in, you know, formal briefing documents
00:12:09,227 -- 00:12:11,696
and have been slammed for the fact that the
00:12:11,696 -- 00:12:13,497
the system unearthed,
00:12:13,497 -- 00:12:15,933
you know, information that was not true.
00:12:15,933 -- 00:12:17,068
We see it happening
00:12:17,068 -- 00:12:19,637
in triaging in the sort of health sector
00:12:19,637 -- 00:12:20,905
where artificial intelligence
00:12:20,905 -- 00:12:22,607
is used in triaging services,
00:12:22,607 -- 00:12:24,242
and there's baked in discrimination
00:12:24,242 -- 00:12:25,910
that wasn't caught in advance,
00:12:25,910 -- 00:12:28,379
and that caused significant harm
00:12:28,379 -- 00:12:30,948
to individuals on the receiving end of that.
00:12:30,948 -- 00:12:31,916
And the list goes on.
00:12:31,916 -- 00:12:32,483
There's actually,
00:12:32,483 -- 00:12:33,484
if you're curious, there's
00:12:33,484 -- 00:12:35,786
actually an AI Incident Database.
00:12:35,786 -- 00:12:38,289
You just literally Google AI Incident Database
00:12:38,289 -- 00:12:40,658
and it's the first thing that will come up.
00:12:40,658 -- 00:12:41,392
And I would
00:12:41,392 -- 00:12:44,762
look at it with some, you know, a critical eye.
00:12:44,762 -- 00:12:47,231
But it's interesting to see the types of incidents
00:12:47,231 -- 00:12:48,699
that are being documented.
00:12:48,699 -- 00:12:50,167
And those incidents reflect
00:12:50,167 -- 00:12:53,104
some of the legal, reputational, ethical
00:12:53,104 -- 00:12:54,538
and other risks that come
00:12:54,538 -- 00:12:56,340
with the use of artificial intelligence.
00:12:56,340 -- 00:12:58,709
So it's by no means, a standalone.
00:12:58,709 -- 00:13:01,212
We will see lots of these examples come up.
00:13:01,212 -- 00:13:04,048
But there are things that can be done to mitigate
00:13:04,048 -- 00:13:06,584
some of those risks and put in place more governance.
00:13:06,584 -- 00:13:08,919
So you're using the technology more responsibly.
00:13:08,919 -- 00:13:11,222
You know, are you seeing businesses doing that?
00:13:11,222 -- 00:13:15,593
Absolutely, absolutely. So the first thing with ChatGPT
00:13:16,560 -- 00:13:17,862
and we in Canada, we have
00:13:17,862 -- 00:13:20,331
similar types, systems like cohere
00:13:20,331 -- 00:13:21,699
that have large language models
00:13:21,699 -- 00:13:23,400
that we can be using as well.
00:13:23,400 -- 00:13:24,769
So the first thing we saw
00:13:24,769 -- 00:13:27,438
is an acceptable use policy for AI,
00:13:27,438 -- 00:13:31,675
for generative AI in particular. That became all the rage.
00:13:31,675 -- 00:13:33,811
Since then we have seen greater investment
00:13:33,811 -- 00:13:35,312
in a data governance, or, sorry, in
00:13:35,312 -- 00:13:39,350
AI governance framework, a suite of AI related policies.
00:13:39,350 -- 00:13:41,952
If you are at all curious, which I'm sure you all are,
00:13:41,952 -- 00:13:44,054
there is an interesting ISO standard,
00:13:44,054 -- 00:13:46,257
and I know we all like reading ISO standards,
00:13:46,257 -- 00:13:48,726
but it's 4201
00:13:48,726 -- 00:13:51,262
and it gives some good guidance
00:13:51,262 -- 00:13:53,531
about what an AI responsible
00:13:53,531 -- 00:13:55,799
AI management framework could look like.
00:13:55,799 -- 00:13:57,468
So even if you don't want to read
00:13:57,468 -- 00:13:59,637
the nuts and bolts of the actual standard,
00:13:59,637 -- 00:14:01,238
look at the index. Like,
00:14:01,238 -- 00:14:02,940
just peruse the index
00:14:02,940 -- 00:14:05,576
to get some ideas about what people are doing.
00:14:05,576 -- 00:14:07,611
What different organizations are doing.
00:14:07,611 -- 00:14:08,379
You're going to see
00:14:08,379 -- 00:14:10,347
there is a suite of policies and procedures
00:14:10,347 -- 00:14:12,883
that touch on appropriate use, risk
00:14:12,883 -- 00:14:17,321
mitigation, impact assessments, incident response.
00:14:17,321 -- 00:14:20,391
Then there will be an entire risk management framework
00:14:20,391 -- 00:14:24,028
that is put in place to help mitigate some of those,
00:14:24,028 -- 00:14:26,130
potential risks of the higher use cases.
00:14:26,130 -- 00:14:28,198
And then there are governance structures in place,
00:14:28,198 -- 00:14:29,733
including various committees.
00:14:29,733 -- 00:14:30,701
I mean, you organize it
00:14:30,701 -- 00:14:32,836
according to your own internal culture,
00:14:32,836 -- 00:14:36,273
but they do help set up that appropriate oversight
00:14:36,273 -- 00:14:38,442
of the higher risk use cases,
00:14:38,442 -- 00:14:41,912
not of every single use of artificial intelligence.
00:14:41,912 -- 00:14:44,648
Thank you. Josh, can I come back to you for a second?
00:14:44,648 -- 00:14:47,084
So, there’s a famous quote by Peter Drucker
00:14:47,084 -- 00:14:49,753
who said, “the only purpose of a business
00:14:49,753 -- 00:14:51,422
just to create a customer.” I'm sure you've heard that.
00:14:52,389 -- 00:14:54,291
Your company looks, as I understand it,
00:14:54,291 -- 00:14:55,959
that the ability of AI to transform
00:14:55,959 -- 00:14:59,830
a given business, right? To improve it.
00:14:59,830 -- 00:15:03,133
How does AI enable financial services,
00:15:03,133 -- 00:15:06,437
businesses, to personalize the customer experience,
00:15:06,437 -- 00:15:08,305
offer tailored product
00:15:08,305 -- 00:15:09,640
recommendations, and generally
00:15:09,640 -- 00:15:12,676
improve customer engagement?
00:15:12,676 -- 00:15:16,213
I think there's a lot to unpack there, but AI can
00:15:16,213 -- 00:15:17,414
sort of supercharge
00:15:17,414 -- 00:15:18,715
not just the customer experience,
00:15:18,715 -- 00:15:20,751
but also the vendor experience
00:15:20,751 -- 00:15:23,320
and the agent and broker experience.
00:15:23,320 -- 00:15:25,189
If we zoom in on the customer governance in particular,
00:15:25,189 -- 00:15:26,523
I think there's use cases on
00:15:26,523 -- 00:15:28,525
almost every stage of the customer
00:15:28,525 -- 00:15:30,727
experience journey from,
00:15:30,727 -- 00:15:32,129
you know, finding out what services
00:15:32,129 -- 00:15:33,597
you even need in the first place,
00:15:33,597 -- 00:15:36,200
to connecting with a service provider,
00:15:36,200 -- 00:15:37,868
evaluating them,
00:15:37,868 -- 00:15:40,270
running through the sales process, concluding a sale
00:15:40,270 -- 00:15:42,439
and then getting support on the back end.
00:15:42,439 -- 00:15:46,176
We're already seeing AI tools in all of these spaces. Right.
00:15:46,176 -- 00:15:47,911
Some of them kind of try to go end to end,
00:15:47,911 -- 00:15:50,547
and some of them focus, focus on a specific vertical.
00:15:50,547 -- 00:15:53,750
But lots of them exist and there's lots more coming.
00:15:53,750 -- 00:15:54,551
I also think,
00:15:56,220 -- 00:15:56,687
when you think
00:15:56,687 -- 00:15:57,654
about
00:15:57,654 -- 00:15:58,855
whether an AI tool
00:15:58,855 -- 00:16:00,357
is the right tool for a particular purpose,
00:16:00,357 -- 00:16:02,326
you got to think about, does it
00:16:02,326 -- 00:16:03,026
first of all, balance
00:16:03,026 -- 00:16:04,428
the risks that we're talking about,
00:16:04,428 -- 00:16:07,064
but also actually make the customer's life easier
00:16:07,064 -- 00:16:08,966
because at the end of the day, improves outcomes,
00:16:08,966 -- 00:16:10,667
but introduces a whole lot of challenges
00:16:10,667 -- 00:16:11,935
and the customer doesn't trust it.
00:16:11,935 -- 00:16:14,371
It's not going to get widely adopted.
00:16:14,371 -- 00:16:15,706
So we think about,
00:16:15,706 -- 00:16:16,206
you know,
00:16:16,206 -- 00:16:18,809
can the customer access the tool outside of office hours
00:16:18,809 -- 00:16:19,876
that would normally be restrictive
00:16:19,876 -- 00:16:22,112
if they want to learn about their policy, for example.
00:16:22,112 -- 00:16:22,646
Right.
00:16:22,646 -- 00:16:24,915
Or can they go ask an AI chat bot about their policy
00:16:24,915 -- 00:16:26,116
and not wait until nine in the morning
00:16:26,116 -- 00:16:28,251
to talk to their broker when their office opens?
00:16:28,251 -- 00:16:30,954
There's lots of tools trying to solve that problem.
00:16:30,954 -- 00:16:32,022
There's also lots of tools.
00:16:32,022 -- 00:16:35,258
Now that I sort of put in a family of AI tools,
00:16:35,258 -- 00:16:37,861
trying to figure out a better way of,
00:16:37,861 -- 00:16:40,697
analyzing the risk profile of an applicant.
00:16:40,697 -- 00:16:43,033
And if you can get more granular in that risk profile,
00:16:43,033 -- 00:16:43,367
you can
00:16:43,367 -- 00:16:46,536
then better match them to an underwriter
00:16:46,536 -- 00:16:47,070
or provider
00:16:47,070 -- 00:16:48,972
who has appetite for that risk
00:16:48,972 -- 00:16:51,007
and then create sort of customized
00:16:51,007 -- 00:16:52,943
or tailored policies for them
00:16:52,943 -- 00:16:54,277
that previously was just not possible,
00:16:54,277 -- 00:16:56,046
because the man hours involved in creating
00:16:56,046 -- 00:16:57,914
that policy was just too high. Right.
00:16:57,914 -- 00:16:59,049
You can now create the policy
00:16:59,049 -- 00:17:01,384
and service that policy all using AI,
00:17:01,384 -- 00:17:03,420
and then support it on the back end through again,
00:17:03,420 -- 00:17:05,989
sort of uses a chat bot type functionality
00:17:05,989 -- 00:17:07,657
when customers have questions about it.
00:17:07,657 -- 00:17:09,659
And thereby improve the customer experience. Yeah.
00:17:11,094 -- 00:17:11,661
Carole, maybe
00:17:11,661 -- 00:17:12,562
back to you for a second,
00:17:12,562 -- 00:17:14,831
because we have lots of people in the room
00:17:14,831 -- 00:17:16,733
who sit on the Board of entities or businesses
00:17:16,733 -- 00:17:18,068
we regulate.
00:17:18,068 -- 00:17:20,170
How do you balance
00:17:20,170 -- 00:17:21,171
or how do you strike the right
00:17:21,171 -- 00:17:23,073
balance of an AI driven automation
00:17:23,073 -- 00:17:25,609
and all the benefits that Josh has spoken to
00:17:25,609 -- 00:17:26,576
and efficiency with,
00:17:26,576 -- 00:17:29,913
and with the need to maintain human oversight
00:17:29,913 -- 00:17:32,349
and accountability, especially in sensitive areas?
00:17:32,349 -- 00:17:33,550
For example,
00:17:33,550 -- 00:17:37,153
you know, our Credit Unions do loan underwriting.
00:17:37,153 -- 00:17:37,854
Yeah.
00:17:37,854 -- 00:17:40,924
So the first thing I would always say
00:17:40,924 -- 00:17:42,826
is figure out what your use cases
00:17:42,826 -- 00:17:45,295
are and figure out what existing
00:17:45,295 -- 00:17:48,265
sort of data security and data governance practices
00:17:48,265 -- 00:17:50,700
you have in place and figure out,
00:17:50,700 -- 00:17:52,035
as I said, what your use cases are.
00:17:52,035 -- 00:17:52,969
So where are you going?
00:17:52,969 -- 00:17:53,870
Where do you think you're going
00:17:53,870 -- 00:17:55,305
to be using this technology?
00:17:55,305 -- 00:17:56,640
Because what you will want to do
00:17:56,640 -- 00:17:59,943
is bridge the gap between where you are today
00:17:59,943 -- 00:18:01,978
and where you are going to be going in the next
00:18:01,978 -- 00:18:03,146
3 to 5 years.
00:18:03,146 -- 00:18:04,414
And I strongly encourage
00:18:04,414 -- 00:18:06,416
everyone to be a bit ambitious about it.
00:18:06,416 -- 00:18:10,153
We I there are absolutely distinct risks with AI,
00:18:10,153 -- 00:18:12,188
but they're not insurmountable risks.
00:18:12,188 -- 00:18:13,456
Or if they are, then at least
00:18:13,456 -- 00:18:15,659
you know which use cases to avoid.
00:18:15,659 -- 00:18:19,262
So bridging that gap becomes very, very important.
00:18:19,262 -- 00:18:21,064
And then you can start to put in place
00:18:21,064 -- 00:18:23,033
a reasonable, responsible
00:18:23,033 -- 00:18:26,336
AI plan that will allow you to operationalize
00:18:26,336 -- 00:18:27,937
while mitigating and lessening
00:18:27,937 -- 00:18:29,639
some of those distinct risks.
00:18:29,639 -- 00:18:30,907
So the number one thing
00:18:30,907 -- 00:18:31,341
that I
00:18:31,341 -- 00:18:33,910
caution every especially Canadian company
00:18:33,910 -- 00:18:36,846
is not to be so fearful of the technology
00:18:36,846 -- 00:18:38,982
because of all the hype around the risks,
00:18:38,982 -- 00:18:41,951
that you don't start investing in and understanding
00:18:41,951 -- 00:18:43,887
where it can actually be quite beneficial
00:18:43,887 -- 00:18:44,888
to your business.
00:18:44,888 -- 00:18:46,523
The good news in all of this
00:18:46,523 -- 00:18:48,792
is that there is a reasonable way forward,
00:18:48,792 -- 00:18:50,860
especially for the initial
00:18:50,860 -- 00:18:52,962
use cases that you're likely to take on,
00:18:52,962 -- 00:18:56,499
which are probably lower risk and higher productivity.
00:18:56,499 -- 00:18:58,501
So you can demonstrate that good ROI.
00:18:58,501 -- 00:19:00,003
And this is a lawyer speaking, right.
00:19:00,003 -- 00:19:01,538
Like I should be telling you, don't touch it
00:19:01,538 -- 00:19:03,339
with a ten foot pole and get away from it.
00:19:03,339 -- 00:19:07,210
But actually I see a distinct risk on the opposite side,
00:19:07,210 -- 00:19:09,879
which is not only the competitive
00:19:09,879 -- 00:19:11,815
disadvantage of not using it,
00:19:11,815 -- 00:19:13,516
but also overall,
00:19:13,516 -- 00:19:16,419
we can all be playing to our higher strengths,
00:19:16,419 -- 00:19:18,154
I think, if we've got some technology
00:19:18,154 -- 00:19:19,823
to augment our intelligence.
00:19:19,823 -- 00:19:21,524
And see if I can follow up,
00:19:21,524 -- 00:19:22,659
you see that discussion
00:19:22,659 -- 00:19:25,195
starting at the Board level or is it starting up?
00:19:25,195 -- 00:19:28,064
Absolutely. It is absolutely happening at the Board level.
00:19:28,064 -- 00:19:29,432
And increasingly, Boards,
00:19:29,432 -- 00:19:31,434
especially of large organizations,
00:19:31,434 -- 00:19:34,337
are bringing on that kind of expertise
00:19:34,337 -- 00:19:36,339
for Board education.
00:19:36,339 -- 00:19:37,106
Over time,
00:19:37,106 -- 00:19:38,241
we are going to see what's happening
00:19:38,241 -- 00:19:39,442
in the cybersecurity world,
00:19:39,442 -- 00:19:41,177
which is you're going to want that expertise
00:19:41,177 -- 00:19:42,545
actually sitting on your Board.
00:19:42,545 -- 00:19:44,314
We're not there yet with AI. Right.
00:19:44,314 -- 00:19:46,316
The regulators will require it, probably.
00:19:46,316 -- 00:19:49,118
Absolutely. They should. Abdi, coming back to you.
00:19:49,118 -- 00:19:50,787
So, you know, Blue J Legal, purpose
00:19:50,787 -- 00:19:53,256
driven, generative AI platform
00:19:53,256 -- 00:19:56,092
built on an authoritative tax law,
00:19:56,092 -- 00:19:58,161
database to provide predictive analysis
00:19:58,161 -- 00:20:00,630
to customers, mainly lawyers.
00:20:00,630 -- 00:20:01,731
Do you see the business
00:20:01,731 -- 00:20:03,566
model is having broader application
00:20:03,566 -- 00:20:05,969
to financial services, for example,
00:20:05,969 -- 00:20:08,271
could you use it to give advice on a Mortgage
00:20:08,271 -- 00:20:11,441
or Auto Insurance or Home Insurance?
00:20:11,441 -- 00:20:14,110
Yeah, I think, one of the points that Josh made earlier
00:20:14,110 -- 00:20:17,347
is that we're trending towards more consolidation, right?
00:20:17,347 -- 00:20:18,247
More domain expertise.
00:20:18,247 -- 00:20:19,749
So if you think about ChatGPT
00:20:19,749 -- 00:20:21,484
and one of the things that's so exciting,
00:20:21,484 -- 00:20:23,553
but also frustrating about it is that it's trained
00:20:23,553 -- 00:20:26,422
on, let's call it the sum total of the internet. Right.
00:20:26,422 -- 00:20:29,392
So that's part of why it's interesting and exciting,
00:20:29,392 -- 00:20:30,727
but also why it's unreliable.
00:20:30,727 -- 00:20:32,862
Why you won't ask it a factual question. Right.
00:20:32,862 -- 00:20:34,964
You might ask it to,
00:20:34,964 -- 00:20:37,433
you know, write your biography or obituary,
00:20:37,433 -- 00:20:39,368
but you can ask it to do,
00:20:39,368 -- 00:20:41,671
and it might give you things that sound compelling,
00:20:41,671 -- 00:20:43,406
that sound like they ought to be about you,
00:20:43,406 -- 00:20:45,341
but maybe aren't specific enough about you.
00:20:45,341 -- 00:20:46,809
Well, that's because it's a language model, right?
00:20:46,809 -- 00:20:49,312
It's at best a predictive,
00:20:49,312 -- 00:20:52,315
or, probabilistic determination of the next likely word.
00:20:52,315 -- 00:20:54,550
Or what if you took that language generation capacity
00:20:54,550 -- 00:20:56,419
and you merited it to a knowledge
00:20:56,419 -- 00:20:58,354
model, language model, knowledge model, where you said,
00:20:58,354 -- 00:21:02,158
let's only pull from vetted, scored information
00:21:02,158 -- 00:21:03,459
in a specific area.
00:21:03,459 -- 00:21:04,026
Well,
00:21:04,026 -- 00:21:05,161
in a regulated profession
00:21:05,161 -- 00:21:06,762
where you have a data rich environment
00:21:06,762 -- 00:21:09,198
and where you have people who are task compliance
00:21:09,198 -- 00:21:11,167
officers, others, who can be tasked with,
00:21:13,336 -- 00:21:15,771
sort of attesting to the veracity of that information.
00:21:15,771 -- 00:21:17,807
Then you have a chance to really say,
00:21:17,807 -- 00:21:19,809
let's use all the language generation capacity of
00:21:19,809 -- 00:21:20,409
this tool,
00:21:20,409 -- 00:21:21,577
but limit what it can pull
00:21:21,577 -- 00:21:23,112
from the information that we know.
00:21:23,112 -- 00:21:26,549
And that's actually a trend that you're seeing everywhere.
00:21:26,549 -- 00:21:28,618
So in education,
00:21:28,618 -- 00:21:30,219
I was talking to a community organization
00:21:30,219 -- 00:21:31,487
the other day, which was saying,
00:21:31,487 -- 00:21:32,955
we're going to use a large language model
00:21:32,955 -- 00:21:35,191
and train it on high school physics textbooks
00:21:35,191 -- 00:21:38,027
so that the kids can have a tutor that's available
00:21:38,027 -- 00:21:41,197
all hours of the night at any time for low cost. Right.
00:21:41,197 -- 00:21:42,331
And so the trend towards
00:21:42,331 -- 00:21:44,800
that kind of domain expertise is a wonderful thing,
00:21:44,800 -- 00:21:46,369
not only because it brings costs down,
00:21:46,369 -- 00:21:48,404
but it gets the right people into the space.
00:21:48,404 -- 00:21:50,706
One of the things that Carole was mentioning was,
00:21:50,706 -- 00:21:52,074
having human beings involved in the loop.
00:21:52,074 -- 00:21:55,044
Well, if we're trending towards more domain expertise
00:21:55,044 -- 00:21:56,445
at a technological level,
00:21:56,445 -- 00:21:57,246
then it means we're gonna need
00:21:57,246 -- 00:21:59,649
more domain experts to verify the information,
00:21:59,649 -- 00:22:01,050
participate in the development.
00:22:01,050 -- 00:22:02,685
I'll tell one very, very quick,
00:22:03,853 -- 00:22:05,121
story, which is
00:22:05,121 -- 00:22:09,091
I talk about this all the time, this lawsuit against
00:22:09,091 -- 00:22:11,193
the State of Arkansas by the Legal Aid Society.
00:22:11,193 -- 00:22:11,927
And in Arkansas,
00:22:11,927 -- 00:22:15,398
they decided to use, an algorithm to replace nurses
00:22:15,398 -- 00:22:17,166
who are determining in the past
00:22:17,166 -- 00:22:19,168
who was entitled to a person support worker
00:22:19,168 -- 00:22:20,669
so you could apply for state funding
00:22:20,669 -- 00:22:22,204
if you're someone with mobility issues.
00:22:22,204 -- 00:22:25,674
They terminated the nurses, had an algorithm,
00:22:25,674 -- 00:22:29,879
and the algorithm ask you questions like, are you,
00:22:29,879 -- 00:22:31,047
do you have foot pain, yes or no?
00:22:31,047 -- 00:22:32,314
The idea being, if you have foot pain,
00:22:32,314 -- 00:22:34,617
you're more likely to need a PSW.
00:22:34,617 -- 00:22:35,951
The following people were answering
00:22:35,951 -- 00:22:37,686
no to the question of their foot pain.
00:22:37,686 -- 00:22:39,021
People who are paraplegic.
00:22:39,021 -- 00:22:40,322
People who are quadriplegic.
00:22:40,322 -- 00:22:41,791
People who are amputees.
00:22:41,791 -- 00:22:43,125
So there's two ways to look at that one way.
00:22:43,125 -- 00:22:46,061
Say, let's never use technology in this context.
00:22:46,061 -- 00:22:47,897
The other way to look at it is, say,
00:22:47,897 -- 00:22:51,267
for determining the nurses, why not have them work on,
00:22:51,267 -- 00:22:52,268
the questionnaire design?
00:22:52,268 -- 00:22:53,202
Or better yet,
00:22:53,202 -- 00:22:53,936
use your common sense
00:22:53,936 -- 00:22:55,704
that have a not available option for the question of
00:22:55,704 -- 00:22:57,740
does someone have a foot pain instead of forcing
00:22:57,740 -- 00:22:58,741
to binary choice.
00:22:58,741 -- 00:23:01,377
So that domain expertise is totally critically necessary.
00:23:01,377 -- 00:23:04,046
The other thing, the last thing I'll say on this is
00:23:04,046 -- 00:23:06,849
when we're talking about insights for consumers,
00:23:06,849 -- 00:23:07,716
we have to recognize that
00:23:07,716 -- 00:23:10,119
we're in a very different world than we used to be.
00:23:10,119 -- 00:23:12,321
Things like targeting consumers
00:23:12,321 -- 00:23:14,056
with their data in order to market
00:23:14,056 -- 00:23:16,959
better prices to them is like, that's yesterday's.
00:23:16,959 -- 00:23:19,528
That's like Expedia or iTravel or something.
00:23:19,528 -- 00:23:23,065
We're talking about now is anticipatory marketing.
00:23:23,065 -- 00:23:23,966
We're talking about,
00:23:25,401 -- 00:23:26,535
being able to
00:23:26,535 -- 00:23:28,671
get information to people, not just based on
00:23:28,671 -- 00:23:30,005
what do we know about them, but
00:23:30,005 -- 00:23:32,241
based on what we know about the 360 degrees
00:23:32,241 -- 00:23:34,209
that surround them, their location,
00:23:34,209 -- 00:23:36,011
the people around them,
00:23:36,011 -- 00:23:37,313
not just their own buying history,
00:23:37,313 -- 00:23:39,348
but the buying history people,
00:23:39,348 -- 00:23:40,482
that they interact with.
00:23:40,482 -- 00:23:41,317
And not just that,
00:23:41,317 -- 00:23:43,585
but also synthetic models of all that information.
00:23:43,585 -- 00:23:46,088
So we can run yet more granular simulations.
00:23:46,088 -- 00:23:47,890
And so I think that,
00:23:47,890 -- 00:23:50,225
if we keep thinking about AI for, say,
00:23:50,225 -- 00:23:52,728
consumer insights or positioning things
00:23:52,728 -- 00:23:54,063
that are better price to people,
00:23:54,063 -- 00:23:55,497
we might be talking about an old model.
00:23:55,497 -- 00:23:57,099
What AI is capable of now,
00:23:57,099 -- 00:24:00,069
given that it has a basically infinite amount of,
00:24:00,069 -- 00:24:02,771
data crunching power is much more powerful than that.
00:24:02,771 -- 00:24:05,841
And the key now is starting at the governance level
00:24:05,841 -- 00:24:08,010
to think through how to mitigate those risks.
00:24:08,010 -- 00:24:08,977
So can I ask you something?
00:24:08,977 -- 00:24:10,412
Because one of the things that struck me
00:24:10,412 -- 00:24:13,816
was, you know, the promise of technology 20 years ago
00:24:13,816 -- 00:24:15,784
was that we were going to have a three day work week.
00:24:15,784 -- 00:24:18,654
We'd have more time for our families, our lifestyles.
00:24:18,654 -- 00:24:20,823
And the exact opposite has happened.
00:24:20,823 -- 00:24:24,159
Do you think AI will deliver that promise?
00:24:24,159 -- 00:24:26,762
The promise of freeing up so productive
00:24:26,762 -- 00:24:29,665
that we get more free time? Yeah. Oh, not a chance. Okay,
00:24:31,033 -- 00:24:32,868
I think, I think
00:24:32,868 -- 00:24:34,570
the evidence is plain
00:24:34,570 -- 00:24:37,573
that we're going to find yet more applications,
00:24:37,573 -- 00:24:39,374
more ways that we can do more work.
00:24:39,374 -- 00:24:40,709
Like as I mentioned,
00:24:40,709 -- 00:24:42,845
think about the example of the individual
00:24:42,845 -- 00:24:44,279
who's suddenly much more productive.
00:24:44,279 -- 00:24:46,215
If the rate limiting factor in the past was
00:24:46,215 -- 00:24:47,583
how many clients it can take on,
00:24:47,583 -- 00:24:49,451
they'll just take on more instead of going home.
00:24:49,451 -- 00:24:50,853
But I think the insight here
00:24:50,853 -- 00:24:51,920
is even more profound than that,
00:24:51,920 -- 00:24:54,456
which is we're at a stage right now.
00:24:54,456 -- 00:24:56,692
The trajectory towards
00:24:56,692 -- 00:24:58,660
artificial general intelligence is not linear.
00:24:58,660 -- 00:25:00,629
There's a messy interregnum along the way.
00:25:00,629 -- 00:25:02,464
And so right now as generating all kinds
00:25:02,464 -- 00:25:03,999
of legal problems, right.
00:25:03,999 -- 00:25:05,701
It's generating all kinds of concerns
00:25:05,701 -- 00:25:07,436
that are requiring a second look, a critical
00:25:07,436 -- 00:25:09,204
eye, policies and procedures.
00:25:09,204 -- 00:25:11,073
So in our hunt for productivity,
00:25:11,073 -- 00:25:12,574
we're also generating all this,
00:25:12,574 -- 00:25:14,977
the secondary market of labor basically.
00:25:14,977 -- 00:25:18,880
I mean, where likewise, I mean, we're all kind of here
00:25:18,880 -- 00:25:23,218
because of that, right? And so, the chances of it being,
00:25:24,286 -- 00:25:25,120
contribute to a strict
00:25:25,120 -- 00:25:27,789
decrease in the amount of work that we do
00:25:27,789 -- 00:25:30,392
just doesn't seem probable.
00:25:30,392 -- 00:25:31,927
I was this close to getting Mark
00:25:31,927 -- 00:25:34,096
to go to a three day work week for us.
00:25:34,096 -- 00:25:36,832
Now, you just you totally kiboshed it. No.
00:25:36,832 -- 00:25:38,367
There's much more likely to be a six day
00:25:38,367 -- 00:25:41,169
work week in the world of AI.
00:25:41,169 -- 00:25:43,038
So, maybe I'll just put out there
00:25:43,038 -- 00:25:44,740
and whoever wants to jump on this one.
00:25:44,740 -- 00:25:47,943
There's a lot of focus, as you know, in the media, about,
00:25:47,943 -- 00:25:50,646
AI replacing various professional jobs,
00:25:50,646 -- 00:25:52,247
lawyers, accountants,
00:25:52,247 -- 00:25:55,283
and it will change the structure of the economy.
00:25:55,283 -- 00:25:58,387
In financial services, though, I think it's fair to say
00:25:58,387 -- 00:26:00,355
that it actually will have beneficial impacts
00:26:00,355 -- 00:26:02,357
in the area of,
00:26:02,357 -- 00:26:04,026
risk management,
00:26:04,026 -- 00:26:06,294
fraud detection and regulatory compliance.
00:26:06,294 -- 00:26:08,230
Can any of you comment on that?
00:26:09,531 -- 00:26:10,165
Maybe starting with.
00:26:10,165 -- 00:26:10,732
I can go first
00:26:10,732 -- 00:26:11,900
and maybe just on the topic
00:26:11,900 -- 00:26:13,869
of replacing humans in the workforce.
00:26:13,869 -- 00:26:16,571
I mean, I generally think of AI tools in this space
00:26:16,571 -- 00:26:18,140
in one of two buckets.
00:26:18,140 -- 00:26:20,242
One is sort of fully autonomous AI,
00:26:20,242 -- 00:26:22,344
and the second is just copilots.
00:26:22,344 -- 00:26:24,579
And there's a ton of copilot on the market
00:26:24,579 -- 00:26:27,883
that augment a human worker, but don't replace them.
00:26:27,883 -- 00:26:29,050
I think the more regulated
00:26:29,050 -- 00:26:29,618
the space is,
00:26:29,618 -- 00:26:30,385
the more likely it is
00:26:30,385 -- 00:26:32,220
we're going to see more of those copilots
00:26:32,220 -- 00:26:34,589
as opposed to fully autonomous software
00:26:34,589 -- 00:26:36,258
regulators are just gonna be more comfortable with it,
00:26:36,258 -- 00:26:37,292
knowing that there's ultimately
00:26:37,292 -- 00:26:39,461
a human still involved in the decision making,
00:26:39,461 -- 00:26:41,229
still apply their professional judgment,
00:26:41,229 -- 00:26:43,265
giving advice, etc.
00:26:43,265 -- 00:26:45,467
So we can talk a lot about sort of the risk
00:26:45,467 -- 00:26:46,334
mitigation and all that.
00:26:46,334 -- 00:26:48,570
But I do think at the end of the day,
00:26:48,570 -- 00:26:49,838
the tools we're going to see hit
00:26:49,838 -- 00:26:52,073
the market are more likely to be those copilots
00:26:52,073 -- 00:26:53,508
that don't actually replace jobs,
00:26:53,508 -- 00:26:54,809
that they make you more powerful,
00:26:54,809 -- 00:26:56,077
make you more proficient, and give you that
00:26:56,077 -- 00:26:57,012
efficiency boost.
00:26:58,480 -- 00:26:59,981
Carole, you're gonna jump in.
00:26:59,981 -- 00:27:03,752
I just want to highlight the point that,
00:27:03,752 -- 00:27:05,620
there is transition right now. Right.
00:27:05,620 -- 00:27:06,388
So we are
00:27:06,388 -- 00:27:08,857
we are very much in a world where we are trying
00:27:08,857 -- 00:27:10,725
to understand the technology
00:27:10,725 -- 00:27:14,362
as it changes exponentially or it feels like it is.
00:27:14,362 -- 00:27:16,064
So that's certainly the feeling
00:27:16,064 -- 00:27:17,766
and we're trying to adapt to it.
00:27:17,766 -- 00:27:21,136
And so we're using these very sort of analog constructs
00:27:21,136 -- 00:27:23,338
to make sense of what
00:27:23,338 -- 00:27:27,075
a much more digitally integrated world looks like.
00:27:27,075 -- 00:27:29,678
And that is very, very challenging.
00:27:29,678 -- 00:27:32,881
So I think a practical tip to take away
00:27:32,881 -- 00:27:34,182
is to sit down
00:27:34,182 -- 00:27:36,418
and really think through where
00:27:36,418 -- 00:27:39,087
there are strategic uses for this technology
00:27:39,087 -- 00:27:40,388
now, and I know I've said that,
00:27:40,388 -- 00:27:41,856
but I think it's really critical
00:27:41,856 -- 00:27:44,526
because it will start to shape that idea of
00:27:44,526 -- 00:27:47,429
what are we augmenting and what are we replacing.
00:27:47,429 -- 00:27:49,330
So what does it look like to do,
00:27:49,330 -- 00:27:52,600
go through that transition, and what do we anticipate
00:27:52,600 -- 00:27:55,403
the other side of the transition looking like,
00:27:55,403 -- 00:27:57,505
so that we can be a little bit more ready
00:27:57,505 -- 00:28:00,909
and much more agile in our strategic approach?
00:28:00,909 -- 00:28:02,510
and I think that's also helpful
00:28:02,510 -- 00:28:04,212
from a change management perspective,
00:28:04,212 -- 00:28:06,848
because all of this transition is also very,
00:28:06,848 -- 00:28:09,551
very, very difficult on workers
00:28:09,551 -- 00:28:12,120
and just this feeling of insecurity that,
00:28:12,120 -- 00:28:14,722
you know, I might be replaced even within my own law firm,
00:28:14,722 -- 00:28:15,824
I have to remind people,
00:28:15,824 -- 00:28:19,327
this is about enabling you to play to your higher strengths,
00:28:19,327 -- 00:28:22,130
as opposed to doing the stuff that we really shouldn't
00:28:22,130 -- 00:28:24,365
be doing and charging for in any case.
00:28:24,365 -- 00:28:26,034
So that change management piece,
00:28:26,034 -- 00:28:28,603
which is the people part of all of this,
00:28:28,603 -- 00:28:30,638
should not be underestimated.
00:28:30,638 -- 00:28:32,707
There's a lot of transition happening right now,
00:28:32,707 -- 00:28:35,043
and we need to help individuals
00:28:35,043 -- 00:28:37,779
understand what this transition process looks like
00:28:37,779 -- 00:28:39,447
and what the ultimate vision looks like
00:28:39,447 -- 00:28:41,316
and where they fit in.
00:28:41,316 -- 00:28:42,450
So we have two minutes.
00:28:42,450 -- 00:28:43,818
I do want to take time
00:28:43,818 -- 00:28:45,520
just to make sure there's any questions in the audience
00:28:45,520 -- 00:28:47,922
because we have, you know, just an amazing panel here.
00:28:49,324 -- 00:28:53,895
I can't see the question.
00:28:53,895 -- 00:28:55,930
Do one of you see it? You’re closer.
00:28:55,930 -- 00:28:58,600
We have a question here.
00:28:58,600 -- 00:29:00,501
similar to how climate change has introduced
00:29:00,501 -- 00:29:03,238
new risk classes such as transition and physical risk.
00:29:03,238 -- 00:29:04,305
What new classes
00:29:04,305 -- 00:29:09,310
do you see AI introducing in the financial sector?
00:29:10,778 -- 00:29:12,413
Do you want to just I want to take note.
00:29:12,413 -- 00:29:15,316
I mean, I think the broad risks that AI introduce
00:29:15,316 -- 00:29:17,485
generally are still good applied in financial services.
00:29:17,485 -- 00:29:20,421
So, confidentiality is going to be a big issue.
00:29:20,421 -- 00:29:22,457
And it's a there's a bit of a tension there.
00:29:22,457 -- 00:29:24,759
Because if you want your AI to be highly performant,
00:29:24,759 -- 00:29:26,060
you want it to have more data,
00:29:26,060 -- 00:29:26,995
and you want that data to come
00:29:26,995 -- 00:29:28,262
from a broad number of sources
00:29:28,262 -- 00:29:29,797
so that it has more context.
00:29:29,797 -- 00:29:31,299
But then you start blending information
00:29:31,299 -- 00:29:31,899
for different sources,
00:29:31,899 -- 00:29:34,502
and then you get into more issues about confidentiality.
00:29:34,502 -- 00:29:35,269
So I think one area
00:29:35,269 -- 00:29:36,671
that we got to think about in financial services
00:29:36,671 -- 00:29:38,272
in particular is going to be
00:29:38,272 -- 00:29:40,742
how do we make sure we have a lot of good quality data
00:29:40,742 -- 00:29:42,610
that comes from multiple contexts
00:29:42,610 -- 00:29:44,545
and yet still preserves the confidentiality?
00:29:44,545 -- 00:29:46,547
I think that's one sort of unique risk,
00:29:46,547 -- 00:29:48,583
particularly with AI in financial services, in particular.
00:29:49,784 -- 00:29:51,386
I might just add that I
00:29:51,386 -- 00:29:54,722
think the nature of the risks faced by
00:29:54,722 -- 00:29:55,690
financial institutions
00:29:55,690 -- 00:29:57,392
is just going to become more complicated.
00:29:57,392 -- 00:29:58,159
Threat actors
00:29:58,159 -- 00:30:00,361
also have AI in their possession,
00:30:00,361 -- 00:30:03,364
and they're governed by absolutely no one but themselves.
00:30:03,364 -- 00:30:05,133
So I would just be mindful
00:30:05,133 -- 00:30:07,201
of the changing threat landscape as well,
00:30:07,201 -- 00:30:09,303
and the insecurity of some of these systems,
00:30:09,303 -- 00:30:12,840
and who has access to some of these systems.
00:30:12,840 -- 00:30:14,675
If I can. Absolutely. If I can add one thing.
00:30:14,675 -- 00:30:17,779
There has to be a cultural shift as we embrace AI,
00:30:17,779 -- 00:30:19,180
which is, I think,
00:30:19,180 -- 00:30:20,181
if I, if I may,
00:30:20,181 -- 00:30:22,517
we have to kind of increase our error tolerance
00:30:22,517 -- 00:30:23,451
when it comes to technology.
00:30:23,451 -- 00:30:26,053
So if I hit my space bar on my laptop
00:30:26,053 -- 00:30:28,322
and it doesn't move the cursor a millimeter,
00:30:28,322 -- 00:30:29,056
if it doesn’t move the cursor
00:30:29,056 -- 00:30:31,125
a millimeter on my word processor, it's
00:30:31,125 -- 00:30:33,361
my laptop is broken. I might throw it against the wall.
00:30:33,361 -- 00:30:34,695
Right. It's clearly a failure.
00:30:34,695 -- 00:30:36,864
Binary states of fail or not.
00:30:36,864 -- 00:30:38,799
But if I'm asking a
00:30:38,799 -- 00:30:39,667
AI application
00:30:39,667 -- 00:30:42,036
to do something like draft a memo,
00:30:42,036 -- 00:30:45,139
then I can think about it in these binary states of,
00:30:45,139 -- 00:30:46,974
failure or not. An error,
00:30:46,974 -- 00:30:49,176
the fact that it produces error can't
00:30:50,211 -- 00:30:51,279
condemn it in
00:30:51,279 -- 00:30:54,782
the same way that me hitting the space bar on my laptop
00:30:54,782 -- 00:30:56,617
not working will condemn my laptop.
00:30:56,617 -- 00:30:57,351
You have to again
00:30:57,351 -- 00:30:59,654
force into the familiar template of the division of labor
00:30:59,654 -- 00:31:00,788
where if
00:31:00,788 -- 00:31:02,723
someone that you work with, a junior colleague
00:31:02,723 -- 00:31:04,825
gave you a memo and it had some issues,
00:31:04,825 -- 00:31:06,193
you would find a way to work with them
00:31:06,193 -- 00:31:08,562
and engage in this dialogical iterative process.
00:31:08,562 -- 00:31:11,098
If AI is aspiring to these higher order tasks,
00:31:11,098 -- 00:31:14,335
it's going to misfire sometimes.
00:31:14,335 -- 00:31:17,104
And until we can absorb that cultural reality
00:31:17,104 -- 00:31:18,039
of needing
00:31:18,039 -- 00:31:19,540
to increase our error tolerance,
00:31:19,540 -- 00:31:20,207
we're probably going
00:31:20,207 -- 00:31:21,909
to have the same conversation over and over again
00:31:21,909 -- 00:31:23,711
where we're not going to
00:31:23,711 -- 00:31:26,847
realize all the gains that are in front of us.
00:31:26,847 -- 00:31:27,948
So I'm conscious of time,
00:31:27,948 -- 00:31:29,917
and I'm also conscious that we’re the last panel
00:31:29,917 -- 00:31:30,584
before lunch.
00:31:30,584 -- 00:31:34,689
So what I did last night was I went on to Chat GPD
00:31:34,689 -- 00:31:37,291
chit Chat GPT, pardon me, and I said, what are the best
00:31:37,291 -- 00:31:40,294
wrap up comments to ask an expert panel on AI?
00:31:41,228 -- 00:31:42,763
And what I got back was,
00:31:42,763 -- 00:31:44,231
we conclude our discussion today,
00:31:44,231 -- 00:31:46,133
it is clear that artificial intelligence
00:31:46,133 -- 00:31:49,003
is not just revolutionizing financial services,
00:31:49,003 -- 00:31:50,771
but it's redefining the very nature
00:31:50,771 -- 00:31:54,175
of how we interact with data markets and customers.
00:31:54,175 -- 00:31:57,244
From predictive analytics,
00:31:57,244 -- 00:31:58,779
to algorithmic trading,
00:31:58,779 -- 00:32:00,748
AI has become the cornerstone of innovation
00:32:00,748 -- 00:32:02,116
in the financial sector,
00:32:02,116 -- 00:32:03,651
driving efficiency,
00:32:03,651 -- 00:32:06,921
accuracy, and agility like never before.
00:32:06,921 -- 00:32:09,557
Our panel has underscored the importance of responsible
00:32:09,557 -- 00:32:10,691
AI implementation.
00:32:10,691 -- 00:32:12,893
Ensuring transparency, fairness,
00:32:12,893 -- 00:32:14,628
and ethical considerations remain
00:32:14,628 -- 00:32:19,200
at the forefront of our strategies. That's pretty good.
00:32:19,200 -- 00:32:21,936
So Mark's like thinking, okay, I can get rid of Solway
00:32:21,936 -- 00:32:24,505
and I can get ChatGPT.
00:32:24,505 -- 00:32:27,775
Please join me in thanking our panelists who, you know...
00:00:05,372 -- 00:00:06,473
That was quite a morning.
00:00:06,473 -- 00:00:09,109
I hope everybody enjoyed it.
00:00:09,109 -- 00:00:10,777
This morning made it clear to me
00:00:10,777 -- 00:00:14,514
that we are indeed regulating in a rapidly changing environment.
00:00:15,181 -- 00:00:20,053
My favorite organizational psychologist, Abraham Maslow, the Hierarchy of Needs,
00:00:20,720 -- 00:00:25,158
said that when we're faced with change, we can step forward into growth
00:00:25,692 -- 00:00:28,161
or step back into safety.
00:00:28,161 -- 00:00:31,164
At FSRA, we embrace your choice
00:00:31,197 -- 00:00:34,134
to step forward into growth.
00:00:34,134 -- 00:00:37,871
Given this choice, the magnitude and the pace of change
00:00:38,304 -- 00:00:41,307
is both an opportunity and a challenge.
00:00:41,374 -- 00:00:43,343
Minister Bethlenfalvy noted
00:00:43,343 -- 00:00:48,648
our fast changing financial services environment
00:00:49,182 -- 00:00:51,084
is both an opportunity and a challenge,
00:00:51,284 -- 00:00:54,120
but he correctly identified the collaboration
00:00:54,120 -- 00:00:57,123
between government regulators and stakeholders
00:00:57,490 -- 00:01:01,861
is the key to successfully tackle whatever challenges will come our way.
00:01:03,063 -- 00:01:05,432
Joanne, Business Chair
00:01:05,432 -- 00:01:08,468
identified that FSRA's principles-based approach
00:01:09,002 -- 00:01:12,806
gives us the flexibility to focus on outcomes as businesses change,
00:01:14,407 -- 00:01:18,211
and that with reliable information that enables us to proactively
00:01:18,211 -- 00:01:23,583
identify issues with higher accuracy and not intrusive supervision,
00:01:24,050 -- 00:01:27,053
that that will allow us to progressively regulate better.
00:01:28,288 -- 00:01:30,223
During the climate change session,
00:01:30,223 -- 00:01:34,027
one of the major takeaways for me was that what we're seeing today
00:01:34,027 -- 00:01:36,196
may be irreversible.
00:01:36,262 -- 00:01:39,866
The actions that we take as a global community can slow down
00:01:39,866 -- 00:01:43,436
the pace of climate change, but we need to be ready
00:01:43,536 -- 00:01:46,473
for a new paradigm.
00:01:46,473 -- 00:01:49,442
This will exert a profound influence
00:01:49,442 -- 00:01:52,378
on financial services,
00:01:52,378 -- 00:01:54,247
introducing new challenges,
00:01:54,247 -- 00:01:58,718
whether they be physical risks to people, property and businesses,
00:01:59,352 -- 00:02:04,190
or transition risks to the shift to a low carbon economy.
00:02:05,625 -- 00:02:09,095
To mitigate these risks, it requires a collaborative approach.
00:02:09,929 -- 00:02:13,266
The discussion on artificial intelligence provided food for thought.
00:02:14,334 -- 00:02:17,804
A.I. indeed transforming the landscape of financial services
00:02:18,271 -- 00:02:21,808
and revolutionizing the way institutions operate,
00:02:23,009 -- 00:02:25,411
the way they make decisions and interact with clients
00:02:25,411 -- 00:02:28,414
and others will be fundamentally changed.
00:02:28,448 -- 00:02:31,584
It also raises concerns about data protection,
00:02:31,784 -- 00:02:34,821
privacy and potential bias.
00:02:34,821 -- 00:02:35,488
At FSRA,
00:02:35,989 -- 00:02:38,324
we work with our sectors,
00:02:38,324 -- 00:02:41,327
the government and other regulators to better understand
00:02:41,461 -- 00:02:44,430
exactly how these issues are to be addressed.
00:02:45,265 -- 00:02:47,100
We always do so to make sure
00:02:47,100 -- 00:02:50,103
that consumer protection is prioritized.
00:02:50,370 -- 00:02:54,274
After all, consumer protection is at the heart of everything we do at FSRA.
00:02:54,607 -- 00:02:57,510
That's our North Star.
00:02:57,510 -- 00:02:59,646
Our approach to regulation, rulemaking,
00:02:59,646 -- 00:03:02,916
supervision and enforcement is developed
00:03:02,916 -- 00:03:05,919
and executed with consumer protection always at the forefront.
00:03:07,020 -- 00:03:09,088
We're now approaching our fifth year.
00:03:09,088 -- 00:03:10,623
We remain a work in progress.
00:03:10,623 -- 00:03:13,626
Or, as the Minister said, we're still a puppy.
00:03:14,093 -- 00:03:15,228
I love puppies, by the way.
00:03:15,228 -- 00:03:17,297
They're so cute.
00:03:17,297 -- 00:03:19,032
Yet with your help
00:03:19,032 -- 00:03:21,701
and your advocacy and questioning,
00:03:21,701 -- 00:03:24,971
we’ll continue to grow and improve the lives of people in Ontario.
00:03:26,005 -- 00:03:28,174
As I look back at 2023,
00:03:28,174 -- 00:03:31,010
there have been many noteworthy accomplishments.
00:03:31,010 -- 00:03:32,779
Let me highlight a few.
00:03:32,779 -- 00:03:36,916
We issued our Take All Comers report detailing systemic noncompliance
00:03:37,217 -- 00:03:40,220
by our 12 largest auto insurers.
00:03:40,220 -- 00:03:42,422
We also identified and acted on
00:03:42,422 -- 00:03:45,425
troubling practices in the life and health insurance business,
00:03:46,125 -- 00:03:48,328
and we proposed guidance to help address that,
00:03:48,328 -- 00:03:50,830
to define who is suitable to be a life agent.
00:03:51,764 -- 00:03:55,802
We're working to ensure that all life agents, including managing general agents,
00:03:56,236 -- 00:03:59,072
will treat customers fairly and respect the law.
00:04:00,807 -- 00:04:01,975
Our Credit Union
00:04:01,975 -- 00:04:05,245
and our insurance prudential groups had conferences last September.
00:04:06,246 -- 00:04:08,881
They strengthened the relationship between FSRA
00:04:08,881 -- 00:04:10,750
and the attending directors.
00:04:10,750 -- 00:04:13,620
We talked about how important risk-based supervision is
00:04:13,620 -- 00:04:16,623
and what principles-based regulation really means.
00:04:17,557 -- 00:04:20,526
In addition, we completed our most ambitious
00:04:20,526 -- 00:04:23,930
consumer education campaigns to date.
00:04:23,930 -- 00:04:25,598
To level the playing field,
00:04:25,598 -- 00:04:28,201
our consumer messages were direct.
00:04:28,201 -- 00:04:31,170
If you're getting a private mortgage, know what you're signing.
00:04:31,838 -- 00:04:35,275
If you're buying life or health insurance, ask the right questions.
00:04:36,009 -- 00:04:39,012
If you're getting auto insurance, shop around
00:04:39,345 -- 00:04:42,348
and learn the value of pensions and saving early.
00:04:43,483 -- 00:04:48,421
I'm pleased that our recent Pension Awareness Day was the most successful ever.
00:04:48,655 -- 00:04:51,691
Finally, I want to thank all of you who participated.
00:04:52,358 -- 00:04:56,829
Those who led our discussions, notably Minister Bethlenfalvy,
00:04:56,829 -- 00:04:58,831
our chair, Joanne De Laurentiis,
00:04:58,831 -- 00:05:00,333
my inquisitor, Clare O'Hare.
00:05:00,733 -- 00:05:04,771
Judy, our host for the day, and all of our panels and moderators.
00:05:05,738 -- 00:05:08,241
I'd like to thank those here in person and online
00:05:08,241 -- 00:05:11,044
for taking time out of your busy days to attend
00:05:11,044 -- 00:05:13,913
our third annual FSRA Exchange.
00:05:13,913 -- 00:05:16,983
And finally, to our many conference organizers,
00:05:16,983 -- 00:05:18,351
because it does take a village.
00:05:18,351 -- 00:05:19,552
Thank you!
00:05:19,552 -- 00:05:22,555
For without you, there would be no Exchange.
00:05:23,022 -- 00:05:27,093
We value this opportunity to connect and to exchange ideas with each other.
00:05:28,027 -- 00:05:31,030
You have the sector workshops to look forward to this afternoon,
00:05:31,331 -- 00:05:32,732
followed by our reception.
00:05:32,732 -- 00:05:35,735
But first, there's lunch. Bon appétit!
00:05:35,935 -- 00:05:36,803
And have a great day.
00:00:04,971 -- 00:00:06,473
I want to welcome you all here.
00:00:06,473 -- 00:00:07,273
Good afternoon.
00:00:07,273 -- 00:00:08,375
My name is Gina Stephens.
00:00:08,375 -- 00:00:12,078
I'm the Director of Mortgage Broker Conduct at FSRA.
00:00:12,078 -- 00:00:14,414
Thank you, folks, for joining us in person.
00:00:14,414 -- 00:00:17,317
And for those of you that are online. Welcome.
00:00:17,317 -- 00:00:18,184
Before we begin,
00:00:18,184 -- 00:00:20,553
I want to remind everyone that this is being taped.
00:00:20,553 -- 00:00:22,021
That includes our panelists.
00:00:22,021 -- 00:00:23,857
This is being taped.
00:00:23,857 -- 00:00:25,458
And there's simultaneous
00:00:25,458 -- 00:00:27,694
French translation for anyone who needs it.
00:00:27,694 -- 00:00:29,229
So if you're in the room
00:00:29,229 -- 00:00:32,665
and you would like a headset for simultaneous translation,
00:00:32,665 -- 00:00:33,433
just put up your hand.
00:00:33,433 -- 00:00:35,935
And our staff will come in and meet you there.
00:00:35,935 -- 00:00:39,472
For those of you online that are attending virtually,
00:00:39,472 -- 00:00:42,275
you can click the initials at the top right
00:00:42,275 -- 00:00:45,778
corner of your screen, and you can select Set Language
00:00:45,778 -- 00:00:48,381
to listen to this session in French.
00:00:49,449 -- 00:00:52,485
We will be taking questions at the end of the session
00:00:52,485 -- 00:00:53,720
through the conference site.
00:00:53,720 -- 00:00:56,956
So we don't have mics going around, but,
00:00:56,956 -- 00:00:58,224
we will be taking questions
00:00:58,224 -- 00:01:00,360
that are fed through the Chime app.
00:01:00,360 -- 00:01:02,395
If for some reason you're here
00:01:02,395 -- 00:01:04,731
and you're having difficulty connecting to the app,
00:01:04,731 -- 00:01:07,033
you can always flag down a FSRA staff member
00:01:07,033 -- 00:01:09,102
and give them your question directly
00:01:09,102 -- 00:01:11,170
and they'll feed it into the app.
00:01:11,170 -- 00:01:13,006
For the folks that are supporting us in the back,
00:01:13,006 -- 00:01:16,342
thank you.
00:01:16,342 -- 00:01:18,711
So now let me introduce our expert panel.
00:01:18,711 -- 00:01:20,613
I'm sure that many of these folks
00:01:20,613 -- 00:01:22,582
do not need an introduction, but nonetheless,
00:01:22,582 -- 00:01:24,484
I will give you a short introduction.
00:01:24,484 -- 00:01:26,686
I encourage you to look at their full bios
00:01:26,686 -- 00:01:28,755
that are on the FSRA event page,
00:01:28,755 -- 00:01:29,989
but to save us some time
00:01:29,989 -- 00:01:31,991
to get into some juicy conversation,
00:01:31,991 -- 00:01:33,793
we're going to do a short introduction
00:01:33,793 -- 00:01:35,595
and then launch right in.
00:01:35,595 -- 00:01:39,065
So I'm joined today by Dong Lee.
00:01:39,065 -- 00:01:41,868
He is the former Principal Broker of Mortgage Architects
00:01:41,868 -- 00:01:43,536
and also the former President
00:01:43,536 -- 00:01:46,439
and COO of DLC Group of Companies.
00:01:46,439 -- 00:01:50,143
Most recently, Dong became the CEO of Axiom Innovations.
00:01:50,143 -- 00:01:52,311
It's one of Canada's largest independent
00:01:52,311 -- 00:01:54,280
point of sale platforms.
00:01:55,481 -- 00:01:57,917
Dong is joined by Kerri Reed.
00:01:57,917 -- 00:01:59,919
She is the Principal Broker and Partner
00:01:59,919 -- 00:02:02,422
at Premiere Mortgage Centre.
00:02:02,422 -- 00:02:04,757
I'm also joined by Sadiq right beside me here,
00:02:04,757 -- 00:02:05,758
who is the Principal Broker
00:02:05,758 -- 00:02:08,327
and CEO of Approved Financial Services.
00:02:08,327 -- 00:02:09,762
And, last
00:02:09,762 -- 00:02:12,598
but not least, in terms of our industry participants,
00:02:12,598 -- 00:02:15,034
Ron Butler is here from Butler Mortgage,
00:02:15,034 -- 00:02:16,369
and you may know him
00:02:16,369 -- 00:02:20,006
also as the star of the Angry Mortgage Podcast.
00:02:20,006 -- 00:02:22,241
I am also joined by Antoinette.
00:02:22,241 -- 00:02:25,178
She's the Head of Financial Institutions
00:02:25,178 -- 00:02:27,113
and Mortgage Brokerage Conduct at FSRA.
00:02:27,113 -- 00:02:29,782
My boss. So no pressure
00:02:29,782 -- 00:02:30,950
and,
00:02:30,950 -- 00:02:33,152
we're here this afternoon to discuss
00:02:33,152 -- 00:02:36,189
something that is very topical.
00:02:36,189 -- 00:02:38,958
It couldn't be more timely in terms of some of the concerns
00:02:38,958 -- 00:02:41,260
that FSRA is seeing in the marketplace
00:02:41,260 -- 00:02:45,064
that some of the speakers earlier today mentioned.
00:02:45,064 -- 00:02:48,501
Interest rates are very high, housing prices are high.
00:02:48,501 -- 00:02:50,803
Most homeowners are seeing huge jumps
00:02:50,803 -- 00:02:52,872
in their mortgage payments,
00:02:52,872 -- 00:02:54,073
and it's getting more
00:02:54,073 -- 00:02:55,608
and more difficult for consumers
00:02:55,608 -- 00:02:57,577
to find affordable mortgage solutions
00:02:57,577 -- 00:02:59,912
when they're looking to buy a home.
00:02:59,912 -- 00:03:02,548
So it's really critical for the mortgage broker sector.
00:03:02,548 -- 00:03:04,784
The advice and the services that you provide to
00:03:04,784 -- 00:03:07,620
your clients has never been more important.
00:03:07,620 -- 00:03:09,088
But in this context, FSRA
00:03:09,088 -- 00:03:11,357
is increasingly concerned
00:03:11,357 -- 00:03:13,859
about, number one, protecting consumers.
00:03:13,859 -- 00:03:16,762
I think you've heard that through all the sessions today.
00:03:16,762 -- 00:03:19,265
ensuring that mortgage brokers are keeping
00:03:19,265 -- 00:03:21,567
their clients' interests top of mind
00:03:21,567 -- 00:03:22,635
and most importantly,
00:03:22,635 -- 00:03:24,070
making sure that consumers
00:03:24,070 -- 00:03:25,905
and investors are receiving mortgage
00:03:25,905 -- 00:03:27,540
product recommendations
00:03:27,540 -- 00:03:29,408
that are suitable for their specific
00:03:29,408 -- 00:03:31,544
needs and circumstances.
00:03:31,544 -- 00:03:33,879
So one of FSRA’s stated priorities
00:03:33,879 -- 00:03:34,914
this year,
00:03:34,914 -- 00:03:36,449
in keeping with this session,
00:03:36,449 -- 00:03:38,517
is to develop and release Guidance
00:03:38,517 -- 00:03:41,887
that is going to enhance principal broker effectiveness.
00:03:41,887 -- 00:03:44,623
We've been working really hard on this proposed Guidance,
00:03:44,623 -- 00:03:46,225
and once it's ready to be published,
00:03:46,225 -- 00:03:47,693
we're very much looking forward
00:03:47,693 -- 00:03:50,563
to your feedback on this topical subject
00:03:50,563 -- 00:03:52,665
that is going to really address
00:03:52,665 -- 00:03:54,233
some of the issues that we talk about
00:03:54,233 -- 00:03:56,268
with our guests here today.
00:03:56,268 -- 00:03:57,403
So without further ado,
00:03:57,403 -- 00:04:00,339
I'd like to launch into the discussion that we're here,
00:04:00,339 -- 00:04:01,674
to participate
00:04:01,674 -- 00:04:04,777
in creating and supporting a strong conduct
00:04:04,777 -- 00:04:07,079
culture in Mortgage Brokerage.
00:04:07,079 -- 00:04:08,981
So I want to begin with a question.
00:04:08,981 -- 00:04:13,152
If I can direct it, to Sadiq.
00:04:13,152 -- 00:04:15,821
Sadiq, how have you changed your approach
00:04:15,821 -- 00:04:18,290
to setting the right tone from the top,
00:04:18,290 -- 00:04:19,158
as we've seen
00:04:19,158 -- 00:04:21,627
the economic fundamentals changing
00:04:21,627 -- 00:04:23,762
now that we're seeing some of the issues
00:04:23,762 -- 00:04:26,198
that I pointed out earlier, higher interest rates, greater
00:04:26,198 -- 00:04:29,068
difficulty for consumers and qualifying for mortgages,
00:04:29,068 -- 00:04:30,669
low housing supply.
00:04:30,669 -- 00:04:32,404
This is the kind of,
00:04:32,404 -- 00:04:35,574
environment where you see people wanting to cut corners
00:04:35,574 -- 00:04:37,877
because their volumes are getting lower.
00:04:38,944 -- 00:04:40,679
You know, how do you deal with that
00:04:40,679 -- 00:04:42,681
in your mortgage brokerage?
00:04:42,681 -- 00:04:45,517
So would say on the compliance standpoint,
00:04:45,517 -- 00:04:46,585
not much has really changed
00:04:46,585 -- 00:04:48,621
because we've always had a very strong,
00:04:48,621 -- 00:04:49,688
focus on compliance.
00:04:49,688 -- 00:04:51,790
We've always, you know,
00:04:51,790 -- 00:04:54,793
put the emphasis on doing what's right for the client
00:04:54,793 -- 00:04:56,795
where things have changed in the past.
00:04:56,795 -- 00:05:00,232
We would be looking kind of more of the meeting
00:05:00,232 -- 00:05:01,800
the immediate need of the client.
00:05:01,800 -- 00:05:04,503
Now that the immediate need has kind of become twofold.
00:05:04,503 -- 00:05:07,806
We're looking at the short term, you know, 2 to 3 year
00:05:07,806 -- 00:05:09,642
goal of the client, the longer,
00:05:09,642 -- 00:05:13,012
prospects of where rates can go into five years.
00:05:13,012 -- 00:05:13,779
So looking at,
00:05:13,779 -- 00:05:15,981
you know, how do we balance clients' affordability
00:05:15,981 -- 00:05:18,283
with their desire for lower rates.
00:05:18,283 -- 00:05:19,418
So looking at,
00:05:19,418 -- 00:05:21,720
you know, putting them into a shorter term product
00:05:21,720 -- 00:05:22,488
that would,
00:05:22,488 -- 00:05:22,788
you know,
00:05:22,788 -- 00:05:24,356
still be affordable
00:05:24,356 -- 00:05:26,825
while giving them flexibility to exit from that product
00:05:26,825 -- 00:05:29,495
should rates eventually come down.
00:05:29,495 -- 00:05:30,963
I think that's one of the biggest concerns
00:05:30,963 -- 00:05:33,499
on homeowners minds right now.
00:05:33,499 -- 00:05:34,566
And what we've done with
00:05:34,566 -- 00:05:37,069
that is we've focused on assessing
00:05:37,069 -- 00:05:39,071
all possible options, opening up,
00:05:39,071 -- 00:05:39,438
you know,
00:05:39,438 -- 00:05:41,774
all the discussions into different types of products,
00:05:41,774 -- 00:05:44,710
different ways of how they can balance their finances
00:05:44,710 -- 00:05:48,380
and how we can help them kind of plan for those changes,
00:05:48,380 -- 00:05:50,182
regardless of which way the market goes,
00:05:50,182 -- 00:05:51,950
to give them more flexibility.
00:05:51,950 -- 00:05:55,521
And I think that's the key to it, is really the discussion
00:05:55,521 -- 00:05:59,258
and it's not us pushing a solution out to the client.
00:05:59,258 -- 00:06:00,859
It's more collaboration with the client
00:06:00,859 -- 00:06:01,894
so that they feel involved
00:06:01,894 -- 00:06:03,929
and they feel confident in the direction
00:06:03,929 -- 00:06:07,332
of how their mortgage and how their finances is heading.
00:06:07,332 -- 00:06:08,700
And those types of conversations
00:06:08,700 -- 00:06:10,869
are really how you determine suitability.
00:06:10,869 -- 00:06:13,472
And you make sure that you have the information
00:06:13,472 -- 00:06:15,607
you need to find a product
00:06:15,607 -- 00:06:16,208
that's suitable
00:06:16,208 -- 00:06:17,342
for that person in front of you
00:06:17,342 -- 00:06:19,945
that's going to last through this period
00:06:19,945 -- 00:06:21,580
of of economic change.
00:06:21,580 -- 00:06:24,149
Hands down, it’s suitability, reasonability.
00:06:24,149 -- 00:06:26,985
And depending on the type of mortgage exit strategy.
00:06:26,985 -- 00:06:29,254
And that's kind of the three fundamentals that we look at
00:06:29,254 -- 00:06:30,255
with every single client.
00:06:31,323 -- 00:06:31,790
That's great.
00:06:31,790 -- 00:06:35,360
I'm going to actually ask Kerrie to chime in if she has,
00:06:35,360 -- 00:06:37,629
any different approaches in your brokerage.
00:06:37,629 -- 00:06:40,699
I know you're brokerage is quite large, so,
00:06:40,699 -- 00:06:42,334
just to see if you have anything to add
00:06:42,334 -- 00:06:45,304
to what Sadiq has, has mentioned to us.
00:06:45,304 -- 00:06:46,939
I think the focus,
00:06:46,939 -- 00:06:47,773
along with,
00:06:47,773 -- 00:06:48,407
with Sadiq’s
00:06:48,407 -- 00:06:51,176
brokerage, the focus is about ensuring
00:06:51,176 -- 00:06:53,812
that the agents and brokers have confidence
00:06:53,812 -- 00:06:55,347
when they're talking to clients
00:06:55,347 -- 00:06:57,015
and the needs and wants of those clients.
00:06:57,015 -- 00:07:00,252
So there are some very dramatic changes, interest rates,
00:07:00,252 -- 00:07:01,320
you know,
00:07:01,320 -- 00:07:02,421
lack of housing,
00:07:02,421 -- 00:07:05,490
even affordability of the housing that they currently own.
00:07:05,490 -- 00:07:05,857
Right.
00:07:05,857 -- 00:07:09,728
So we've spent a significant amount of time,
00:07:09,728 -- 00:07:13,298
training and informing the agents and the brokers
00:07:13,298 -- 00:07:15,100
of what these changes
00:07:15,100 -- 00:07:17,769
mean in their own portfolios of business,
00:07:17,769 -- 00:07:19,571
right, their own book of business.
00:07:19,571 -- 00:07:21,340
Actually drilling it right down to
00:07:21,340 -- 00:07:23,709
how is this going to impact your clients?
00:07:25,410 -- 00:07:29,414
We've brought in and encourage and continue to train,
00:07:29,414 -- 00:07:33,318
bring in the experts on alternative products,
00:07:33,318 -- 00:07:35,020
different strategies.
00:07:35,020 -- 00:07:36,188
You know, I'm not going to claim
00:07:36,188 -- 00:07:37,823
to be the expert for everybody,
00:07:37,823 -- 00:07:40,392
and neither will the rest of the leadership team
00:07:40,392 -- 00:07:41,660
at Premiere Mortgage Centre.
00:07:41,660 -- 00:07:43,528
But we encourage,
00:07:43,528 -- 00:07:45,831
you know, that the sharing is caring model, right?
00:07:45,831 -- 00:07:47,365
Which is, bring in the people
00:07:47,365 -- 00:07:49,935
that can talk with the agents and brokers
00:07:49,935 -- 00:07:51,269
to give them the confidence
00:07:51,269 -- 00:07:54,406
to build the strategies with their clients.
00:07:54,406 -- 00:07:54,706
Right.
00:07:54,706 -- 00:07:56,007
Providing solutions
00:07:56,007 -- 00:07:59,211
that, you know, are actually going to,
00:07:59,211 -- 00:08:00,479
are actually going to bring the result
00:08:00,479 -- 00:08:01,813
that everyone's looking for, right?
00:08:01,813 -- 00:08:03,648
We're not just throwing them into something.
00:08:03,648 -- 00:08:05,917
There's a lot of training involved in the last
00:08:05,917 -- 00:08:07,919
year and year or two years.
00:08:09,855 -- 00:08:11,623
A lot of agents and brokers were kind of
00:08:11,623 -- 00:08:14,292
just walking the path every day. Right?
00:08:14,292 -- 00:08:16,862
It was it was it was an easy path to walk.
00:08:16,862 -- 00:08:18,196
And it's not today.
00:08:18,196 -- 00:08:21,099
So it was really important for us.
00:08:21,099 -- 00:08:23,902
And it remains top of top of the list
00:08:23,902 -- 00:08:26,137
to ensure that the information
00:08:26,137 -- 00:08:27,706
is available to the agents and brokers.
00:08:27,706 -- 00:08:29,274
They understand the information,
00:08:29,274 -- 00:08:30,642
they know what's available.
00:08:30,642 -- 00:08:31,910
We're training to it,
00:08:31,910 -- 00:08:34,579
and they can provide strategies that,
00:08:34,579 -- 00:08:37,582
that their clients are actually going to benefit from.
00:08:37,582 -- 00:08:39,584
So to Kerrie's point, it's
00:08:39,584 -- 00:08:42,454
a reminder of the story of a of a mortgage broker who,
00:08:42,454 -- 00:08:45,090
in the midst of all the interest rate hikes
00:08:45,090 -- 00:08:46,491
and something brave and courageous,
00:08:46,491 -- 00:08:49,127
she emailed all of her variable rate customers and said,
00:08:49,127 -- 00:08:51,429
if you want to have a conversation,
00:08:51,429 -- 00:08:54,432
please book some time with me on my account.
00:08:54,432 -- 00:08:56,868
She got booked for the entire month.
00:08:56,868 -- 00:08:59,304
And I said to her, I said, I said were you scared?
00:08:59,304 -- 00:08:59,604
She goes,
00:08:59,604 -- 00:09:01,873
I was terrified about the comments
00:09:01,873 -- 00:09:02,440
you get back,
00:09:02,440 -- 00:09:05,810
how could you dare put me into a variable mortgage?
00:09:05,810 -- 00:09:07,045
It's a worst decision in my life.
00:09:07,045 -- 00:09:09,781
She said of the 50 conversations she had,
00:09:09,781 -- 00:09:11,516
she said only one customer came back
00:09:11,516 -- 00:09:13,084
and was really angry at her.
00:09:13,084 -- 00:09:14,352
The rest of them were just thankful
00:09:14,352 -- 00:09:16,421
that she took the time to have that conversation with them.
00:09:16,421 -- 00:09:18,556
Because I think the problem these days is,
00:09:18,556 -- 00:09:20,458
is we get so nervous about the conversation
00:09:20,458 -- 00:09:21,626
we have to have with our customers
00:09:21,626 -- 00:09:24,396
when the truth is, if you just get ahead of it,
00:09:24,396 -- 00:09:26,264
the great things happen. I think that's to carry Sadiq’s
00:09:26,264 -- 00:09:27,966
point is, is
00:09:27,966 -- 00:09:31,035
if we are there to provide advice to the customer,
00:09:31,035 -- 00:09:31,970
I think there's so many people
00:09:31,970 -- 00:09:34,072
who are afraid to have that conversation.
00:09:34,072 -- 00:09:35,173
I think my financial planner,
00:09:35,173 -- 00:09:38,343
who didn't once called me through the entire changes
00:09:38,343 -- 00:09:40,145
to the interest rate environment and didn't
00:09:40,145 -- 00:09:42,213
once call me when my portfolio was declining.
00:09:42,213 -- 00:09:43,047
And so, you know what I mean?
00:09:43,047 -- 00:09:44,382
It's just one of those things, I think.
00:09:44,382 -- 00:09:46,918
I think as an industry, we're doing a better job with.
00:09:46,918 -- 00:09:48,119
I agree, I think,
00:09:49,120 -- 00:09:52,223
you know, Ron, although you would disagree with,
00:09:52,223 -- 00:09:53,958
mortgage brokers being order takers
00:09:53,958 -- 00:09:55,326
at times from clients
00:09:55,326 -- 00:09:58,229
who seem to believe that they know what's best for them.
00:09:58,229 -- 00:09:59,597
We're now in an environment
00:09:59,597 -- 00:10:02,300
where we're no longer taking orders,
00:10:02,300 -- 00:10:05,270
and or orders aren't being shouted at us from clients
00:10:05,270 -- 00:10:06,738
who are now providing solutions.
00:10:06,738 -- 00:10:09,607
So you just got to have the information, right?
00:10:09,607 -- 00:10:09,874
You know,
00:10:09,874 -- 00:10:14,879
potentially the best concept of this is 2,700 years old.
00:10:15,580 -- 00:10:19,617
Socrates said the first principle would be to do no harm,
00:10:19,617 -- 00:10:23,288
and that is potentially the most important thing that
00:10:23,288 -- 00:10:24,856
all of us have to address, and particularly
00:10:24,856 -- 00:10:26,858
a regulator has to address
00:10:26,858 -- 00:10:31,596
is mistakes can be made, markets can change.
00:10:31,596 -- 00:10:34,098
People make,
00:10:34,098 -- 00:10:35,466
people have bad judgment
00:10:35,466 -- 00:10:36,501
sometimes about what
00:10:36,501 -- 00:10:38,836
particular product or what particular term.
00:10:38,836 -- 00:10:41,906
But the most important element
00:10:41,906 -- 00:10:44,042
when dealing with a consumer,
00:10:44,042 -- 00:10:45,343
some of them are very sophisticated
00:10:45,343 -- 00:10:47,312
and some of them are very unsophisticated.
00:10:47,312 -- 00:10:50,648
So the most important element is do no harm
00:10:50,648 -- 00:10:52,717
come from a place
00:10:52,717 -- 00:10:55,386
where you want to do the best for the consumer,
00:10:55,386 -- 00:11:00,692
and then we have to find the people who want to do harm,
00:11:00,858 -- 00:11:02,694
and we have to get them out of the business.
00:11:03,795 -- 00:11:08,199
So just to follow up on that, Ron, with you, because,
00:11:08,199 -- 00:11:10,668
you know, I think as the panelists have already noted,
00:11:10,668 -- 00:11:12,470
the margin for error
00:11:12,470 -- 00:11:16,374
now, given the economic fundamentals have changed,
00:11:16,374 -- 00:11:17,942
is much narrower.
00:11:17,942 -- 00:11:22,947
So previous to this, in a in a hot market, you know,
00:11:23,114 -- 00:11:24,749
people could be putting
00:11:24,749 -- 00:11:26,617
consumers into mortgages
00:11:26,617 -- 00:11:28,820
and they had lots of room to maneuver.
00:11:28,820 -- 00:11:30,188
Interest rates were low.
00:11:30,188 -- 00:11:31,923
But now with interest rates being so high,
00:11:31,923 -- 00:11:34,425
it's very hard to qualify for a mortgage.
00:11:34,425 -- 00:11:36,627
Some people are getting into mortgages
00:11:36,627 -- 00:11:39,130
that are very unusual, like private mortgages
00:11:39,130 -- 00:11:42,934
that have unusual terms that consumers are not used to.
00:11:42,934 -- 00:11:44,969
What kind of methods do you use
00:11:44,969 -- 00:11:50,074
in your brokerage to communicate your conduct expectations,
00:11:50,508 -- 00:11:52,810
especially when it comes to new agents.
00:11:52,810 -- 00:11:55,446
So these are new agents that are just out there starting
00:11:55,446 -- 00:11:56,247
to operate.
00:11:57,281 -- 00:12:00,051
And, you know, it's much easier these days
00:12:00,051 -- 00:12:01,719
to put someone in a mortgage product
00:12:01,719 -- 00:12:03,054
that's not going to work for them
00:12:03,054 -- 00:12:05,690
if you don't collect enough information.
00:12:05,690 -- 00:12:07,458
And if you don't have those, you know,
00:12:07,458 -- 00:12:10,328
very in-depth conversations with your clients.
00:12:10,328 -- 00:12:13,631
So what kind of methods do you use with new agents
00:12:13,631 -- 00:12:14,398
when you hire them
00:12:14,398 -- 00:12:16,400
to make sure that they're living up
00:12:16,400 -- 00:12:19,503
to the expectations that you have for your brand?
00:12:19,503 -- 00:12:22,306
Well, sometimes the best thing to do is just say no.
00:12:22,306 -- 00:12:25,910
It's in all parts of life.
00:12:25,910 -- 00:12:28,446
That brings to mind,
00:12:28,446 -- 00:12:31,115
something we're seeing on social media right now
00:12:31,115 -- 00:12:36,120
where, agents, mortgage agents are promoting the idea of,
00:12:36,420 -- 00:12:42,026
$1.7 million property purchase where you only put 5% down
00:12:42,460 -- 00:12:45,997
because it's fractional ownership with other parties,
00:12:45,997 -- 00:12:47,565
which will, without doubt,
00:12:47,565 -- 00:12:49,100
have a horrible result eventually.
00:12:50,201 -- 00:12:51,669
But yet it's out there.
00:12:51,669 -- 00:12:56,407
So the most important thing you can tell people again is
00:12:56,407 -- 00:12:58,609
just don't do stupidity.
00:12:58,609 -- 00:13:00,845
You know, when Google started
00:13:00,845 -- 00:13:03,180
there, they've changed it drastically since.
00:13:03,180 -- 00:13:08,018
But when Google started, their mantra was don't do evil.
00:13:08,018 -- 00:13:11,489
Now they swapped out to, you know, destroy the world
00:13:11,489 -- 00:13:13,657
really quickly after that. But that was how it started.
00:13:13,657 -- 00:13:15,459
So don't do evil.
00:13:15,459 -- 00:13:16,660
And, you know,
00:13:16,660 -- 00:13:18,662
if you just as a
00:13:18,662 -- 00:13:19,764
as a leader in your business,
00:13:19,764 -- 00:13:23,334
if you just take the position that we don't tolerate this,
00:13:23,334 -- 00:13:25,269
we won't accept it.
00:13:25,269 -- 00:13:26,837
It's a nonstarter.
00:13:26,837 -- 00:13:30,107
And if we catch you, we get rid of you.
00:13:30,107 -- 00:13:33,410
is probably the best operating guidelines.
00:13:33,410 -- 00:13:36,280
Sadiq, do you have anything to add to what Ron said?
00:13:36,280 -- 00:13:37,581
Well, I totally agree, right?
00:13:37,581 -- 00:13:38,649
I mean, if
00:13:38,649 -- 00:13:40,050
if you're doing the wrong things,
00:13:40,050 -- 00:13:41,318
you need to be booted out, right?
00:13:41,318 -- 00:13:43,354
That's in our brokerage.
00:13:43,354 -- 00:13:46,690
Like, our protocols are very, very tight.
00:13:46,690 -- 00:13:49,493
Not a single commitment or,
00:13:49,493 -- 00:13:50,794
document goes in front of a client
00:13:50,794 -- 00:13:52,229
unless I've reviewed it myself.
00:13:53,497 -- 00:13:56,667
I, we look for, you know, of the suitability.
00:13:56,667 -- 00:13:57,701
We look for the reasonability,
00:13:57,701 -- 00:14:00,704
we look for the proper disclosures.
00:14:00,704 -- 00:14:03,040
And every agent is trained that way.
00:14:03,040 -- 00:14:04,608
And in fact,
00:14:04,608 -- 00:14:06,176
when I say tight protocols
00:14:06,176 -- 00:14:09,813
until I am fully confident that you understand
00:14:09,813 -- 00:14:11,582
every single aspect of your role
00:14:11,582 -- 00:14:13,083
as a mortgage agent or broker
00:14:13,083 -- 00:14:16,687
in how to explain to a customer
00:14:16,687 -- 00:14:20,057
the risks involved and all the steps,
00:14:20,057 -- 00:14:22,593
that they need to take for their mortgage.
00:14:22,593 -- 00:14:25,029
You cannot submit a deal without my review,
00:14:25,029 -- 00:14:27,231
so they literally don't have the access to it.
00:14:27,231 -- 00:14:30,167
And I think that's what kind of keeps, you know, agents,
00:14:30,167 -- 00:14:31,602
you know, an agent coming into a brokerage,
00:14:31,602 -- 00:14:33,003
he will hate that.
00:14:33,003 -- 00:14:33,671
Absolutely.
00:14:33,671 -- 00:14:35,739
I know why,
00:14:35,739 -- 00:14:37,041
you know, somebody restricting your ability
00:14:37,041 -- 00:14:39,510
to do business like that with the way you want to.
00:14:39,510 -- 00:14:40,411
But at the end of the day,
00:14:40,411 -- 00:14:44,948
you know, it's a brand that I and my team have built.
00:14:44,948 -- 00:14:46,550
We're not going to risk that over
00:14:46,550 -- 00:14:47,651
somebody being,
00:14:47,651 -- 00:14:48,485
you know,
00:14:48,485 -- 00:14:50,220
treating mortgages like the Wild West
00:14:50,220 -- 00:14:51,822
and doing whatever they want.
00:14:51,822 -- 00:14:53,057
Maybe not the Wild, Wild West.
00:14:53,057 -- 00:14:54,324
It's still a little bit Wild West, right?
00:14:54,324 -- 00:14:56,727
But, we want to make sure that, you know,
00:14:56,727 -- 00:14:58,796
customers are protected. And as Ron said, you know,
00:15:00,130 -- 00:15:01,832
it is that do no harm.
00:15:01,832 -- 00:15:04,034
And the best way to insure that is
00:15:04,034 -- 00:15:07,071
you have to, supervise, you have to monitor.
00:15:07,071 -- 00:15:09,039
Which brings me to the challenge
00:15:09,039 -- 00:15:11,075
of what happens in larger brokerages.
00:15:11,075 -- 00:15:13,477
And if I can maybe ask Dong to put his principal
00:15:13,477 -- 00:15:17,881
broker hat on from his previous brokerage.
00:15:17,881 -- 00:15:18,415
You know, what did,
00:15:18,415 -- 00:15:20,951
what were some of the techniques that you use
00:15:20,951 -- 00:15:23,954
to handle misconduct and discipline in an environment
00:15:23,954 -- 00:15:26,857
where you have a lot of moving parts?
00:15:26,857 -- 00:15:27,491
I always said,
00:15:27,491 -- 00:15:28,792
you know, brokers are motivated
00:15:28,792 -- 00:15:32,329
by two things either fear or greed.
00:15:32,329 -- 00:15:37,334
As a principal broker and one that holds a compliance hat,
00:15:37,501 -- 00:15:42,339
fear was oftentimes what we use as a means of trying to
00:15:42,339 -- 00:15:45,776
direct agents in a, in a path of conduct culture.
00:15:45,776 -- 00:15:47,678
So, you know,
00:15:47,678 -- 00:15:48,045
it's funny
00:15:48,045 -- 00:15:49,980
because when something bad happens, people
00:15:49,980 -- 00:15:51,515
get into this, this mode of
00:15:51,515 -- 00:15:53,617
of hiding and not sharing
00:15:53,617 -- 00:15:57,487
where we actually had the absolute opposite effect,
00:15:57,487 -- 00:15:58,922
where when something didn't go
00:15:58,922 -- 00:16:00,190
right that we were supposed to,
00:16:00,190 -- 00:16:02,259
we actually cascaded it to
00:16:02,259 -- 00:16:03,260
the entire audience,
00:16:03,260 -- 00:16:04,728
because we want everyone to know
00:16:04,728 -- 00:16:06,763
that this is a consequence for poor behavior.
00:16:06,763 -- 00:16:09,266
So a good example might be,
00:16:09,266 -- 00:16:10,601
we had an agent in Ontario
00:16:10,601 -- 00:16:14,137
do a transaction in New Brunswick where they were’nt licensed.
00:16:14,137 -- 00:16:17,708
So I got a letter from the regulator from New Brunswick
00:16:17,708 -- 00:16:18,475
letting them know that
00:16:18,475 -- 00:16:20,611
if this happens again, the fine would be
00:16:20,611 -- 00:16:22,145
I think it was a half $1 million and,
00:16:22,145 -- 00:16:23,313
you know, another ten grand
00:16:23,313 -- 00:16:25,315
for the agent that was involved.
00:16:25,315 -- 00:16:26,616
And I had no problem sharing that
00:16:26,616 -- 00:16:28,919
with all of our broker owners
00:16:28,919 -- 00:16:31,221
and agents, because to me,
00:16:31,221 -- 00:16:33,824
I get how hard it is to be a principal broker.
00:16:33,824 -- 00:16:36,460
I understand that you've got competing interests.
00:16:36,460 -- 00:16:37,060
I get that,
00:16:37,060 -- 00:16:38,528
you know, you have agents that are
00:16:38,528 -- 00:16:41,098
that are motivated and sometimes very difficult to manage
00:16:41,098 -- 00:16:44,134
because they're only focused on getting transactions done.
00:16:44,134 -- 00:16:46,303
And interprovincial transactions are one of those ones
00:16:46,303 -- 00:16:48,438
where like, what harm am I doing?
00:16:48,438 -- 00:16:50,140
And to me it's giving,
00:16:50,140 -- 00:16:51,975
you know, equipping our principal brokers
00:16:51,975 -- 00:16:55,312
with the information and case studies to be able to make
00:16:55,312 -- 00:16:56,880
it have those difficult conversations.
00:16:56,880 -- 00:16:58,348
So I had no problem,
00:16:58,348 -- 00:17:01,418
you know, someone using me as a litmus test of here's
00:17:01,418 -- 00:17:04,654
what happens, for the sake of, of doing those things.
00:17:04,654 -- 00:17:07,090
And the other thing we do is we have no problem,
00:17:08,325 -- 00:17:11,361
when we have an agent that that did something wrong to,
00:17:11,361 -- 00:17:15,765
in some cases, hang them from the, the square of the town
00:17:15,765 -- 00:17:16,766
to let everybody know
00:17:16,766 -- 00:17:19,636
this is what happens when you do wrong. Right.
00:17:19,636 -- 00:17:21,571
And having a relationship with the regulators,
00:17:21,571 -- 00:17:23,140
I think is also critically important,
00:17:23,140 -- 00:17:25,208
because I think when you become large
00:17:25,208 -- 00:17:28,778
and you have so many agents, it's
00:17:28,778 -- 00:17:30,213
like, I think it's easy to
00:17:30,213 -- 00:17:32,382
to point out the one wrong person.
00:17:32,382 -- 00:17:33,617
But the simple reality is
00:17:33,617 -- 00:17:35,285
I think we've got a lot of really great agents
00:17:35,285 -- 00:17:37,020
and a few bad apples.
00:17:37,020 -- 00:17:39,389
and the best thing we can do is, is do the best
00:17:39,389 -- 00:17:42,392
we can to weed those bad apples out,
00:17:42,392 -- 00:17:44,227
and, and work from that perspective.
00:17:44,227 -- 00:17:44,828
And I think, listen,
00:17:44,828 -- 00:17:46,696
I think as an industry,
00:17:46,696 -- 00:17:48,465
we're doing better with things like technology.
00:17:49,532 -- 00:17:50,667
And I think if
00:17:50,667 -- 00:17:51,368
somebody wants
00:17:51,368 -- 00:17:53,770
to behave poorly in this industry,
00:17:53,770 -- 00:17:54,704
then they're going to typically
00:17:54,704 -- 00:17:57,340
go to a place where there's less technology,
00:17:57,340 -- 00:17:58,508
as opposed to more technology,
00:17:58,508 -- 00:18:00,977
because if you have the document portal
00:18:00,977 -- 00:18:02,345
where you're getting documents directly
00:18:02,345 -- 00:18:03,613
from the customer into your portal,
00:18:03,613 -- 00:18:06,116
you know exactly where that document came from.
00:18:06,116 -- 00:18:07,884
There's no
00:18:07,884 -- 00:18:09,219
nefarious acts happening,
00:18:09,219 -- 00:18:11,454
which becomes a little bit more tougher to do.
00:18:11,454 -- 00:18:12,856
So I think a lot of these things
00:18:12,856 -- 00:18:15,392
are working in our favor to make us a better industry.
00:18:15,392 -- 00:18:18,428
But as an as an industry as a whole in large brokerages,
00:18:18,428 -- 00:18:20,397
I think that's what we're doing to make things better.
00:18:20,397 -- 00:18:23,633
Couldn't the people from New Brunswick fly to Ontario
00:18:23,633 -- 00:18:25,435
and then say they met you in your office?
00:18:26,569 -- 00:18:27,070
I'm kidding, I.
00:18:27,070 -- 00:18:31,975
Tried that, they didn't buy it.
00:18:31,975 -- 00:18:33,877
which brings me to ask Ron,
00:18:33,877 -- 00:18:34,911
because I think you know that
00:18:34,911 -- 00:18:38,148
Ron doesn't put up with guff from what you've heard of Ron.
00:18:38,148 -- 00:18:40,950
So I'd be interested, Ron, to hear,
00:18:40,950 -- 00:18:44,821
if your experience is similar to what Don's articulated,
00:18:44,821 -- 00:18:46,856
how did you deal with,
00:18:46,856 -- 00:18:48,491
issues of misconduct and discipline
00:18:48,491 -- 00:18:50,260
in your own brokerage?
00:18:50,260 -- 00:18:51,661
Well, in a brokerage it operates
00:18:51,661 -- 00:18:52,562
a salary model,
00:18:52,562 -- 00:18:53,563
which is not,
00:18:53,563 -- 00:18:55,999
you know, very, very prevalent in Ontario or any place else,
00:18:55,999 -- 00:18:57,967
but in a brokerage with a salary model,
00:18:57,967 -- 00:18:59,536
people just have no choice
00:18:59,536 -- 00:19:01,237
but to do exactly what they're told to do.
00:19:01,237 -- 00:19:04,240
And so you set standards and that's how it works.
00:19:04,240 -- 00:19:07,076
we use to have a few outside agents and, you know,
00:19:08,144 -- 00:19:10,380
to, to Dong and
00:19:10,380 -- 00:19:13,449
everybody else's point, you just have to,
00:19:13,449 -- 00:19:15,652
particularly when they're new,
00:19:15,652 -- 00:19:17,220
you have to analyze the hell
00:19:17,220 -- 00:19:19,289
out of the compliance documents.
00:19:19,289 -- 00:19:22,225
You have to decide whether something's going on there
00:19:22,225 -- 00:19:25,495
that doesn't seem normal, that doesn't seem
00:19:25,495 -- 00:19:27,964
common and take more steps.
00:19:27,964 -- 00:19:30,967
I mean, that's always at the end of the day.
00:19:30,967 -- 00:19:32,569
I don't know if I'm going to look at every file
00:19:32,569 -- 00:19:34,337
before it goes to the lender stick.
00:19:34,337 -- 00:19:37,440
But, just maybe a few to many.
00:19:37,440 -- 00:19:42,478
but the, but the reality is that if you look at
00:19:42,478 -- 00:19:43,813
your compliance documents
00:19:43,813 -- 00:19:45,248
from a holistic point of view,
00:19:45,248 -- 00:19:48,284
you will often find stuff that makes no sense at all.
00:19:48,284 -- 00:19:50,954
And if you're well trained,
00:19:50,954 -- 00:19:53,056
you have a solid compliance group.
00:19:53,056 -- 00:19:54,390
They will say, well, wait a minute.
00:19:54,390 -- 00:19:57,026
Why would, it looks like a normal file?
00:19:57,026 -- 00:19:59,362
Why is there a B lender? Why is it a private mortgage?
00:19:59,362 -- 00:20:01,998
I mean, let's dig in. Let's dig in deeper.
00:20:01,998 -- 00:20:04,233
And as long as you have that in your compliance group,
00:20:04,233 -- 00:20:07,270
you'll discover some things, you will.
00:20:07,270 -- 00:20:09,105
So I think that raises a good point,
00:20:09,105 -- 00:20:11,207
because I think, you know, what we run into is, is
00:20:11,207 -- 00:20:12,408
sometimes a little bit of information
00:20:12,408 -- 00:20:13,943
can be very dangerous.
00:20:13,943 -- 00:20:16,679
And, Nick and I were having a conversation over lunch
00:20:16,679 -- 00:20:19,082
and we were talking about, you know, mix,
00:20:19,082 -- 00:20:21,351
and some of them have never done a foreclosure
00:20:21,351 -- 00:20:22,785
before or understand
00:20:22,785 -- 00:20:24,887
how to take somebody through a legal proceedings.
00:20:24,887 -- 00:20:26,456
I think there's a lot of brokers out there
00:20:26,456 -- 00:20:29,058
that have never really done a private mortgage
00:20:29,058 -- 00:20:32,228
or a B transaction to really understand the problems with it.
00:20:32,228 -- 00:20:33,429
And I think that's,
00:20:33,429 -- 00:20:33,629
you know,
00:20:33,629 -- 00:20:34,597
I applaud FSRA
00:20:34,597 -- 00:20:36,032
for taking that first step forward
00:20:36,032 -- 00:20:37,934
of creating a licensing class
00:20:37,934 -- 00:20:40,236
so that you're getting a little bit more information.
00:20:40,236 -- 00:20:44,140
The challenge is, is when house prices are going up,
00:20:44,140 -- 00:20:45,274
everybody look like a hero.
00:20:45,274 -- 00:20:47,477
Everybody looked like they knew exactly what they're doing.
00:20:47,477 -- 00:20:50,179
Make wonderful underwriting decisions.
00:20:50,179 -- 00:20:52,482
And when, you know, property prices dropped
00:20:52,482 -- 00:20:54,550
and things happen all of a sudden, you know,
00:20:54,550 -- 00:20:57,220
as one presenter said, you know, when the
00:20:57,220 -- 00:20:59,856
when the tide goes out, you can see who's swimming naked.
00:20:59,856 -- 00:21:00,790
And there's a lot of people
00:21:00,790 -- 00:21:03,226
swimming naked in this, in this industry.
00:21:03,226 -- 00:21:04,527
And I think, you know,
00:21:04,527 -- 00:21:06,162
we have to work harder as an industry
00:21:06,162 -- 00:21:08,197
to just clean everything up.
00:21:08,197 -- 00:21:09,098
And I think we're getting there,
00:21:09,098 -- 00:21:12,168
but it's going to take time. That's a horrible visual.
00:21:14,036 -- 00:21:15,771
Really tough.
00:21:15,771 -- 00:21:18,307
I also I just wanted to add into that.
00:21:18,307 -- 00:21:21,878
Yes, it is a horrible visual. I closed my eyes by the way.
00:21:21,878 -- 00:21:22,678
You know.
00:21:22,678 -- 00:21:25,748
We talk a lot about educating,
00:21:25,748 -- 00:21:29,919
our agents and our brokers, training them,
00:21:29,919 -- 00:21:34,690
Premiere Mortgage Centre is a very large brokerage.
00:21:34,690 -- 00:21:35,558
More than over
00:21:35,558 -- 00:21:38,227
170 agents and brokers across five provinces.
00:21:38,227 -- 00:21:40,830
But we're just speaking to Ontario right now
00:21:40,830 -- 00:21:45,101
where there's a little over 90 agents and brokers.
00:21:45,101 -- 00:21:46,636
We've spent a lot of time
00:21:46,636 -- 00:21:49,272
not only training the agents and the brokers,
00:21:49,272 -- 00:21:52,375
but training the operational leadership as well.
00:21:52,375 -- 00:21:57,079
So when you speak about having locked in compliance
00:21:57,079 -- 00:21:59,148
procedures and policies,
00:21:59,148 -- 00:22:01,617
you know, our individual staff
00:22:01,617 -- 00:22:03,085
that work in those departments,
00:22:03,085 -- 00:22:05,154
we're training them at all times as well.
00:22:05,154 -- 00:22:06,522
And many of them,
00:22:06,522 -- 00:22:07,023
you know,
00:22:07,023 -- 00:22:09,825
one in particular came from a real estate background, but,
00:22:09,825 -- 00:22:12,428
you know, now probably knows more about mortgage brokering
00:22:12,428 -- 00:22:14,764
than she ever thought that she would have. Right.
00:22:14,764 -- 00:22:17,533
But by training them and giving them
00:22:17,533 -- 00:22:18,701
the confidence
00:22:18,701 -- 00:22:21,270
and the information that they need to do their job
00:22:21,270 -- 00:22:21,937
well, right.
00:22:21,937 -- 00:22:23,539
Because their salary drawn, right,
00:22:23,539 -- 00:22:24,407
they have no choice
00:22:24,407 -- 00:22:27,309
but to do what Kerri has told them to do.
00:22:27,309 -- 00:22:32,548
They are in fact, you know, educated enough to really find
00:22:32,548 -- 00:22:33,849
some of those,
00:22:33,849 -- 00:22:36,252
you know, little pieces that we would be looking for
00:22:36,252 -- 00:22:38,621
that would send us searching for some answers
00:22:38,621 -- 00:22:42,124
as to why certain decisions were made in those files. Yeah.
00:22:43,759 -- 00:22:45,694
So we've spent some time talking
00:22:45,694 -- 00:22:48,631
about the principal broker perspective.
00:22:48,631 -- 00:22:49,398
At this point.
00:22:49,398 -- 00:22:50,800
It would be interesting to hear
00:22:50,800 -- 00:22:52,902
from Antoinette in terms of the things
00:22:52,902 -- 00:22:56,472
that keep us the regulator up at night.
00:22:56,472 -- 00:23:00,009
What are the things that that at the present time
00:23:00,009 -- 00:23:04,547
we're most worried about? I have the answer already, but,
00:23:04,547 -- 00:23:06,882
and why is, strong conduct,
00:23:06,882 -- 00:23:09,351
culture and effective principal broker
00:23:09,351 -- 00:23:12,288
supervision so important at this particular time?
00:23:12,288 -- 00:23:13,289
Antoinette.
00:23:13,289 -- 00:23:15,624
Yeah. So there's a few things that we are worried about.
00:23:15,624 -- 00:23:16,959
And I think we talked about it.
00:23:16,959 -- 00:23:20,796
One is really about proficiency of the sector. Right.
00:23:20,796 -- 00:23:24,700
You know, in the last five years the sector has grown 20%.
00:23:24,700 -- 00:23:28,304
So we have 20% more licensed individuals.
00:23:28,304 -- 00:23:30,739
But the number of firms stay the same.
00:23:30,739 -- 00:23:32,608
So obviously, from our perspective
00:23:32,608 -- 00:23:35,377
is, many of those entering
00:23:35,377 -- 00:23:39,815
this sector, might not have experienced a market downturn.
00:23:39,815 -- 00:23:41,717
So are these individuals,
00:23:41,717 -- 00:23:43,185
proficient enough to be able
00:23:43,185 -- 00:23:45,487
to give that suitable mortgage advice?
00:23:45,487 -- 00:23:48,023
The other thing that we're also noticing
00:23:48,023 -- 00:23:51,093
is that consumer expectation has gone up.
00:23:51,093 -- 00:23:53,963
the reason why they use a mortgage broker
00:23:53,963 -- 00:23:55,664
is because they need assistance.
00:23:55,664 -- 00:23:57,633
They need help. They need that advice.
00:23:57,633 -- 00:24:02,438
And when you couple a market downturn uncertainty
00:24:02,438 -- 00:24:05,574
with higher consumer expectation,
00:24:05,574 -- 00:24:08,043
it just makes the work of the sector
00:24:08,043 -- 00:24:09,678
so much more important. Right.
00:24:09,678 -- 00:24:12,014
So you need to be more diligent.
00:24:12,014 -- 00:24:13,782
You need to be,
00:24:13,782 -- 00:24:15,217
you really need to up your game
00:24:15,217 -- 00:24:19,388
to make sure that you understand a client situation.
00:24:19,388 -- 00:24:21,790
I think a lot of us, we're all human.
00:24:21,790 -- 00:24:25,327
We like to think we're in a better situation than we are.
00:24:25,327 -- 00:24:28,363
And when you have that expectation gap,
00:24:28,363 -- 00:24:33,235
that's when you know, as a broker, your job is harder.
00:24:33,235 -- 00:24:36,305
We do think that because of this environment,
00:24:36,305 -- 00:24:39,007
the risk of unsuitable mortgage advice
00:24:39,007 -- 00:24:42,544
and the risk that a client don't quite understand
00:24:42,544 -- 00:24:45,447
what is being offered to them is going to go up.
00:24:45,447 -- 00:24:48,784
So obviously, we are going to be very focused on,
00:24:48,784 -- 00:24:50,018
you know, suitability,
00:24:50,018 -- 00:24:51,353
on what you're explaining,
00:24:51,353 -- 00:24:53,589
what is being explained to consumers.
00:24:53,589 -- 00:24:55,624
And why a brokerage
00:24:55,624 -- 00:24:57,593
and a principal broker is so important
00:24:57,593 -- 00:24:59,194
in this environment is that,
00:25:00,529 -- 00:25:02,431
you are a senior person
00:25:02,431 -- 00:25:05,033
within your organization, even if you're like
00:25:05,033 -- 00:25:08,136
sometimes you're the owner, you set the direction.
00:25:08,136 -- 00:25:10,939
And we've all heard that, you know, culture of a firm
00:25:10,939 -- 00:25:14,710
is always starts from the top.
00:25:14,710 -- 00:25:16,078
From our perspective,
00:25:16,078 -- 00:25:16,945
if you know,
00:25:16,945 -- 00:25:18,981
if a principal broker is able
00:25:18,981 -- 00:25:23,318
to set that high standard of conduct and behavior,
00:25:23,318 -- 00:25:25,020
it makes our job easier.
00:25:25,020 -- 00:25:26,622
I mean, like any regulators,
00:25:26,622 -- 00:25:28,357
we don't have unlimited resources.
00:25:28,357 -- 00:25:32,060
We got to be able to focus our limited resources
00:25:32,060 -- 00:25:33,629
on the bad actors.
00:25:33,629 -- 00:25:35,597
So to the extent that,
00:25:35,597 -- 00:25:38,100
we are seeing principal brokers,
00:25:38,100 -- 00:25:39,668
you know, doing what they can,
00:25:39,668 -- 00:25:41,903
taking reasonable steps to,
00:25:41,903 -- 00:25:43,605
set high standards of conduct
00:25:43,605 -- 00:25:45,507
and doing proper supervision,
00:25:45,507 -- 00:25:49,878
then we can divert our resources to the bad actors.
00:25:49,878 -- 00:25:52,180
We use the word conduct culture a lot.
00:25:52,180 -- 00:25:54,282
And I know this is a term that,
00:25:54,282 -- 00:25:56,952
you start hearing from a lot of regulators
00:25:56,952 -- 00:26:00,088
and if we have to summarize what it means
00:26:00,088 -- 00:26:01,056
for us, it's
00:26:01,056 -- 00:26:06,561
really about having a culture so that your organization,
00:26:06,561 -- 00:26:07,896
the people,
00:26:07,896 -- 00:26:11,032
they are always thinking about the consumer,
00:26:11,032 -- 00:26:13,101
the do no harm concept. Right.
00:26:13,101 -- 00:26:15,971
When you are dealing with consumers, you're
00:26:15,971 -- 00:26:17,539
thinking about what's best for them.
00:26:17,539 -- 00:26:18,740
How do we make sure that
00:26:19,941 -- 00:26:22,110
you are providing the right service?
00:26:22,110 -- 00:26:23,812
So be more proactive
00:26:23,812 -- 00:26:25,180
because
00:26:25,180 -- 00:26:27,382
we will never have the resources
00:26:27,382 -- 00:26:30,051
to be able to check everybody, every transaction.
00:26:30,051 -- 00:26:31,386
And we don't want to do that.
00:26:31,386 -- 00:26:33,622
So we want to be able to leverage,
00:26:33,622 -- 00:26:36,691
principal brokers and senior management of firms
00:26:36,691 -- 00:26:38,693
to be able to do that.
00:26:38,693 -- 00:26:39,995
And so as a follow up,
00:26:39,995 -- 00:26:43,098
I mean, not to try and scare people here or anything,
00:26:43,098 -- 00:26:44,633
I think people know
00:26:44,633 -- 00:26:47,369
kind of the usual basic disciplinary actions
00:26:47,369 -- 00:26:49,671
that can take place for individuals.
00:26:49,671 -- 00:26:50,238
But Antoinette,
00:26:50,238 -- 00:26:52,274
I was wondering if you could maybe
00:26:52,274 -- 00:26:54,809
articulate a bit for, for folks out there,
00:26:54,809 -- 00:26:58,113
what are some of the regulatory consequences
00:26:58,113 -- 00:27:02,284
that can happen for a principal broker and their brokerage
00:27:02,284 -- 00:27:04,319
if they're found, their agents
00:27:04,319 -- 00:27:07,489
and brokers are found to be not dealing with,
00:27:07,489 -- 00:27:09,658
consumers fairly and more importantly,
00:27:09,658 -- 00:27:11,560
breaching the legislation.
00:27:11,560 -- 00:27:14,195
So the first thing we always look at is
00:27:14,195 -- 00:27:15,697
whether the principal broker
00:27:15,697 -- 00:27:17,732
actually have a systematic process
00:27:17,732 -- 00:27:21,937
to monitor the conduct and supervise the agents.
00:27:21,937 -- 00:27:23,805
and some of these could include,
00:27:23,805 -- 00:27:26,574
you know, all the proper training for,
00:27:26,574 -- 00:27:28,910
for the brokers and agents.
00:27:28,910 -- 00:27:33,915
are there process to help you identify potential,
00:27:33,982 -- 00:27:38,019
bad behavior or, quality of service or not there.
00:27:38,019 -- 00:27:40,822
So I like to stress the quality of service
00:27:40,822 -- 00:27:45,627
we do see a lot of firms that have a compliance process,
00:27:45,627 -- 00:27:47,062
but is very checklist based.
00:27:47,062 -- 00:27:49,197
Oh, all these documentation are there,
00:27:49,197 -- 00:27:52,867
but there is little focus on the content,
00:27:52,867 -- 00:27:53,501
like,
00:27:53,501 -- 00:27:55,403
you know, do my brokers and agents
00:27:55,403 -- 00:27:58,073
actually collect the right information?
00:27:58,073 -- 00:28:00,408
Did they make that link from,
00:28:00,408 -- 00:28:00,675
you know,
00:28:00,675 -- 00:28:02,544
the know your client information
00:28:02,544 -- 00:28:06,414
all the way to the final product recommendation?
00:28:06,414 -- 00:28:07,682
So,
00:28:07,682 -- 00:28:08,183
you know,
00:28:08,183 -- 00:28:12,821
we like to emphasize the quality of those process.
00:28:12,821 -- 00:28:15,056
If you can demonstrate as a principal broker,
00:28:15,056 -- 00:28:16,458
you can demonstrate,
00:28:16,458 -- 00:28:18,460
you have that systematic approach
00:28:18,460 -- 00:28:22,263
to monitoring the activities of your brokers and agents.
00:28:22,263 -- 00:28:23,798
You are giving them training.
00:28:23,798 -- 00:28:25,366
If you're identifying issues,
00:28:25,366 -- 00:28:27,635
you are actually dealing with it.
00:28:27,635 -- 00:28:28,536
We're all human.
00:28:28,536 -- 00:28:29,871
So there will be mistake
00:28:29,871 -- 00:28:31,739
and it is okay to make mistake
00:28:31,739 -- 00:28:33,608
as long as you learn from your mistake and then
00:28:34,642 -- 00:28:37,011
you address them.
00:28:37,011 -- 00:28:40,982
So if you can demonstrate that, then that's very helpful.
00:28:40,982 -- 00:28:45,653
Now, if we notice that there is no process
00:28:45,653 -- 00:28:47,388
and your brokers and agents
00:28:47,388 -- 00:28:50,258
are found to be breaching requirements
00:28:50,258 -- 00:28:53,094
or treating consumers unfairly,
00:28:53,094 -- 00:28:56,097
then yes, a principal broker could be liable.
00:28:56,097 -- 00:28:59,734
You know, it could be as simple as
00:28:59,734 -- 00:29:03,104
you are going to see us a lot more often,
00:29:03,104 -- 00:29:07,175
To, you know, license revocation or even,
00:29:07,175 -- 00:29:08,876
you know, conditions on your licensing.
00:29:08,876 -- 00:29:10,478
And sometimes we
00:29:10,478 -- 00:29:15,450
may ban somebody from being a principal broker.
00:29:15,717 -- 00:29:18,186
Good to note.
00:29:18,186 -- 00:29:20,622
But you bring up an interesting topic, Antoinette,
00:29:20,622 -- 00:29:23,858
and I think this came up earlier in the conversation, too.
00:29:23,858 -- 00:29:26,227
FSRA has seen a really rapid growth
00:29:26,227 -- 00:29:27,996
in the number of agents and brokers
00:29:27,996 -- 00:29:32,000
and not the same jump in the number of brokerages.
00:29:32,000 -- 00:29:35,136
So that means that brokerages are getting larger
00:29:35,136 -- 00:29:37,505
and they were getting larger very quickly
00:29:37,505 -- 00:29:39,507
for a certain period of time there.
00:29:39,507 -- 00:29:40,842
So maybe I can ask Kerrie
00:29:40,842 -- 00:29:43,478
because I know you have a pretty big organization.
00:29:43,478 -- 00:29:47,782
How do you meet the challenge of being systematic,
00:29:47,782 -- 00:29:49,884
like Antoinette was talking about making sure
00:29:49,884 -- 00:29:52,453
that there's oversight over your agents and brokers,
00:29:52,453 -- 00:29:57,458
when you have so many additional bodies being onboarded?
00:29:57,525 -- 00:29:59,927
What are some of the techniques that larger
00:29:59,927 -- 00:30:02,530
growing operations can take to make sure
00:30:02,530 -- 00:30:03,998
that they've got their finger on the pulse
00:30:03,998 -- 00:30:06,834
and that they are having those kind of processes
00:30:06,834 -- 00:30:09,704
put in place, like Antoinette just outlined in her remarks.
00:30:12,673 -- 00:30:14,909
We
00:30:14,909 -- 00:30:17,879
start the process of,
00:30:17,879 -- 00:30:18,880
for lack of a better word,
00:30:18,880 -- 00:30:20,648
managing the agents and the brokers
00:30:20,648 -- 00:30:23,618
in their individual businesses from day one.
00:30:23,618 -- 00:30:26,087
So we are in five different provinces.
00:30:26,087 -- 00:30:30,925
We're specifically speaking to Ontario, today, but
00:30:30,925 -- 00:30:32,860
you're right, the growth of agents
00:30:32,860 -- 00:30:35,229
and brokers inside of the brokerage is showing,
00:30:35,229 -- 00:30:37,999
but the number of brokerages remains the same.
00:30:37,999 -- 00:30:41,102
That's interesting to me, but it but it does make sense.
00:30:41,102 -- 00:30:43,571
So how do we manage through,
00:30:43,571 -- 00:30:48,476
making sure that all of these 170 or 90 some-odd Ontario
00:30:48,476 -- 00:30:51,178
businesses are running successfully and are compliant
00:30:51,178 -- 00:30:54,448
and are abiding by the rules
00:30:54,448 -- 00:30:56,317
and regulations within the industry.
00:30:56,317 -- 00:30:57,118
Well,
00:30:57,118 -- 00:30:59,053
we train specifically from day
00:30:59,053 -- 00:31:02,723
one to our policies and procedures manual. Day one.
00:31:02,723 -- 00:31:04,392
We marry that with,
00:31:04,392 -- 00:31:07,094
I would call it our own premiere code of conduct
00:31:07,094 -- 00:31:10,197
and what we would consider,
00:31:10,197 -- 00:31:12,266
you know, what we consider
00:31:12,266 -- 00:31:14,769
to be the standard of excellence for us.
00:31:14,769 -- 00:31:16,470
And we're very well known in the industry for that.
00:31:17,705 -- 00:31:22,710
We take advantage of tools, technology,
00:31:23,844 -- 00:31:26,047
you know, different levels of expertise
00:31:26,047 -- 00:31:27,815
with, with certain agents and brokers
00:31:27,815 -- 00:31:30,284
that are within our industry that are very well known.
00:31:30,284 -- 00:31:34,221
We manage,
00:31:34,221 -- 00:31:35,289
as a principal broker
00:31:35,289 -- 00:31:37,058
and not only manage the agents and brokers,
00:31:37,058 -- 00:31:37,692
but we
00:31:37,692 -- 00:31:41,395
layer in as we grow, we layer in, we have sales leadership,
00:31:41,395 -- 00:31:43,297
we have operational leadership.
00:31:43,297 -- 00:31:46,400
You know, the more, the more hands on deck, the better.
00:31:46,400 -- 00:31:48,969
And to Ron's point, his brokerages,
00:31:48,969 -- 00:31:49,837
you know,
00:31:49,837 -- 00:31:53,007
comprised of many salaried employees,
00:31:53,007 -- 00:31:55,843
these leadership roles are also salaried employees for us.
00:31:55,843 -- 00:31:57,278
So that there's no,
00:31:57,278 -- 00:31:58,345
you know, there
00:31:58,345 -- 00:31:59,680
isn't, you know, a
00:31:59,680 -- 00:32:00,915
lack of balance in terms
00:32:00,915 -- 00:32:03,818
of what we require from them to help us
00:32:03,818 -- 00:32:06,754
make sure that these 170 or 90 some-odd
00:32:06,754 -- 00:32:09,190
Ontario businesses are running effectively
00:32:09,190 -- 00:32:10,458
and efficiently,
00:32:10,458 -- 00:32:12,493
and which then means the brokerages
00:32:12,493 -- 00:32:14,428
is running in the same capacity.
00:32:14,428 -- 00:32:18,699
So, you know, it starts with onboarding.
00:32:18,699 -- 00:32:22,436
You know, our operational staff are using,
00:32:22,436 -- 00:32:25,272
are using management systems and technology
00:32:25,272 -- 00:32:25,906
to make sure
00:32:25,906 -- 00:32:28,509
that every single step that needs to happen
00:32:28,509 -- 00:32:29,577
with an agent or a broker
00:32:29,577 -- 00:32:31,846
when they come into Premiere is happening,
00:32:31,846 -- 00:32:34,782
we make sure that the agents and the brokers know who
00:32:36,150 -- 00:32:36,750
within
00:32:36,750 -- 00:32:38,185
the brokerage
00:32:38,185 -- 00:32:41,855
they can answer to, they can ask questions to,
00:32:41,855 -- 00:32:45,693
you know, it's a collaborative approach.
00:32:45,693 -- 00:32:48,195
It's not something that I can do on my own.
00:32:48,195 -- 00:32:49,797
I'm well aware of that.
00:32:49,797 -- 00:32:51,832
And I would never say that I could. Right.
00:32:51,832 -- 00:32:53,200
It takes a village.
00:32:53,200 -- 00:32:55,869
So as we continued to grow,
00:32:55,869 -- 00:32:58,372
because Premiere Mortgage Centre did start 18 years ago,
00:32:58,372 -- 00:33:00,941
as you know, a handful of people.
00:33:00,941 -- 00:33:01,275
Right.
00:33:01,275 -- 00:33:01,775
And today
00:33:01,775 -- 00:33:07,147
we're 170 strong and 14 staff, full-time staff, right,
00:33:07,147 -- 00:33:08,382
that are helping us manage
00:33:08,382 -- 00:33:11,785
and make sure that each of the agents and the brokers
00:33:11,785 -- 00:33:13,187
and how they're conducting business,
00:33:13,187 -- 00:33:17,391
that their business is strong so that we're strong.
00:33:17,391 -- 00:33:18,292
All right.
00:33:18,292 -- 00:33:21,996
It's funny because I think I always learn from my mistakes.
00:33:21,996 -- 00:33:24,431
And so I remember a few years ago,
00:33:24,431 -- 00:33:27,401
I think I got called 2 or 3 times from FSRA
00:33:27,401 -- 00:33:31,839
about a client complaint, usually private related.
00:33:31,839 -- 00:33:34,908
And they asked me if you could pull the file for me and
00:33:34,908 -- 00:33:35,642
I couldn't find it.
00:33:36,944 -- 00:33:37,378
And it
00:33:37,378 -- 00:33:39,780
so happened that these three different agents
00:33:39,780 -- 00:33:42,850
had done transactions privately, but got paid directly
00:33:42,850 -- 00:33:44,051
and didn't report it.
00:33:44,051 -- 00:33:47,621
So I'm like, man, this is really painful.
00:33:47,621 -- 00:33:50,357
If I get another call from the regulator and they ask me,
00:33:50,357 -- 00:33:51,458
can you look up this file?
00:33:51,458 -- 00:33:53,894
And if I had to say one more time, I did not know about it
00:33:53,894 -- 00:33:57,097
at some point that excuse becomes a little bit muted.
00:33:57,097 -- 00:33:58,232
And then it's like, well,
00:33:58,232 -- 00:33:59,700
where are you actually supervising?
00:33:59,700 -- 00:34:00,567
Like what's going on there?
00:34:00,567 -- 00:34:02,369
So the one thing that we did
00:34:02,369 -- 00:34:04,204
internally is all of us
00:34:04,204 -- 00:34:05,439
as principal brokers has to file
00:34:05,439 -- 00:34:06,807
an annual information return.
00:34:06,807 -- 00:34:08,742
So I said, well, you know what,
00:34:08,742 -- 00:34:10,310
we're going to get all of our agents to file
00:34:10,310 -- 00:34:12,579
annual information returns to the brokerage.
00:34:12,579 -- 00:34:13,714
So we're going to ask questions
00:34:13,714 -- 00:34:15,215
like, were there any transactions
00:34:15,215 -- 00:34:17,351
that you did outside the brokerage where you got paid
00:34:17,351 -- 00:34:19,219
and didn't get paid through the brokerage?
00:34:19,219 -- 00:34:21,588
It's a pretty straightforward question.
00:34:21,588 -- 00:34:22,222
Are you,
00:34:22,222 -- 00:34:24,892
do you have licenses in other disciplines
00:34:24,892 -- 00:34:26,260
that may be a conflict of interest
00:34:26,260 -- 00:34:27,494
to you as a mortgage brokerage?
00:34:27,494 -- 00:34:28,462
Please name them.
00:34:28,462 -- 00:34:30,664
So if I'm an insurance agent, let me know.
00:34:30,664 -- 00:34:33,100
So now I know that I've got a conflict of interest.
00:34:33,100 -- 00:34:36,069
You know, have you seen and read the last policy?
00:34:36,069 -- 00:34:37,738
These are all questions you can ask anything.
00:34:37,738 -- 00:34:39,439
Every brokerage has their own nuances.
00:34:39,439 -- 00:34:41,241
You know, Ron, being mostly
00:34:41,241 -- 00:34:42,809
salary people might be a little bit different.
00:34:42,809 -- 00:34:45,979
But to me that became a very powerful tool
00:34:45,979 -- 00:34:48,115
because all of a sudden, now annually,
00:34:48,115 -- 00:34:49,883
I have to get every single one of my agents
00:34:49,883 -- 00:34:52,119
to be able to answer this question for me.
00:34:52,119 -- 00:34:54,054
And it's so funny because sometimes, like, oh,
00:34:54,054 -- 00:34:55,656
I didn't know that this was a case.
00:34:55,656 -- 00:34:58,925
I'm like, no, it's freaking black and white, man. Let's.
00:34:58,925 -- 00:35:00,994
And then so it draws a conversation
00:35:00,994 -- 00:35:02,763
and a lot of that problem disappears.
00:35:02,763 -- 00:35:04,631
So, you know, if that's one practical
00:35:04,631 -- 00:35:07,100
example of how you, as a principal broker,
00:35:07,100 -- 00:35:08,301
want to run your brokerage
00:35:08,301 -- 00:35:09,870
to help you with those sorts of things.
00:35:09,870 -- 00:35:11,171
I think an annual information return
00:35:11,171 -- 00:35:12,973
no different than the regulator asks of us
00:35:12,973 -- 00:35:14,341
principal brokers
00:35:14,341 -- 00:35:15,676
ask it of your agents,
00:35:15,676 -- 00:35:19,179
and you might be surprised that the response you get back.
00:35:19,179 -- 00:35:20,047
You know, Dong,
00:35:20,047 -- 00:35:22,449
11 people online just said,
00:35:22,449 -- 00:35:24,518
you mean we can get the lawyers to pay us directly?
00:35:24,518 -- 00:35:26,420
Wow, that's a great idea.
00:35:26,420 -- 00:35:27,788
So...
00:35:27,788 -- 00:35:31,525
So you can't always control the way people think.
00:35:31,525 -- 00:35:32,259
I gotta say that.
00:35:33,260 -- 00:35:34,494
Can I just add to that?
00:35:34,494 -- 00:35:36,696
Because I think that is great, right?
00:35:36,696 -- 00:35:37,264
Like from,
00:35:37,264 -- 00:35:38,632
I know a lot of
00:35:38,632 -- 00:35:43,470
we get asked a lot. What are the things that we need to do.
00:35:43,470 -- 00:35:44,971
Can you just give us a checklist.
00:35:44,971 -- 00:35:46,373
And we always said, I,
00:35:46,373 -- 00:35:47,974
we're not giving you a checklist,
00:35:47,974 -- 00:35:51,411
but definitely there's a lot of best practices out there
00:35:51,411 -- 00:35:53,780
like attestation is interesting.
00:35:53,780 -- 00:35:55,115
And then using
00:35:55,115 -- 00:35:56,383
you know, management system
00:35:56,383 -- 00:35:59,553
and technology to help is it's also, you know,
00:35:59,553 -- 00:36:00,654
very powerful.
00:36:00,654 -- 00:36:02,222
We heard this morning about AI
00:36:02,222 -- 00:36:05,625
there's definitely a lot there that we can leverage.
00:36:05,625 -- 00:36:07,460
The one thing that
00:36:07,460 -- 00:36:09,162
that we are deliberate in
00:36:09,162 -- 00:36:11,231
not setting out what to do is
00:36:11,231 -- 00:36:13,700
because every brokerage is different,
00:36:13,700 -- 00:36:15,769
that there are a couple of things that I thought
00:36:15,769 -- 00:36:16,937
I'll put it on the table
00:36:16,937 -- 00:36:17,804
because I,
00:36:17,804 -- 00:36:19,306
I know for other sectors,
00:36:19,306 -- 00:36:20,240
some firms
00:36:20,240 -- 00:36:22,642
like to use consumer reviews
00:36:22,642 -- 00:36:26,346
as a tool to identify other issues
00:36:26,346 -- 00:36:28,248
or other things that we do really good at.
00:36:28,248 -- 00:36:30,917
That's good to emphasize.
00:36:30,917 -- 00:36:32,419
Some other do analyze
00:36:32,419 -- 00:36:33,453
complaints data,
00:36:33,453 -- 00:36:33,753
you know,
00:36:33,753 -- 00:36:37,791
are there other complaints coming from a specific pocket.
00:36:37,791 -- 00:36:38,558
Is that
00:36:38,558 -- 00:36:40,794
is there a systemic issue that we need to think about.
00:36:40,794 -- 00:36:42,696
So there are different ways to do it.
00:36:42,696 -- 00:36:45,832
We recognize that it's not going to be,
00:36:45,832 -- 00:36:50,570
you know, checking every transaction all the time.
00:36:50,570 -- 00:36:52,739
Because it's probably not necessary
00:36:52,739 -- 00:36:55,041
if you have somebody who's very, you know, so
00:36:55,041 -- 00:36:56,710
who has been in the business long time
00:36:56,710 -- 00:37:00,213
and have seen the, the up and down of the sector.
00:37:00,213 -- 00:37:04,351
But for more junior agents, that's probably necessary,
00:37:05,985 -- 00:37:06,953
I think.
00:37:06,953 -- 00:37:08,922
I just wanted to add one more thing in there.
00:37:08,922 -- 00:37:12,225
One of the best practice that we use as we have,
00:37:12,225 -- 00:37:13,393
an agent questionnaire.
00:37:13,393 -- 00:37:15,195
So much like a client
00:37:15,195 -- 00:37:16,629
would,
00:37:16,629 -- 00:37:18,098
would provide information
00:37:18,098 -- 00:37:19,299
to an agent to our broker
00:37:19,299 -- 00:37:21,000
when they're doing an application.
00:37:21,000 -- 00:37:22,836
We require this of our agents
00:37:22,836 -- 00:37:25,538
every year on their licensing renewal.
00:37:25,538 -- 00:37:26,840
So we're looking for them
00:37:26,840 -- 00:37:29,409
to answer questions about themselves,
00:37:29,409 -- 00:37:32,112
their businesses, which is our business,
00:37:32,112 -- 00:37:35,248
although they consider it theirs.
00:37:35,248 -- 00:37:36,883
And the information
00:37:36,883 -- 00:37:37,851
that they provide to us
00:37:37,851 -- 00:37:39,085
is really, really helpful
00:37:39,085 -- 00:37:40,220
and understanding
00:37:40,220 -- 00:37:43,323
where they are in their business or their personal life.
00:37:43,323 -- 00:37:44,124
There are some questions
00:37:44,124 -- 00:37:46,292
that many actually wouldn't want to answer.
00:37:46,292 -- 00:37:47,827
one of them that I specifically ask
00:37:47,827 -- 00:37:49,796
is whether or not they're in good standing with CRA.
00:37:50,997 -- 00:37:54,100
This is important to me as a broker owner.
00:37:54,100 -- 00:37:58,171
Those are issues that can lead to other issues.
00:37:58,171 -- 00:37:59,138
So, you know,
00:37:59,138 -- 00:38:00,874
and if they choose not to answer that question,
00:38:00,874 -- 00:38:03,042
that's a whole other question.
00:38:03,042 -- 00:38:05,678
You know, but again,
00:38:05,678 -- 00:38:08,848
managing as many agents and brokers or supporting,
00:38:08,848 -- 00:38:10,216
let's call it, supporting
00:38:10,216 -- 00:38:14,220
as many agents and brokers in their businesses as, as I do,
00:38:14,220 -- 00:38:15,788
it's really important for me to make sure
00:38:15,788 -- 00:38:17,657
that I know exactly
00:38:17,657 -- 00:38:21,361
who these agents and brokers are as best as I can.
00:38:21,361 -- 00:38:22,595
You know, the CRA question
00:38:22,595 -- 00:38:25,465
would wipe out about five agencies.
00:38:25,465 -- 00:38:27,433
Yes, it would Ron.
00:38:27,433 -- 00:38:29,269
But we all know, we all know what it means
00:38:29,269 -- 00:38:31,671
when an agent or a broker is not in good standing. Right?
00:38:31,671 -- 00:38:33,006
Just as you would ask your client,
00:38:33,006 -- 00:38:35,408
have you paid your taxes, right? Yeah.
00:38:37,310 -- 00:38:38,945
And so improving conduct
00:38:38,945 -- 00:38:41,581
at your brokerage is it takes time. It takes effort.
00:38:41,581 -- 00:38:43,516
And this is a sales business.
00:38:43,516 -- 00:38:46,085
So it takes time away from your employees
00:38:46,085 -- 00:38:48,855
selling to be able to focus on things
00:38:48,855 -- 00:38:52,992
like making sure that they've done the KYC properly, etc.
00:38:52,992 -- 00:38:55,695
So, Sadiq,
00:38:55,695 -- 00:38:58,831
does improving conduct culture in your brokerage?
00:38:58,831 -- 00:39:01,834
Is it divisible from your bottom line,
00:39:01,834 -- 00:39:05,104
or does it support your bottom line? Does it improve
00:39:05,104 -- 00:39:07,707
you know, the reputation of your brokerage?
00:39:07,707 -- 00:39:08,674
Well, you know, strong
00:39:08,674 -- 00:39:10,910
conduct culture definitely improves your reputation.
00:39:10,910 -- 00:39:13,579
The brokerage improves your reputation with your customers
00:39:13,579 -- 00:39:14,914
and with your lenders
00:39:14,914 -- 00:39:17,350
and with your brokerage, your team itself. Right.
00:39:17,350 -- 00:39:18,684
I think, you know,
00:39:18,684 -- 00:39:20,486
people who care about their business,
00:39:20,486 -- 00:39:21,554
care about their reputation,
00:39:21,554 -- 00:39:23,790
want to work with a reputable company.
00:39:23,790 -- 00:39:24,757
Consumers want to deal
00:39:24,757 -- 00:39:26,058
with a reputable company
00:39:26,058 -- 00:39:27,360
and the lenders,
00:39:27,360 -- 00:39:30,429
they want to deal with reputable brokerages and agents.
00:39:30,429 -- 00:39:32,732
You know, I find where it does support is,
00:39:32,732 -- 00:39:35,334
you know, especially with the lender side of things is
00:39:35,334 -- 00:39:37,170
lenders are willing to back you on that deal,
00:39:37,170 -- 00:39:39,939
that they can go either way with it because they know
00:39:39,939 -- 00:39:42,408
your brokerage runs a tight ship.
00:39:42,408 -- 00:39:44,243
You got, you know, strong,
00:39:44,243 -- 00:39:46,045
good quality agents working for you.
00:39:46,045 -- 00:39:48,881
So they'll have your back on a decision to help a client
00:39:48,881 -- 00:39:50,183
where it could have gone the other way.
00:39:51,317 -- 00:39:53,486
Does it necessarily, you know, translate.
00:39:53,486 -- 00:39:55,821
Is it measurable to your bottom line?
00:39:55,821 -- 00:39:56,756
You know, you don't necessarily
00:39:56,756 -- 00:39:58,224
see increased revenue
00:39:58,224 -- 00:40:00,660
by having a stronger conduct culture because,
00:40:00,660 -- 00:40:02,028
as you mentioned,
00:40:02,028 -- 00:40:03,129
it takes away your time,
00:40:03,129 -- 00:40:05,665
as Kerrie mentioned, there’s cost of staffing
00:40:05,665 -- 00:40:06,098
and all that stuff.
00:40:06,098 -- 00:40:07,567
So there's an expense,
00:40:07,567 -- 00:40:08,834
that’s inherently there.
00:40:08,834 -- 00:40:11,971
The stronger you want to build your conduct culture.
00:40:11,971 -- 00:40:14,106
There's processes and technology and all this stuff.
00:40:14,106 -- 00:40:15,508
You have to spend money behind.
00:40:15,508 -- 00:40:18,244
But where it does translate to a stronger bottom line,
00:40:18,244 -- 00:40:19,979
and I think a lot of times we don't recognize it
00:40:19,979 -- 00:40:23,115
because we don't see a revenue coming in,
00:40:23,115 -- 00:40:26,385
is that it protects you from losing the revenue you've made
00:40:26,385 -- 00:40:27,687
because of lawsuits
00:40:27,687 -- 00:40:30,256
and things that you have to now spend money
00:40:30,256 -- 00:40:32,124
on to fix problems
00:40:32,124 -- 00:40:34,260
that you could have avoided in the first place.
00:40:34,260 -- 00:40:35,227
And I look at the way
00:40:35,227 -- 00:40:37,463
I consider a strong conduct
00:40:37,463 -- 00:40:41,033
culture is like an insurance policy on your revenue.
00:40:41,033 -- 00:40:42,668
If you have it in place,
00:40:42,668 -- 00:40:43,636
you're protecting the money
00:40:43,636 -- 00:40:45,271
you did earn as opposed to
00:40:45,271 -- 00:40:47,273
just looking at it as, could I have earned more?
00:40:48,574 -- 00:40:50,843
Does anyone have anything to add to that?
00:40:50,843 -- 00:40:51,577
I would say,
00:40:51,577 -- 00:40:53,079
you know, it's,
00:40:53,079 -- 00:40:54,013
the age old saying,
00:40:54,013 -- 00:40:57,183
if you tell the truth and you don't need a memory, right?
00:40:57,183 -- 00:40:59,852
And, you know, to,
00:40:59,852 -- 00:41:01,587
Antoinette's point,
00:41:01,587 -- 00:41:03,189
if you do what's right for the customer
00:41:03,189 -- 00:41:04,090
because I think that's really
00:41:04,090 -- 00:41:05,224
what conduct culture is, just do
00:41:05,224 -- 00:41:07,059
what's right for the customer.
00:41:07,059 -- 00:41:08,527
Funny, because I went on your website, Ron,
00:41:08,527 -- 00:41:09,528
because I was thinking, well,
00:41:09,528 -- 00:41:10,763
if Ron and I are going to sit together
00:41:10,763 -- 00:41:12,231
and he's going to beat me up about something
00:41:12,231 -- 00:41:14,533
and I'm going to come back and fight him.
00:41:14,533 -- 00:41:16,969
And your Google review ratings are spectacular.
00:41:16,969 -- 00:41:18,337
I think they're 4.8.
00:41:18,337 -- 00:41:19,839
And haven't even started beating you up. Yet.
00:41:19,839 -- 00:41:21,440
Yeah, I know.
00:41:21,440 -- 00:41:22,808
I try to,
00:41:22,808 -- 00:41:24,376
so I'm thinking like
00:41:24,376 -- 00:41:27,513
if you look at Ron's business as an example, you know,
00:41:27,513 -- 00:41:31,083
what more is an example of doing the right thing
00:41:31,083 -- 00:41:34,253
because it resonates in the reviews from your customers.
00:41:34,253 -- 00:41:35,888
Or if you do the right thing for your customers
00:41:35,888 -- 00:41:38,057
and then it finds a way back.
00:41:38,057 -- 00:41:40,159
The problem I do think that is, is
00:41:40,159 -- 00:41:43,028
as much as the people up here on stage and watching
00:41:43,028 -- 00:41:45,598
probably feel the same way that doing the right thing
00:41:45,598 -- 00:41:47,399
and having the right conduct culture
00:41:47,399 -- 00:41:48,667
is good for your business.
00:41:48,667 -- 00:41:51,670
There's also a handful or more people out there
00:41:51,670 -- 00:41:54,106
that don't actually see the correlation.
00:41:54,106 -- 00:41:57,476
That taking that shortcut is better for my bottom line
00:41:57,476 -- 00:42:00,212
than doing the right thing about asking the right questions
00:42:00,212 -- 00:42:03,449
and sometimes saying, no, and they can't say no.
00:42:03,449 -- 00:42:05,918
So, I think, I think that's a challenge.
00:42:05,918 -- 00:42:07,186
I think, you know, as Sadiq said, it's
00:42:07,186 -- 00:42:08,487
not a it's not a direct correlation.
00:42:08,487 -- 00:42:11,190
If it was and we wouldn't have a regulator in the industry
00:42:11,190 -- 00:42:12,358
be really easy to manage.
00:42:12,358 -- 00:42:14,193
But the problem is we've got people out there
00:42:14,193 -- 00:42:16,762
that just don't feel that same way.
00:42:16,762 -- 00:42:18,697
And we got to find a way to root those people out
00:42:18,697 -- 00:42:20,499
and make sure the good people stay.
00:42:20,499 -- 00:42:21,867
Yeah, I'd have to say that
00:42:22,968 -- 00:42:26,038
the key answer to that question is longevity.
00:42:26,038 -- 00:42:30,075
So, I've seen people who've run very bad shops.
00:42:30,075 -- 00:42:31,577
They can't do it forever.
00:42:31,577 -- 00:42:34,747
They have to change or they get removed.
00:42:34,747 -- 00:42:36,015
And it's just as simple as that.
00:42:36,015 -- 00:42:37,783
So if you're planning on running a business
00:42:37,783 -- 00:42:40,386
for a very short time,
00:42:40,386 -- 00:42:41,987
doing bad things is an option.
00:42:41,987 -- 00:42:45,057
But if you want to run a business for a long time,
00:42:45,057 -- 00:42:45,791
sooner or later
00:42:45,791 -- 00:42:46,658
you have to come around
00:42:46,658 -- 00:42:48,160
to doing the right thing for the consumer.
00:42:48,160 -- 00:42:50,396
And that's just the way it is.
00:42:50,396 -- 00:42:52,464
Do you think agents can bounce around
00:42:52,464 -- 00:42:54,433
and stay under the radar?
00:42:54,433 -- 00:42:58,537
Different topic. Sorry.
00:42:58,537 -- 00:42:59,905
Good question.
00:42:59,905 -- 00:43:04,109
So is the approach to this different
00:43:04,109 -- 00:43:06,612
depending on the size of your firm?
00:43:06,612 -- 00:43:08,547
So I know that there's people out there
00:43:08,547 -- 00:43:09,681
that are probably saying, well,
00:43:09,681 -- 00:43:12,084
I know if it's a small firm you've got, you know,
00:43:12,084 -- 00:43:13,418
you know, who's working for you.
00:43:13,418 -- 00:43:14,920
You're probably looking at their
00:43:14,920 -- 00:43:16,622
deals before they get sent,
00:43:17,723 -- 00:43:20,292
but is this kind of an approach scalable
00:43:20,292 -- 00:43:23,328
depending on the size of your brokerage?
00:43:23,328 -- 00:43:26,165
Ron, I'm looking at you for an answer to this.
00:43:26,165 -- 00:43:29,668
You know, the attitude of the management
00:43:29,668 -- 00:43:32,938
is prevalent even at any scale.
00:43:32,938 -- 00:43:34,006
At any scale.
00:43:34,006 -- 00:43:36,642
Now, Kerrie talks about a big operation, people
00:43:36,642 -- 00:43:39,945
all working from their homes or from offices,
00:43:39,945 -- 00:43:43,348
but not in her office, obviously.
00:43:43,348 -- 00:43:47,920
and they understand that it's consequential
00:43:47,920 -- 00:43:50,088
that bad actions are consequential.
00:43:50,088 -- 00:43:51,056
Everybody understands it.
00:43:51,056 -- 00:43:52,958
It doesn't take long.
00:43:52,958 -- 00:43:56,528
Even for newcomers, to understand it's consequential.
00:43:56,528 -- 00:44:00,432
So that's the essence of it all.
00:44:00,432 -- 00:44:05,070
If management cares and management radiates that concept
00:44:05,070 -- 00:44:06,204
that,
00:44:06,204 -- 00:44:10,175
you know, you will get clipped if you do something wrong,
00:44:10,175 -- 00:44:14,413
and we only accept proper behavior
00:44:14,413 -- 00:44:16,648
that is just known.
00:44:16,648 -- 00:44:19,017
And people will leave once they figure it out.
00:44:19,017 -- 00:44:20,786
Oh, well, I can't get away with anything here.
00:44:20,786 -- 00:44:22,387
I got to leave. I got to go.
00:44:22,387 -- 00:44:25,891
And, consequentially, you end up with a pretty good group.
00:44:27,025 -- 00:44:28,927
Does anyone have anything to add to that?
00:44:28,927 -- 00:44:29,227
Maybe
00:44:29,227 -- 00:44:33,098
Kerrie, you have different approaches at your brokerage.
00:44:33,098 -- 00:44:34,733
Ironically, no.
00:44:34,733 -- 00:44:35,867
It's the same approach.
00:44:35,867 -- 00:44:36,201
I think.
00:44:36,201 -- 00:44:38,236
No matter how large the brokerage is,
00:44:38,236 -- 00:44:41,506
you have to have your agents and brokers aligned,
00:44:41,506 -- 00:44:43,375
your leadership have to be aligned.
00:44:43,375 -- 00:44:46,478
Management, leadership, whatever title you're giving them,
00:44:46,478 -- 00:44:47,946
everyone has to be in the alignment.
00:44:47,946 -- 00:44:49,681
We all have to be in the same circle.
00:44:49,681 -- 00:44:51,750
If you want to step outside the circle,
00:44:51,750 -- 00:44:54,219
then the circle's just going to get smaller, right?
00:44:54,219 -- 00:44:57,923
You're just not going to have you as a part of that group.
00:44:57,923 -- 00:44:58,256
Right.
00:44:58,256 -- 00:45:01,626
And we're all consistently walking forward together. Right.
00:45:01,626 -- 00:45:03,195
So it shouldn't matter.
00:45:03,195 -- 00:45:04,095
I know at Premiere
00:45:04,095 -- 00:45:04,896
it shouldn't matter
00:45:04,896 -- 00:45:06,531
if you contact myself,
00:45:06,531 -- 00:45:10,469
you contact my business partner Don, or you contact,
00:45:10,469 -- 00:45:11,536
you know, Michelle Drover,
00:45:11,536 -- 00:45:13,038
who helps me run Atlantic Canada.
00:45:13,038 -- 00:45:17,108
You're going to get the same exact answer to a question.
00:45:17,108 -- 00:45:19,010
And that's really, really important.
00:45:19,010 -- 00:45:24,049
And I've never been afraid to, to communicate or
00:45:24,049 -- 00:45:25,684
to voice that, you know,
00:45:27,352 -- 00:45:27,819
if I have to
00:45:27,819 -- 00:45:29,354
ask you a question, if I'm asking you a question
00:45:29,354 -- 00:45:30,455
and you're not willing to
00:45:30,455 -- 00:45:31,489
to answer that question
00:45:31,489 -- 00:45:33,225
or you're going to become defensive,
00:45:33,225 -- 00:45:35,393
in some investigation or conversation
00:45:35,393 -- 00:45:38,730
that we need to have, right, then you're the issue, not me.
00:45:38,730 -- 00:45:39,064
Right?
00:45:39,064 -- 00:45:41,466
This again, the brokerage itself is a business
00:45:41,466 -- 00:45:42,968
and it's a strong business.
00:45:42,968 -- 00:45:44,069
And without the brokerage,
00:45:44,069 -- 00:45:46,805
the agent, the brokers don't have a business.
00:45:46,805 -- 00:45:48,306
So we all have to work together.
00:45:48,306 -- 00:45:49,341
We all have to be aligned.
00:45:49,341 -- 00:45:50,442
There's no you know,
00:45:50,442 -- 00:45:53,712
I don't think there's outside of the size of
00:45:53,712 -- 00:45:55,447
call it the staff that I would have.
00:45:55,447 -- 00:45:57,849
And yes, I don't have them here in Ontario
00:45:57,849 -- 00:45:58,950
all working together.
00:45:58,950 -- 00:46:00,752
All of our staff are in Atlantic Canada,
00:46:00,752 -- 00:46:02,020
but they're all housed together.
00:46:03,088 -- 00:46:04,089
you know, it's
00:46:04,089 -- 00:46:07,192
we're the same no matter how big or small you are.
00:46:07,192 -- 00:46:08,493
Can I, can I add something?
00:46:08,493 -- 00:46:11,496
Because one of the things that I keep hearing
00:46:11,496 -- 00:46:13,631
is that the good brokerages
00:46:13,631 -- 00:46:15,400
are trying to do the right thing,
00:46:15,400 -- 00:46:16,868
but then agents and brokers
00:46:16,868 -- 00:46:18,970
who realize that, oh, I'm under scrutiny.
00:46:18,970 -- 00:46:23,341
I'm just going to leave and find a brokerage that
00:46:23,341 -- 00:46:26,311
you maybe have easier standard.
00:46:26,311 -- 00:46:26,678
Right?
00:46:26,678 -- 00:46:31,783
So I think as a regulator, you know, our role is really to,
00:46:32,117 -- 00:46:32,717
you know,
00:46:32,717 -- 00:46:35,420
emphasize the importance and hold
00:46:35,420 -- 00:46:37,889
all principal brokers accountable.
00:46:37,889 -- 00:46:40,725
And one of the, and,
00:46:40,725 -- 00:46:41,826
you know, going forward,
00:46:41,826 -- 00:46:43,194
I think a lot of our emphasis
00:46:43,194 -- 00:46:46,464
is going to be on onboarding and retention.
00:46:46,464 -- 00:46:48,500
What are principal brokers doing
00:46:48,500 -- 00:46:52,737
when you are onboarding a new brokerage agent?
00:46:52,737 -- 00:46:55,073
Are you doing due diligence?
00:46:55,073 -- 00:46:58,810
Are you checking their compliance history?
00:46:58,810 -- 00:46:59,878
Are you,
00:46:59,878 -- 00:47:03,181
you know, maybe checking their consumer reviews online?
00:47:03,181 -- 00:47:06,184
What are you doing to get you comfortable
00:47:06,184 -- 00:47:07,819
that somebody who's joining
00:47:07,819 -- 00:47:11,356
your firm is going to be living up to your expectation?
00:47:11,356 -- 00:47:15,627
We know the sector is not mature as other financial sectors.
00:47:16,794 -- 00:47:18,763
So I do have principal
00:47:18,763 -- 00:47:20,965
brokers who have come up to me to say,
00:47:20,965 -- 00:47:22,867
hey, FSRA, you licensed that individual,
00:47:22,867 -- 00:47:24,068
why should I check?
00:47:24,068 -- 00:47:26,070
And my,
00:47:26,070 -- 00:47:28,039
yes, and my comments has always been
00:47:28,039 -- 00:47:30,942
because as your business, it's your reputation.
00:47:30,942 -- 00:47:34,112
So and then the other thing that we are also doing more
00:47:34,112 -- 00:47:35,947
and I want to kind of
00:47:35,947 -- 00:47:40,551
maybe do a little pitches is that a lot of times
00:47:40,551 -- 00:47:45,556
sectors know who are the bad actors.
00:47:45,623 -- 00:47:48,426
Regulators often don't know fast enough.
00:47:48,426 -- 00:47:52,997
And we do have a whistleblower program that,
00:47:52,997 -- 00:47:55,833
if that is allowed, you know,
00:47:55,833 -- 00:47:59,003
people in the sector to report to us,
00:47:59,003 -- 00:48:01,039
and with, with, you know,
00:48:01,039 -- 00:48:03,374
so that we can protect them from consequences.
00:48:03,374 -- 00:48:05,476
So there is, there is different tools
00:48:05,476 -- 00:48:08,379
that we're putting out there to support the sector,
00:48:08,379 -- 00:48:11,416
to let us know if there are misconduct
00:48:11,416 -- 00:48:13,351
because if you give us credible information
00:48:13,351 -- 00:48:15,820
that we can act on, we will look at it seriously.
00:48:17,655 -- 00:48:19,223
Dong, I think you had one more thing.
00:48:19,223 -- 00:48:21,559
Yeah, it was funny because, a couple of years ago,
00:48:21,559 -- 00:48:22,760
I did a survey
00:48:22,760 -- 00:48:25,063
with all the provincial regulators across the country.
00:48:25,063 -- 00:48:25,763
And one of the questions
00:48:25,763 -- 00:48:27,265
I asked, and I asked this question,
00:48:27,265 -- 00:48:29,801
I said, do most of your problems
00:48:29,801 -- 00:48:33,638
happen in small brokerages or big brokerages?
00:48:33,638 -- 00:48:37,075
And and the answer was, the truth is, it's
00:48:37,075 -- 00:48:38,176
it's even across the board
00:48:38,176 -- 00:48:40,711
because if you run a small brokerage,
00:48:40,711 -- 00:48:43,181
you have small brokerage issues, right?
00:48:43,181 -- 00:48:45,683
You've got a principal broker who's doing the payroll
00:48:45,683 -- 00:48:47,018
compliance running, you know,
00:48:47,018 -- 00:48:48,619
running their own transactions,
00:48:48,619 -- 00:48:50,221
trying to grow their business.
00:48:50,221 -- 00:48:52,023
And then you and then you have a situation
00:48:52,023 -- 00:48:53,558
where you have a large brokerage, where you have
00:48:53,558 -- 00:48:55,259
maybe shareholders and,
00:48:55,259 -- 00:49:00,064
and the political issues and undue influence and, you know,
00:49:00,064 -- 00:49:01,232
the bottom line is more important
00:49:01,232 -- 00:49:02,333
than compliance and all sorts.
00:49:02,333 -- 00:49:05,736
So I think every brokerage has its challenges and issues.
00:49:05,736 -- 00:49:06,771
And I think as a regulator,
00:49:06,771 -- 00:49:09,607
it makes it very difficult for these guys, which is
00:49:09,607 -- 00:49:11,342
how do you tailor the
00:49:11,342 -- 00:49:14,579
the regulation to make sure that that you move everybody
00:49:14,579 -- 00:49:18,883
from the continuum along so that we're all behaving well.
00:49:18,883 -- 00:49:19,784
And it's a tough thing, right?
00:49:19,784 -- 00:49:20,251
I think, you know,
00:49:20,251 -- 00:49:22,820
the struggles of a small brokerage is very different
00:49:22,820 -- 00:49:24,422
from a struggles of a large brokerage
00:49:24,422 -- 00:49:25,656
where you have 170 agents.
00:49:26,791 -- 00:49:28,125
Where you have structure in place.
00:49:28,125 -- 00:49:30,061
So it's a really tricky thing.
00:49:30,061 -- 00:49:32,730
So I think, you know, that
00:49:32,730 -- 00:49:36,133
conduct culture, the compliance,
00:49:36,133 -- 00:49:37,768
starting from the beginning becomes really,
00:49:37,768 -- 00:49:39,670
really important because, you know, as
00:49:39,670 -- 00:49:41,606
you know, these things are legacy things.
00:49:41,606 -- 00:49:43,641
And if you have a legacy that starts off
00:49:43,641 -- 00:49:45,276
as being a bit of a shady brokerage,
00:49:45,276 -- 00:49:47,678
then sometimes that's that's hard to shake.
00:49:47,678 -- 00:49:48,813
as you as you grow out,
00:49:48,813 -- 00:49:52,416
so do the right thing from the beginning.
00:49:52,416 -- 00:49:55,886
Great way to end that discussion.
00:49:55,886 -- 00:49:56,887
Thank you, panelists.
00:49:56,887 -- 00:49:58,522
That was a really robust discussion
00:49:58,522 -- 00:50:00,691
on a very important topic.
00:50:00,691 -- 00:50:01,792
At this point,
00:50:01,792 -- 00:50:05,029
we're going to get some questions from the virtual audience
00:50:05,029 -- 00:50:08,399
or even our folks here that are plugged into the app.
00:50:08,399 -- 00:50:11,235
so we will ask you some questions from the audience
00:50:11,235 -- 00:50:13,037
as soon as they pop up on my screen here.
00:50:14,238 -- 00:50:15,339
Screen is white.
00:50:15,339 -- 00:50:17,074
The screen is white.
00:50:17,074 -- 00:50:20,044
Takes a few seconds and you go
00:50:20,044 -- 00:50:22,680
anonymous. Anonymous.
00:50:22,680 -- 00:50:26,817
Here we go. Anonymous. They're scared.
00:50:26,817 -- 00:50:30,554
FSRA, what are the key leadership characteristics
00:50:30,554 -- 00:50:33,324
that a principal, broker, principal, representative
00:50:33,324 -- 00:50:36,327
and leadership should have to support
00:50:36,327 -- 00:50:38,696
a strong conduct culture?
00:50:38,696 -- 00:50:42,700
That is a great question.
00:50:42,700 -- 00:50:45,002
I would say two main things.
00:50:45,002 -- 00:50:47,204
One is integrity.
00:50:47,204 -- 00:50:50,808
I know a lot of people will say, oh, what is integrity?
00:50:50,808 -- 00:50:52,409
Integrity, you know,
00:50:52,409 -- 00:50:54,078
you can really see from
00:50:54,078 -- 00:50:59,517
is that, you know, customer centric and understanding where
00:50:59,517 -- 00:51:00,951
you, as a principal broker
00:51:00,951 -- 00:51:02,920
should be placed in a conflict situation
00:51:02,920 -- 00:51:04,522
and be able to remove yourself.
00:51:04,522 -- 00:51:06,657
So integrity is really important.
00:51:06,657 -- 00:51:11,662
Second thing that we look for is experience and competence.
00:51:12,229 -- 00:51:16,400
We, you know, sometimes the title principal broker
00:51:16,400 -- 00:51:18,602
could seem big, and some,
00:51:18,602 -- 00:51:19,270
younger folks
00:51:19,270 -- 00:51:20,938
may get attached,
00:51:20,938 -- 00:51:22,273
you know, attracted to the title
00:51:22,273 -- 00:51:24,975
and want to be a principal broker.
00:51:24,975 -- 00:51:26,910
But we from our perspective, as you know,
00:51:26,910 -- 00:51:27,645
principal brokers
00:51:27,645 -- 00:51:31,282
do need to have that experience and the competence
00:51:31,282 -- 00:51:33,217
they got to understand,
00:51:33,217 -- 00:51:35,753
the sector, they got to understand the business challenges.
00:51:35,753 -- 00:51:40,324
They got to understand the regulatory requirements.
00:51:40,324 -- 00:51:41,892
They got to understand the customer.
00:51:41,892 -- 00:51:46,797
So, you know, having that competence and having experience,
00:51:48,065 -- 00:51:51,802
will be really important and being,
00:51:51,802 -- 00:51:54,038
I would say, also not having the courage
00:51:54,038 -- 00:51:55,806
to do the right things
00:51:55,806 -- 00:51:57,307
and having the courage to acknowledge
00:51:57,307 -- 00:52:00,711
that or maybe this is a new area I need, I need more,
00:52:00,711 -- 00:52:03,414
I need more education and more information
00:52:03,414 -- 00:52:05,482
and go seek help.
00:52:05,482 -- 00:52:06,750
Do any of the panelists
00:52:06,750 -- 00:52:11,755
have any views on what brokerages need to do to support
00:52:12,089 -- 00:52:13,257
a principal broker
00:52:13,257 -- 00:52:17,394
in making the right decisions and making strong,
00:52:17,394 -- 00:52:19,763
conduct decisions in their day to day
00:52:19,763 -- 00:52:21,698
work, especially if, for example,
00:52:21,698 -- 00:52:24,034
they may not be an owner
00:52:24,034 -- 00:52:27,671
or a partner in the, in the brokerage.
00:52:27,671 -- 00:52:32,009
Well, I would suggest that one thing that no regulator
00:52:32,009 -- 00:52:34,444
and no principal broker,
00:52:34,444 -- 00:52:39,650
no compliance officer can easily manage, is bad intentions.
00:52:40,417 -- 00:52:43,687
People start from a framework of bad intentions
00:52:43,687 -- 00:52:46,690
or become reckless and crazy in their
00:52:46,690 -- 00:52:48,025
approach to the business.
00:52:49,960 -- 00:52:53,230
It only tends to come out later.
00:52:53,230 -- 00:52:54,431
That just means
00:52:54,431 -- 00:52:57,968
that the management of the brokerage has to be vigilant,
00:52:57,968 -- 00:53:01,438
has to care about what they're seeing in social media
00:53:01,438 -- 00:53:03,540
that the agent brokers putting out.
00:53:03,540 -- 00:53:06,076
They have to think about what they're seeing.
00:53:06,076 -- 00:53:08,345
But, you know,
00:53:08,345 -- 00:53:10,614
I'm a guy who actually talks to reporters
00:53:10,614 -- 00:53:11,748
from time to time.
00:53:11,748 -- 00:53:16,753
And the thing that I have to constantly remind them is that
00:53:17,087 -- 00:53:19,556
bad intentions are not something
00:53:19,556 -- 00:53:21,558
a regulator can easily control.
00:53:21,558 -- 00:53:23,994
If somebody sets out to do wrong,
00:53:23,994 -- 00:53:25,562
it's also sometimes the principal broker,
00:53:25,562 -- 00:53:26,830
hopefully it's not the principal broker
00:53:26,830 -- 00:53:31,835
is doing wrong, but, it's, it's not as easy as people think.
00:53:32,202 -- 00:53:33,236
It's hard.
00:53:33,236 -- 00:53:36,440
And it just means that vigilance
00:53:36,440 -- 00:53:38,475
has to be the watchword of what you do.
00:53:38,475 -- 00:53:41,845
Because those who set out to do wrong,
00:53:41,845 -- 00:53:43,980
they'll do some wrong before they finally get caught.
00:53:43,980 -- 00:53:45,649
And that's reality.
00:53:47,584 -- 00:53:48,518
And hopefully someone will
00:53:48,518 -- 00:53:51,455
use the whistleblower provision to report them.
00:53:51,455 -- 00:53:53,957
Just saying.
00:53:53,957 -- 00:53:57,160
Any other questions from the crowd?
00:53:57,160 -- 00:53:58,495
There we go.
00:53:58,495 -- 00:53:59,329
Anonymous.
00:53:59,329 -- 00:54:02,165
It's a question for Antoinette.
00:54:02,165 -- 00:54:03,734
As a financial institution
00:54:03,734 -- 00:54:06,036
that deals with brokers and agents.
00:54:06,036 -- 00:54:06,770
Bad actors
00:54:06,770 -- 00:54:08,505
show up on occasion
00:54:08,505 -- 00:54:10,073
other than internally placing
00:54:10,073 -- 00:54:12,242
these brokers and agents on caution.
00:54:12,242 -- 00:54:16,279
What other recourses do FI’s have on reporting
00:54:16,279 -- 00:54:21,284
improper activity and what is the right course of action?
00:54:23,019 -- 00:54:25,155
So thank you for this question.
00:54:25,155 -- 00:54:26,189
It does
00:54:26,189 -- 00:54:29,726
give me comfort that there seems to be an interest
00:54:29,726 -- 00:54:31,595
in reporting those to us.
00:54:31,595 -- 00:54:32,662
So there are,
00:54:32,662 -- 00:54:34,431
there are right now,
00:54:34,431 -- 00:54:36,099
I would say two main ways
00:54:36,099 -- 00:54:38,902
that this information can be reported to us.
00:54:38,902 -- 00:54:41,004
We just talked about the whistleblower program,
00:54:41,004 -- 00:54:42,439
where you can,
00:54:42,439 -- 00:54:45,108
you know, submit that information through there.
00:54:45,108 -- 00:54:47,210
The other channel is our regular
00:54:47,210 -- 00:54:50,280
complaints channel, where you can, you know,
00:54:50,280 -- 00:54:52,148
send in complaints.
00:54:52,148 -- 00:54:55,051
There will be a form where you can outline,
00:54:55,051 -- 00:54:56,653
you know, what are the observation?
00:54:56,653 -- 00:55:00,290
What are the information you've collected that suggest
00:55:00,290 -- 00:55:02,192
there may be misconduct?
00:55:02,192 -- 00:55:04,661
And that way we will come back to you
00:55:04,661 -- 00:55:06,596
and gather information so that we
00:55:06,596 -- 00:55:08,898
we can get to the bottom of it. Are there misconduct?
00:55:08,898 -- 00:55:09,699
Are there breaches?
00:55:09,699 -- 00:55:12,869
And then we can, we can address them accordingly.
00:55:14,170 -- 00:55:15,939
Good stuff.
00:55:15,939 -- 00:55:20,944
Any other questions?
00:55:22,078 -- 00:55:22,846
Here we go.
00:55:22,846 -- 00:55:23,780
Another anonymous.
00:55:23,780 -- 00:55:27,684
Anonymous is active in this, in this session.
00:55:27,684 -- 00:55:30,887
Have you discovered or used any best practices
00:55:30,887 -- 00:55:34,224
for automating good conduct so using tech.
00:55:34,224 -- 00:55:37,627
Are there easier ways to automate processes
00:55:37,627 -- 00:55:41,331
for your agents and brokers that lead to better outcomes
00:55:41,331 -- 00:55:44,334
and more compliant outcomes?
00:55:44,334 -- 00:55:46,736
So I'll take the first stab at this.
00:55:46,736 -- 00:55:49,372
I think,
00:55:49,372 -- 00:55:54,377
100% using some level of technology makes,
00:55:57,614 -- 00:55:59,949
makes fraud easier and sometimes harder.
00:55:59,949 -- 00:56:01,151
So it's a two pronged approach.
00:56:01,151 -- 00:56:05,422
So the way I say this is, is I mentioned earlier,
00:56:05,422 -- 00:56:07,524
with, with all this advent of technology,
00:56:07,524 -- 00:56:10,560
there are document portals, there is,
00:56:10,560 -- 00:56:11,895
tracking of documentation
00:56:11,895 -- 00:56:15,465
coming from customer directly to the broker.
00:56:15,465 -- 00:56:18,468
The form of those documents coming through are captured.
00:56:18,468 -- 00:56:20,236
You can see what happened to the documentation
00:56:20,236 -- 00:56:21,304
as it came through.
00:56:21,304 -- 00:56:24,808
So if you are interested in being a bad actor,
00:56:24,808 -- 00:56:26,609
then maybe being a part of a brokerage
00:56:26,609 -- 00:56:27,977
that has lots of technology
00:56:27,977 -- 00:56:29,579
becomes a little bit more difficult.
00:56:29,579 -- 00:56:31,147
Or you're gonna have to step up your game
00:56:31,147 -- 00:56:34,784
and play different games to, to game the game.
00:56:34,784 -- 00:56:35,718
There's all sorts of things.
00:56:35,718 -- 00:56:37,053
You know, I remember,
00:56:37,053 -- 00:56:37,687
ten years ago,
00:56:37,687 -- 00:56:40,924
we put a, a mechanism within our, our compliance department
00:56:40,924 -- 00:56:42,091
where we could actually look up,
00:56:43,059 -- 00:56:44,360
employers.
00:56:44,360 -- 00:56:45,261
So I might look
00:56:45,261 -- 00:56:50,600
up Sadiq and I might put in, PetSmart as an employer.
00:56:50,600 -- 00:56:52,769
And if Sadiq, happens to have 4
00:56:52,769 -- 00:56:56,072
or 5 customers with PetSmart as employer,
00:56:56,072 -- 00:56:58,107
that might raise a bit of a red flag to me, that
00:56:58,107 -- 00:57:01,244
maybe some of these employment letters are not legitimate.
00:57:01,244 -- 00:57:02,745
Maybe they're fraudulent.
00:57:02,745 -- 00:57:04,847
Because what is the likelihood that Sadiq’s done
00:57:04,847 -- 00:57:07,717
five transactions for employees of PetSmart?
00:57:07,717 -- 00:57:09,652
So, and then, and then you can look at them and go,
00:57:09,652 -- 00:57:13,523
the job letters are a little bit off.
00:57:13,523 -- 00:57:15,758
And I think with the advent of,
00:57:15,758 -- 00:57:16,959
open banking
00:57:16,959 -- 00:57:19,195
and with better sharing of information
00:57:19,195 -- 00:57:20,596
with CRA and things like that,
00:57:20,596 -- 00:57:21,698
I think we'll get to a place
00:57:21,698 -- 00:57:24,634
where a lot of this becomes a lot more difficult to do.
00:57:25,802 -- 00:57:27,837
But like anything, you know, technology evolve.
00:57:27,837 -- 00:57:30,039
And as much as we're leveraging
00:57:30,039 -- 00:57:32,408
good technology, the bad actors are also leveraging it
00:57:32,408 -- 00:57:33,309
to do what they need to do.
00:57:33,309 -- 00:57:36,279
So I think at the end of the game, it's just a race,
00:57:36,279 -- 00:57:37,647
but I do think the technology,
00:57:37,647 -- 00:57:39,382
it will play a bigger role
00:57:39,382 -- 00:57:41,684
in making sure that we all behave well.
00:57:41,684 -- 00:57:43,419
And if you do choose to play,
00:57:43,419 -- 00:57:45,722
nefariously then you'll go somewhere else to do it.
00:57:45,722 -- 00:57:47,523
Just, you know, they were all family members.
00:57:47,523 -- 00:57:49,425
Yes, of course I know.
00:57:49,425 -- 00:57:52,128
That's why he has his own brokerage now.
00:57:52,128 -- 00:57:53,863
I will say, though, that linkage
00:57:53,863 -- 00:57:55,031
to CRA for income
00:57:55,031 -- 00:58:00,036
verification will put a serious, serious dent
00:58:00,369 -- 00:58:03,473
in any fraudsters ability to do that stuff.
00:58:03,473 -- 00:58:05,374
So that's something we gotta have.
00:58:05,374 -- 00:58:06,442
We just keep pushing for it.
00:58:06,442 -- 00:58:08,744
We don't. We never stop. Just keep after it.
00:58:08,744 -- 00:58:09,879
Someday it'll happen.
00:58:10,880 -- 00:58:12,381
Someday.
00:58:12,381 -- 00:58:12,849
Right?
00:58:12,849 -- 00:58:15,852
So this is an idea that some have suggested.
00:58:15,852 -- 00:58:19,789
This technology can be used to analyze a lot of data.
00:58:19,789 -- 00:58:23,092
Right. You can use that to analyze all that anomaly.
00:58:23,092 -- 00:58:24,994
Why is this particular agent
00:58:24,994 -- 00:58:27,129
just seems to be doing so much more do
00:58:27,129 -- 00:58:29,732
when he or she is the youngest,
00:58:29,732 -- 00:58:34,203
like I think identifying that anomaly that is just
00:58:34,203 -- 00:58:36,405
not, seem
00:58:36,405 -- 00:58:38,841
unreasonable, is a way to help,
00:58:38,841 -- 00:58:40,977
you know, help you to target
00:58:40,977 -- 00:58:44,080
where you need to spend your time on.
00:58:44,080 -- 00:58:47,583
It's something that is not a secret.
00:58:47,583 -- 00:58:48,951
As a risk based regulator,
00:58:48,951 -- 00:58:51,254
we, we do that too, is try to look for anomaly.
00:58:51,254 -- 00:58:54,757
Look at where seems to be the highest risk area.
00:58:54,757 -- 00:58:56,626
and then it help us target our resources.
00:58:56,626 -- 00:59:00,630
So that's definitely, is what some has told me this
00:59:00,630 -- 00:59:03,165
as use of technology and automation.
00:59:05,334 -- 00:59:05,635
Okay.
00:59:05,635 -- 00:59:09,639
So I think this might be our last question. We'll see.
00:59:09,639 -- 00:59:11,674
When I try to implement
00:59:11,674 -- 00:59:13,309
a new compliance measure
00:59:13,309 -- 00:59:15,978
standard document or other process,
00:59:15,978 -- 00:59:16,645
my agents
00:59:16,645 -- 00:59:19,148
push back saying they're independent contractors,
00:59:19,148 -- 00:59:22,118
so I shouldn't be so controlling or monitoring.
00:59:22,118 -- 00:59:24,553
How do we bridge the gap in understanding
00:59:24,553 -- 00:59:26,522
that supervision and compliance
00:59:26,522 -- 00:59:29,291
expectations are no different, regardless
00:59:29,291 -- 00:59:31,861
of whether they are salaried or contractors?
00:59:31,861 -- 00:59:32,995
I'll start with that one.
00:59:32,995 -- 00:59:36,532
When I think I've heard that many times.
00:59:36,532 -- 00:59:39,301
you know, so,
00:59:39,301 -- 00:59:42,938
yes, you know, mortgage or agent broker will say, you know, yes I’m an independent contractor,
00:59:42,938 -- 00:59:45,875
but you cannot operate without being under a brokerage.
00:59:45,875 -- 00:59:50,412
So the way I approach this, my sandbox, my rules. Okay.
00:59:50,412 -- 00:59:53,115
So reality is, if you don't like it,
00:59:53,115 -- 00:59:54,850
by all means, there's the door.
00:59:54,850 -- 00:59:57,386
You just show yourself out. You're independent, you can go.
00:59:57,386 -- 01:00:00,222
But the reality, the approach that I,
01:00:00,222 -- 01:00:02,691
I take with, it's showing them is like.
01:00:02,691 -- 01:00:06,061
And I actually I love that FSRA has the enforcement page,
01:00:06,061 -- 01:00:09,565
I weekly will go on there and pull up.
01:00:09,565 -- 01:00:12,468
Where do you think that's new and send it out to my team.
01:00:12,468 -- 01:00:13,702
And here is
01:00:13,702 -- 01:00:16,639
and I'll relate it to why we have a process in place.
01:00:16,639 -- 01:00:19,375
Here's something that somebody did wrong
01:00:19,375 -- 01:00:21,744
FSRA, you know, took action. Here's the penalty.
01:00:21,744 -- 01:00:25,748
Here's $140,000 in penalty that they got hit with.
01:00:25,748 -- 01:00:28,651
And here's how our documentation or our process
01:00:28,651 -- 01:00:32,621
or our policy protects you from being on that page.
01:00:32,621 -- 01:00:34,456
And that's how I related back to them.
01:00:34,456 -- 01:00:35,858
And in the beginning
01:00:35,858 -- 01:00:38,160
it was always that kind of like, well, you know,
01:00:38,160 -- 01:00:40,329
I want to run my business how I want to run my business.
01:00:40,329 -- 01:00:40,930
No problem.
01:00:40,930 -- 01:00:42,131
By all means, go get your mortgage,
01:00:42,131 -- 01:00:43,832
your principal broker's license,
01:00:43,832 -- 01:00:46,302
go open your own brokerage and go to town on it.
01:00:46,302 -- 01:00:48,370
But if you're going to be part of my brokerage,
01:00:48,370 -- 01:00:49,471
this is how we're going to do it.
01:00:49,471 -- 01:00:51,440
And here's the reason why.
01:00:51,440 -- 01:00:53,809
I'm taking this extra step
01:00:53,809 -- 01:00:55,077
to protect you
01:00:55,077 -- 01:00:58,514
and your business, so that you are going to be, as Ron
01:00:58,514 -- 01:01:00,749
mentioned, you know, it's longevity.
01:01:00,749 -- 01:01:03,085
You're going to be in this business longer
01:01:03,085 -- 01:01:05,688
because of these processes, because of these steps,
01:01:05,688 -- 01:01:07,890
because of the standardization of documentation
01:01:07,890 -- 01:01:10,125
that make sure you don't miss something
01:01:10,125 -- 01:01:11,293
when dealing with a client.
01:01:12,394 -- 01:01:13,529
I guess my first comment would be
01:01:13,529 -- 01:01:15,564
if a principal broker is the person
01:01:15,564 -- 01:01:17,299
asking that question,
01:01:17,299 -- 01:01:21,770
like the appropriate comment is grow a spine.
01:01:21,770 -- 01:01:23,572
Nothing else
01:01:23,572 -- 01:01:25,240
relevant after that.
01:01:25,240 -- 01:01:27,943
So it's funny because you know,
01:01:27,943 -- 01:01:30,746
one thing that I used to deal with all the time was brokers
01:01:30,746 -- 01:01:32,347
and agents
01:01:32,347 -- 01:01:36,151
wanted to advertise themselves as their own entity.
01:01:36,151 -- 01:01:36,385
Right?
01:01:36,385 -- 01:01:37,820
They all have personal service corp.
01:01:37,820 -- 01:01:42,825
So, you know, it’s, it’s, Ron’s mortgages as an example.
01:01:42,991 -- 01:01:45,461
And I tell the story, I go years ago,
01:01:45,461 -- 01:01:48,831
I had an agent who wanted to go and create his own brand.
01:01:48,831 -- 01:01:49,531
And, you know,
01:01:49,531 -- 01:01:52,701
so he created a company, Ron’s Mortgages, Inc.,
01:01:52,701 -- 01:01:54,269
and he decided that he was going to put it
01:01:54,269 -- 01:01:58,307
on all his letterhead, including the brokerage letterhead.
01:01:58,307 -- 01:02:00,209
And one day they made a mistake
01:02:00,209 -- 01:02:03,445
on quoting the prepayment penalty
01:02:03,445 -- 01:02:05,514
and sure enough, a lawsuit occured
01:02:05,514 -- 01:02:09,451
So the simple reality was in this lawsuit,
01:02:09,451 -- 01:02:10,519
the brokerage was named
01:02:11,486 -- 01:02:13,689
Ron Butler was named as the agent.
01:02:13,689 -- 01:02:15,791
Butler Mortgages, Inc. was also named.
01:02:15,791 -- 01:02:17,125
But the problem was the,
01:02:17,125 -- 01:02:19,895
you know, insurance only covered the brokerage
01:02:19,895 -- 01:02:22,364
and the individual, but not this entity.
01:02:22,364 -- 01:02:25,000
So it was the most awkward situation
01:02:25,000 -- 01:02:27,736
because we had to go to court and discoveries,
01:02:27,736 -- 01:02:30,572
and the individual had to get his own lawyer
01:02:30,572 -- 01:02:33,108
to protect his corporate entity.
01:02:33,108 -- 01:02:33,809
Yet we had an,
01:02:33,809 -- 01:02:34,676
you know, person
01:02:34,676 -- 01:02:36,078
representing the individual
01:02:36,078 -- 01:02:37,212
in the brokerage
01:02:37,212 -- 01:02:39,448
of which at the end of day, we came up with a settlement
01:02:39,448 -- 01:02:41,984
of which everybody paid a certain sum.
01:02:41,984 -- 01:02:43,385
But it's a very awkward scenario.
01:02:43,385 -- 01:02:46,188
And, and I tell these stories because to me, it's like,
01:02:46,188 -- 01:02:47,456
if you want to go down this road
01:02:47,456 -- 01:02:49,391
and you want to do these sorts of things,
01:02:49,391 -- 01:02:51,159
and this is a consequence, like you can
01:02:51,159 -- 01:02:52,327
you're going to be named in this suit
01:02:52,327 -- 01:02:54,329
and you have absolutely no coverage
01:02:54,329 -- 01:02:55,430
and you're going to get screwed.
01:02:55,430 -- 01:02:57,432
So why do you want to go down this road?
01:02:57,432 -- 01:02:58,367
So, you know, it's funny
01:02:58,367 -- 01:03:01,169
but you know, to this, you know, to Ron's point
01:03:01,169 -- 01:03:02,938
to grow a spine,
01:03:02,938 -- 01:03:05,440
it is very true that I think as the principal broker,
01:03:05,440 -- 01:03:07,843
you have to have, you know,
01:03:07,843 -- 01:03:09,277
I think Antoinette said this, you know,
01:03:09,277 -- 01:03:10,345
you need to do the right thing.
01:03:10,345 -- 01:03:11,380
You need to have integrity,
01:03:11,380 -- 01:03:14,082
and you need to make sure that the things that you're doing
01:03:14,082 -- 01:03:16,151
is in the best interest of the entity
01:03:16,151 -- 01:03:17,686
in which you're serving,
01:03:17,686 -- 01:03:19,388
and not to fall into the trap
01:03:19,388 -- 01:03:21,056
of doing what your agent wants to do,
01:03:21,056 -- 01:03:23,625
because they're a big producer and they call the shots.
01:03:25,694 -- 01:03:27,562
Which...Oh, sorry, go ahead, Kerrie.
01:03:27,562 -- 01:03:28,930
Sorry, I'll add into that.
01:03:28,930 -- 01:03:30,832
Obviously, we deal with a lot of agents
01:03:30,832 -- 01:03:34,703
and brokers in different provinces as well.
01:03:34,703 -- 01:03:39,708
Courage is another key word that comes to mind for me.
01:03:40,408 -- 01:03:43,578
I'm not a very scary person, but I can be.
01:03:43,578 -- 01:03:46,848
And, you know, we approach
01:03:46,848 -- 01:03:50,085
we approach the licensing renewal
01:03:50,085 -- 01:03:55,090
as an opportunity for an agent to stay or go
01:03:55,390 -- 01:03:58,093
instead of, I really do like Sadiq's approach.
01:03:58,093 -- 01:03:59,427
And I was sending out,
01:03:59,427 -- 01:04:03,031
FSRA communications or other principal brokers
01:04:03,031 -- 01:04:04,900
who are sharing information of a situation
01:04:04,900 -- 01:04:05,867
that they've gone through.
01:04:05,867 -- 01:04:06,735
You can,
01:04:06,735 -- 01:04:07,035
you know,
01:04:07,035 -- 01:04:10,539
you can send out the communications of the did
01:04:10,539 -- 01:04:15,210
you knows that this could happen or this has happened.
01:04:15,210 -- 01:04:19,648
I tend to use the annual renewals as an opportunity
01:04:19,648 -- 01:04:23,251
for me to interview the agents all over again,
01:04:23,251 -- 01:04:26,821
making sure that they are strong and stable
01:04:26,821 -- 01:04:28,123
and who they are as a body
01:04:28,123 -- 01:04:30,458
because they're actually a business in themselves,
01:04:30,458 -- 01:04:33,395
which is, you know, a smaller part of who we are.
01:04:33,395 -- 01:04:38,533
But I also use that time to communicate what's coming,
01:04:39,234 -- 01:04:39,534
right.
01:04:39,534 -- 01:04:41,636
What changes as Premier Mortgage Centre is
01:04:41,636 -- 01:04:44,639
going to be making within the brokerage.
01:04:44,639 -- 01:04:48,143
And it opens lines of communication for feedback,
01:04:48,143 -- 01:04:50,145
although I may not welcome any of it.
01:04:51,146 -- 01:04:53,415
It does keep the line of communication open,
01:04:53,415 -- 01:04:54,549
but it also gives the agent
01:04:54,549 -- 01:04:56,918
an opportunity to say,
01:04:56,918 -- 01:05:00,188
you know, I'm not interested in having to,
01:05:00,188 -- 01:05:02,057
you know, operate in this way
01:05:02,057 -- 01:05:03,258
moving forward and,
01:05:03,258 -- 01:05:05,293
and FSRA can back me up on this one.
01:05:05,293 -- 01:05:08,363
There are licenses that we don't renew. That's okay.
01:05:08,363 -- 01:05:09,364
It's okay.
01:05:09,364 -- 01:05:12,067
Sadiq and I were speaking about this earlier today.
01:05:12,067 -- 01:05:16,604
Where if there ever comes a time where I am more concerned
01:05:16,604 -- 01:05:19,040
and focused on your business than you are,
01:05:19,040 -- 01:05:20,842
then we have an improper imbalance,
01:05:20,842 -- 01:05:23,311
and it's time for us to part ways.
01:05:23,311 -- 01:05:23,511
Yeah.
01:05:23,511 -- 01:05:27,682
And just to add to Kerrie, like, you know, every year I do,
01:05:27,682 -- 01:05:28,650
at least once a year,
01:05:28,650 -- 01:05:30,952
I'll have a mandatory compliance meeting
01:05:30,952 -- 01:05:33,221
where everybody has to attend their
01:05:33,221 -- 01:05:34,923
they're given the two months notice.
01:05:34,923 -- 01:05:37,025
So whatever else you've got going on in your life,
01:05:37,025 -- 01:05:39,494
you better sort it out and be there.
01:05:39,494 -- 01:05:41,529
Because if you're not there,
01:05:41,529 -- 01:05:43,598
your license isn't getting renewed.
01:05:43,598 -- 01:05:46,835
And that's the meeting. And so next Monday is my meeting.
01:05:46,835 -- 01:05:49,671
And I bring everybody up to date on everything
01:05:49,671 -- 01:05:52,073
that's happening in the, in the,
01:05:52,073 -- 01:05:52,841
the brokerage
01:05:52,841 -- 01:05:55,410
where the direction we're going, all that good stuff
01:05:55,410 -- 01:05:57,812
and also anything new that we're implementing
01:05:57,812 -- 01:06:00,648
because of trends in the industry
01:06:00,648 -- 01:06:01,950
or things that we're seeing
01:06:01,950 -- 01:06:06,254
and again, that I have one for sure, every single year
01:06:06,254 -- 01:06:08,389
with my mandatory one, just coming up to renewal.
01:06:08,389 -- 01:06:10,091
And then I'll also, if needed,
01:06:10,091 -- 01:06:12,160
have other mandatory ones throughout the year
01:06:12,160 -- 01:06:14,128
if things are evolving a little bit faster,
01:06:14,128 -- 01:06:15,730
if there's more changes, regulatory
01:06:15,730 -- 01:06:17,565
or anything, I have to bring them up too.
01:06:17,565 -- 01:06:21,135
But the rule is, is if you don't attend this, you're gone
01:06:21,135 -- 01:06:23,504
because mandatory is mandatory,
01:06:23,504 -- 01:06:25,239
and if you don't like it, don't show up.
01:06:25,239 -- 01:06:27,842
But you're also not going to be part of this brokerage
01:06:27,842 -- 01:06:30,845
because I don't want that liability on my shoulders.
01:06:33,581 -- 01:06:35,750
So it looks like the last question
01:06:35,750 -- 01:06:37,151
Antoinette is for FSRA.
01:06:37,151 -- 01:06:39,220
FSRA is being put on the spot.
01:06:39,220 -- 01:06:41,923
Does FSRA have specific expectations
01:06:41,923 -- 01:06:44,592
or guidelines for compliance?
01:06:44,592 -- 01:06:47,528
How do brokerages know if their compliance procedures
01:06:47,528 -- 01:06:49,997
are being handed down to their agents or brokers,
01:06:49,997 -- 01:06:52,567
are meeting FSRA’s expectations?
01:06:52,567 -- 01:06:54,435
So we're doing a few things.
01:06:54,435 -- 01:06:58,673
I think some of you have heard us talked about this before.
01:06:58,673 -- 01:07:00,908
we are going to be putting out Guidance,
01:07:00,908 -- 01:07:04,045
for principal brokers and brokerages,
01:07:04,045 -- 01:07:04,979
just to set out
01:07:04,979 -- 01:07:06,047
what are the things
01:07:06,047 -- 01:07:09,517
that we would be expecting a principal broker
01:07:09,517 -- 01:07:10,318
to do,
01:07:10,318 -- 01:07:12,954
you know, from on boarding, training all the way
01:07:12,954 -- 01:07:16,958
to addressing compliance issues. So that's coming up.
01:07:16,958 -- 01:07:20,728
Other things that we are looking at doing more is,
01:07:20,728 -- 01:07:24,365
you know, communicating best practices.
01:07:24,365 -- 01:07:28,903
We have put out semiannual newsletters, starting
01:07:28,903 -- 01:07:31,139
maybe a couple of years ago. So that's going to continue.
01:07:31,139 -- 01:07:32,607
So there's going to be information
01:07:32,607 -- 01:07:34,575
there as we notice,
01:07:34,575 -- 01:07:36,944
best practices that came out from the sector.
01:07:36,944 -- 01:07:39,247
We want to share that with all of you.
01:07:39,247 -- 01:07:41,716
So that's another useful tool.
01:07:41,716 -- 01:07:44,352
Other things that we are going to do
01:07:44,352 -- 01:07:49,290
more going forward is through either webinars or training,
01:07:49,290 -- 01:07:54,128
to identify topics that may be of interest to the sector,
01:07:54,128 -- 01:07:55,897
to principal brokers.
01:07:55,897 -- 01:07:59,000
So if there are topics that you're interested
01:07:59,000 -- 01:08:00,234
in, do let us know.
01:08:00,234 -- 01:08:02,503
We will make sure that we find ways
01:08:02,503 -- 01:08:05,172
to address some of your questions.
01:08:05,172 -- 01:08:09,777
And, and you're going to hear more from us, about upcoming,
01:08:09,777 -- 01:08:13,147
training or webinars or sessions. Great.
01:08:14,115 -- 01:08:15,349
Chris, I know
01:08:15,349 -- 01:08:18,819
we're not allowed to do this, but I'll make the exception.
01:08:18,819 -- 01:08:21,522
Question for the market.
01:08:21,522 -- 01:08:22,390
What do you feel
01:08:22,390 -- 01:08:27,395
are challenges, with respect to the in our...
01:08:28,863 -- 01:08:31,032
Do you want to repeat the question
01:08:31,032 -- 01:08:32,033
for our audience?
01:08:32,033 -- 01:08:35,369
So from the audience, someone asked if,
01:08:35,369 -- 01:08:38,005
the industry participants can share with us
01:08:38,005 -- 01:08:41,876
what are some of the greatest challenges with implementing
01:08:41,876 -- 01:08:43,878
the new anti-money
01:08:43,878 -- 01:08:46,881
laundering terrorist financing requirements
01:08:46,881 -- 01:08:49,316
that FINTRAC has put in place?
01:08:49,316 -- 01:08:53,487
Okay, so I'll take that first. One element
01:08:53,487 -- 01:08:55,956
that is ridiculous.
01:08:55,956 -- 01:08:58,058
If you're doing a mortgage with a bank,
01:08:58,058 -- 01:09:02,897
you're doing a mortgage with CMHC, a lender.
01:09:02,897 -- 01:09:04,665
They have to meet all those compliance
01:09:04,665 -- 01:09:06,967
guidelines themselves.
01:09:06,967 -- 01:09:10,971
So we're actually just duplicating our efforts
01:09:10,971 -- 01:09:14,208
on 90% of the files. It's just pure duplication.
01:09:14,208 -- 01:09:16,744
It's a pure expense on the brokerage.
01:09:16,744 -- 01:09:22,183
Now, if FINTRAC had spent even 30 seconds
01:09:22,416 -- 01:09:25,419
doing rational consultation with the industry,
01:09:25,419 -- 01:09:27,688
they would have realized that
01:09:27,688 -- 01:09:30,958
you only need to track the private mortgage money.
01:09:30,958 -- 01:09:31,392
That's it.
01:09:31,392 -- 01:09:32,793
That's the only place,
01:09:32,793 -- 01:09:37,798
if every, if every other entity is doing this work already.
01:09:38,199 -- 01:09:40,768
Why I get the belt and suspenders idea.
01:09:40,768 -- 01:09:42,803
But please, it's too much.
01:09:42,803 -- 01:09:45,506
If we're, if it's, if the, if a bank,
01:09:45,506 -- 01:09:47,641
if the Bank of Nova Scotia and TD Bank
01:09:47,641 -- 01:09:50,844
can't report properly to FINTRAC,
01:09:50,844 -- 01:09:52,846
we're probably going to do a worse job. Right?
01:09:52,846 -- 01:09:54,648
So in the end,
01:09:54,648 -- 01:09:58,319
the private money needs to be meticulously reviewed,
01:09:58,319 -- 01:10:01,355
because that's where all the evil doing goes on
01:10:01,355 -- 01:10:04,525
is in the private space in terms of AML.
01:10:04,525 -- 01:10:06,894
And I've seen it, I've observed it.
01:10:06,894 -- 01:10:09,263
I've observed what some brokerages have done,
01:10:09,263 -- 01:10:10,998
but it's creating a whole regime
01:10:10,998 -- 01:10:13,200
to have us duplicate something
01:10:13,200 -- 01:10:16,570
that banks and CMHC lenders are doing already.
01:10:16,570 -- 01:10:19,606
It just never made any sense to me. Yeah.
01:10:19,606 -- 01:10:20,774
The other part of that, too, is
01:10:20,774 -- 01:10:22,810
I've had conversations with FINTRAC over it.
01:10:22,810 -- 01:10:26,280
Is that, you, the,
01:10:26,280 -- 01:10:29,049
they have not provided any details of
01:10:29,049 -- 01:10:31,118
how to report, when to report, how often report,
01:10:31,118 -- 01:10:33,020
what method of reporting, any of that.
01:10:33,020 -- 01:10:35,789
So it's like how will we how is a brokerage especially
01:10:36,924 -- 01:10:38,325
that to Ron's point,
01:10:38,325 -- 01:10:38,625
you know,
01:10:38,625 -- 01:10:40,594
when 90% of your business is institutional
01:10:40,594 -- 01:10:41,462
and they already
01:10:41,462 -- 01:10:42,730
have those processes in place,
01:10:42,730 -- 01:10:46,467
and we're now just duplicating efforts, for that other 10%.
01:10:46,467 -- 01:10:47,701
It's a big cost.
01:10:47,701 -- 01:10:51,405
And you still haven't provided any framework for
01:10:51,405 -- 01:10:52,973
how are we supposed to implement that?
01:10:52,973 -- 01:10:53,974
It's kind of like,
01:10:53,974 -- 01:10:55,676
I might as well just be shooting in the dark here,
01:10:55,676 -- 01:10:57,578
because how do I report that to you
01:10:57,578 -- 01:10:59,113
if you haven't given me a framework
01:10:59,113 -- 01:11:02,716
and a methodology and a format in which you want to see it.
01:11:02,716 -- 01:11:03,083
Right.
01:11:03,083 -- 01:11:04,585
And I think that's kind of the problem
01:11:04,585 -- 01:11:05,953
that brokerage people face
01:11:05,953 -- 01:11:10,757
until something systematic is put in place by FINTRAC.
01:11:10,757 -- 01:11:11,959
I think like most things, it's going to
01:11:11,959 -- 01:11:13,861
take time to, to flush out,
01:11:15,429 -- 01:11:15,896
you know,
01:11:15,896 -- 01:11:20,868
what brings me the biggest fear is if you look at the, AML,
01:11:20,868 -- 01:11:22,135
penalties have been levied
01:11:22,135 -- 01:11:24,938
so far, it brings a chill to my spine.
01:11:24,938 -- 01:11:26,273
And I'm thankful
01:11:26,273 -- 01:11:27,341
that I'm not in the business anymore
01:11:27,341 -- 01:11:29,676
from that perspective, because
01:11:29,676 -- 01:11:31,144
you know, there's real estate firms
01:11:31,144 -- 01:11:32,179
that have had big fines
01:11:32,179 -- 01:11:33,680
levied against them, like this stuff isn't,
01:11:33,680 -- 01:11:34,781
you know, $5,000 fine.
01:11:34,781 -- 01:11:38,652
This is like $50,000 like, this is big money.
01:11:38,652 -- 01:11:39,519
So, you know,
01:11:39,519 -- 01:11:41,488
I think to Ron's point, we don't quite understand
01:11:41,488 -- 01:11:42,356
how it's all going to work out
01:11:42,356 -- 01:11:44,791
because I think it's, to Ron's point,
01:11:44,791 -- 01:11:47,361
the truth is, is if you do an institutional transaction,
01:11:47,361 -- 01:11:49,029
then they're going to do the work anyways
01:11:49,029 -- 01:11:50,597
and they probably will do a better job than us.
01:11:50,597 -- 01:11:53,100
But if we're doing business with MICs and private lenders
01:11:53,100 -- 01:11:54,968
then we better get our act together
01:11:54,968 -- 01:11:56,303
and make sure we're doing the right thing.
01:11:56,303 -- 01:11:57,537
And, you know, to some extent,
01:11:57,537 -- 01:12:00,007
I do think that the industry probably has
01:12:00,007 -- 01:12:02,109
turned a blind eye because the truth is, is
01:12:02,109 -- 01:12:03,176
you might have sent the deal to
01:12:03,176 -- 01:12:04,478
Home Trust or Equitable Bank
01:12:05,479 -- 01:12:08,115
and got a list of requirements that came back,
01:12:08,115 -- 01:12:09,416
said, oh, I don't need to provide this.
01:12:09,416 -- 01:12:10,817
If I go to a MIC or private lender.
01:12:10,817 -- 01:12:12,319
And off it went, and,
01:12:12,319 -- 01:12:14,388
and all those banks and lenders were doing
01:12:14,388 -- 01:12:15,756
was following AML rules.
01:12:15,756 -- 01:12:18,125
So all we've done is we leveled the plain field
01:12:18,125 -- 01:12:20,560
and we all have to do the right level of due
01:12:20,560 -- 01:12:23,230
diligence, especially on private and MIC transactions.
01:12:23,230 -- 01:12:24,765
So for principal brokers
01:12:24,765 -- 01:12:26,800
who've got agents playing in that space,
01:12:26,800 -- 01:12:30,070
I think the responsibility is growing leaps and bounds.
01:12:30,070 -- 01:12:30,937
And it's going to be it's
01:12:30,937 -- 01:12:32,005
going to take some time before
01:12:32,005 -- 01:12:33,740
people have all sort of graduated
01:12:33,740 -- 01:12:36,576
to the level of expectation because,
01:12:36,576 -- 01:12:36,777
you know,
01:12:36,777 -- 01:12:38,845
there's a lot of MICs out there that are very small,
01:12:38,845 -- 01:12:42,115
and I don't know that I trust them to do all the work.
01:12:42,115 -- 01:12:43,283
But there's some bigger ones that,
01:12:43,283 -- 01:12:44,451
that I have a better relationship with.
01:12:44,451 -- 01:12:46,319
But those are the kind of things, I think,
01:12:46,319 -- 01:12:47,287
we're just now at a point
01:12:47,287 -- 01:12:49,122
where we can't rely on somebody else.
01:12:49,122 -- 01:12:50,524
We're just gonna have to do the work ourselves,
01:12:50,524 -- 01:12:53,193
especially on MIC and private transactions.
01:12:56,163 -- 01:13:00,534
So I think we're at our final last question.
01:13:00,534 -- 01:13:03,470
It seems like everything is on the PB.
01:13:03,470 -- 01:13:05,672
What about other management or directors
01:13:05,672 -- 01:13:07,340
or officers of the corporation?
01:13:07,340 -- 01:13:11,578
What is their responsibility and liability?
01:13:11,578 -- 01:13:13,213
Can I take this one?
01:13:13,213 -- 01:13:14,981
That is a great question.
01:13:14,981 -- 01:13:20,453
And I think is a, is a misunderstanding of the sector.
01:13:20,554 -- 01:13:22,956
There are in fact liability provision
01:13:22,956 -- 01:13:26,059
within our statute that deals with
01:13:26,059 -- 01:13:27,994
all directors and officers.
01:13:27,994 -- 01:13:29,863
And one of the things that we're attempting
01:13:29,863 -- 01:13:30,297
to do
01:13:30,297 -- 01:13:34,834
with our upcoming Guidance is to outline, you know,
01:13:34,834 -- 01:13:40,106
what are our expectation on management, of the brokerage,
01:13:40,774 -- 01:13:43,510
in addition to the principal brokers,
01:13:43,510 -- 01:13:44,978
especially in cases
01:13:44,978 -- 01:13:47,080
where the principal broker is not an owner,
01:13:47,080 -- 01:13:50,250
they don't have direct control over the whole business.
01:13:50,250 -- 01:13:53,853
So that's where we want to emphasize that they play a role.
01:13:53,853 -- 01:13:57,090
They have a responsibility to make sure that
01:13:57,090 -- 01:13:58,391
whoever they appoint
01:13:58,391 -- 01:14:01,361
as the principal broker have the capability
01:14:01,361 -- 01:14:02,796
and the capacity to do it,
01:14:02,796 -- 01:14:06,700
they also have the responsibility to make sure that,
01:14:06,700 -- 01:14:09,469
they are supporting their principal broker
01:14:09,469 -- 01:14:11,471
so that they can do the job effectively.
01:14:11,471 -- 01:14:12,806
So we're going to clarify that,
01:14:12,806 -- 01:14:15,341
because that, that is an excellent question.
01:14:15,341 -- 01:14:17,177
And that was also one of the reason why
01:14:17,177 -- 01:14:19,612
it is such a difficult job for principal brokers.
01:14:21,414 -- 01:14:21,848
Great.
01:14:21,848 -- 01:14:24,918
Well, we have almost run out of time.
01:14:24,918 -- 01:14:29,055
Thank you very much, panel. This was really great
01:14:29,055 -- 01:14:31,024
content. Great discussion.
01:14:31,024 -- 01:14:32,992
I hope the folks online enjoyed it
01:14:32,992 -- 01:14:35,295
as much as the folks that are here.
01:14:35,295 -- 01:14:37,530
I do want to take a few moments
01:14:37,530 -- 01:14:39,432
because my licensing colleagues
01:14:39,432 -- 01:14:42,068
gave me a bit of a poke earlier.
01:14:42,068 -- 01:14:45,271
And they said, you know, you got to get this message out.
01:14:45,271 -- 01:14:46,239
Want to remind
01:14:46,239 -- 01:14:48,174
everyone that the deadline to renew
01:14:48,174 -- 01:14:51,511
your license is approaching really fast.
01:14:51,511 -- 01:14:53,279
So if you want to keep arranging
01:14:53,279 -- 01:14:55,281
private mortgages for your clients,
01:14:55,281 -- 01:14:57,650
you need to have completed two things.
01:14:57,650 -- 01:14:59,819
One, your private mortgage course
01:14:59,819 -- 01:15:02,589
and two, your continuing education course.
01:15:02,589 -- 01:15:03,223
So please
01:15:03,223 -- 01:15:05,458
remember that you need to do these things before
01:15:05,458 -- 01:15:08,261
renewing your license by the March 31st deadline.
01:15:09,729 -- 01:15:14,734
So thank you again for taking the time to be with us today.
01:15:14,968 -- 01:15:16,769
Thank you for the excellent discussion
01:15:16,769 -- 01:15:18,338
that the panel gave us.
01:15:18,338 -- 01:15:21,241
I hope that you found this session helpful.
01:15:21,241 -- 01:15:21,641
Please
01:15:21,641 -- 01:15:24,377
do take some time to fill in the conference
01:15:24,377 -- 01:15:26,946
survey on the conference website.
01:15:26,946 -- 01:15:29,315
It's under the heading of feedback,
01:15:29,315 -- 01:15:31,985
And it's on the lobby homepage.
01:15:31,985 -- 01:15:34,187
After this session concludes,
01:15:34,187 -- 01:15:37,790
there will be more discussion and more importantly,
01:15:37,790 -- 01:15:41,227
some light food and a cash bar out in the lobby.
01:15:41,227 -- 01:15:43,463
So hopefully we can continue the conversation
01:15:43,463 -- 01:15:45,798
out there in the interim.
01:15:45,798 -- 01:15:47,000
Thank you again, folks.
01:15:47,000 -- 01:15:48,568
This was a really great conversation.
01:15:48,568 -- 01:15:50,169
I think everyone that's here
01:15:50,169 -- 01:15:53,806
got something, different and exciting out of it. Thank you.
01:15:53,806 -- 01:15:54,440
Thank you, thank you.
00:00:05,004 -- 00:00:06,172
Welcome to
00:00:06,172 -- 00:00:07,774
our Life and Health Insurance
00:00:07,774 -- 00:00:11,678
breakout at the 2024 FSRA Exchange.
00:00:11,678 -- 00:00:13,346
My name is Erica Hiemstra.
00:00:13,346 -- 00:00:16,950
I'm the Head of Insurance Conduct for FSRA.
00:00:16,950 -- 00:00:21,287
and I'm your moderator for today's session.
00:00:21,287 -- 00:00:24,991
Thank you so much for joining us here today in the room
00:00:24,991 -- 00:00:26,826
as well as virtually.
00:00:26,826 -- 00:00:30,997
And, I will just pause, just for a nod from our
00:00:30,997 -- 00:00:32,132
tech crew at the back.
00:00:32,132 -- 00:00:35,468
Are we going, were live virtually as well?
00:00:35,468 -- 00:00:39,105
Okay, so I'm getting the thumbs up, so we'll just proceed.
00:00:39,105 -- 00:00:40,773
Before we begin,
00:00:40,773 -- 00:00:41,975
I wondered why they gave us
00:00:41,975 -- 00:00:42,876
just ten minutes
00:00:42,876 -- 00:00:44,010
to introduce the session
00:00:44,010 -- 00:00:46,012
because I thought, well, everybody already knows
00:00:46,012 -- 00:00:48,548
Eric and Swati and Kim and Robert.
00:00:48,548 -- 00:00:49,616
So what is this about?
00:00:49,616 -- 00:00:51,217
But there's a whole bunch of directions
00:00:51,217 -- 00:00:53,453
that they then gave me to read out to you.
00:00:53,453 -- 00:00:55,088
So I'm going to go through those first
00:00:55,088 -- 00:00:58,057
and then we'll get going into our discussion.
00:00:58,057 -- 00:00:58,791
So hold tight.
00:01:00,159 -- 00:01:03,630
I just wanted to go over a couple of housekeeping measures.
00:01:03,630 -- 00:01:03,963
First one, to,
00:01:03,963 -- 00:01:05,899
remind everyone
00:01:05,899 -- 00:01:07,333
that this session is being taped
00:01:07,333 -- 00:01:10,570
for future posting on FSRA's website.
00:01:10,570 -- 00:01:12,238
And also,
00:01:12,238 -- 00:01:12,906
we do have
00:01:12,906 -- 00:01:15,608
simultaneous French translation
00:01:15,608 -- 00:01:18,444
for those who wish to listen in French.
00:01:18,444 -- 00:01:20,713
So for those of you in the room,
00:01:20,713 -- 00:01:22,916
we can provide you with a headset.
00:01:22,916 -- 00:01:23,650
If you need one,
00:01:23,650 -- 00:01:24,784
just raise your hand,
00:01:24,784 -- 00:01:27,186
and a staff member will bring the headset
00:01:27,186 -- 00:01:29,689
to you here in the room.
00:01:29,689 -- 00:01:33,159
And then for those of you attending virtually,
00:01:33,159 -- 00:01:34,160
simply click
00:01:34,160 -- 00:01:37,797
on your initials in the top right corner of your screen.
00:01:37,797 -- 00:01:42,802
Select, Set Language and choose to listen in French.
00:01:43,302 -- 00:01:45,371
Just pause to see if any hands are going up.
00:01:45,371 -- 00:01:47,106
It looks like we can proceed
00:01:47,106 -- 00:01:50,410
and hopefully those online can catch up with us.
00:01:50,410 -- 00:01:54,013
We do have an exciting discussion planned for you today.
00:01:54,013 -- 00:01:55,415
I have a number of questions
00:01:55,415 -- 00:01:58,017
for the panel, and we'll also be taking your questions
00:01:58,017 -- 00:02:00,720
during the last portion of the discussion.
00:02:00,720 -- 00:02:01,387
So please
00:02:01,387 -- 00:02:04,257
submit your questions through the conference site
00:02:04,257 -- 00:02:07,160
any time during our discussion today.
00:02:07,160 -- 00:02:08,194
For those of you
00:02:08,194 -- 00:02:09,362
who are in person,
00:02:09,362 -- 00:02:10,797
if for some reason
00:02:10,797 -- 00:02:12,965
you can't make the
00:02:12,965 -- 00:02:16,569
site work or can't access the conference site,
00:02:16,569 -- 00:02:18,037
again, just put up your hand
00:02:18,037 -- 00:02:19,472
and one of our FSRA staff will come
00:02:19,472 -- 00:02:22,108
and take your question down for you.
00:02:22,108 -- 00:02:24,477
Our team at the back of the room,
00:02:24,477 -- 00:02:25,878
will send the questions to me
00:02:25,878 -- 00:02:28,214
for our Q&A portion of the session.
00:02:28,214 -- 00:02:29,549
And if there are any questions
00:02:29,549 -- 00:02:30,817
that we cannot answer
00:02:30,817 -- 00:02:33,085
today, we'll post those responses
00:02:33,085 -- 00:02:35,955
on our event website in due course.
00:02:35,955 -- 00:02:36,856
And if,
00:02:36,856 -- 00:02:39,992
questions are similar, we will group them,
00:02:39,992 -- 00:02:42,428
just to get through as many questions as possible.
00:02:44,197 -- 00:02:47,066
Now, please allow me to introduce our expert
00:02:47,066 -- 00:02:49,235
panel for today's session.
00:02:49,235 -- 00:02:49,869
I encourage you
00:02:49,869 -- 00:02:54,840
to read their full biographies on the conference site.
00:02:55,708 -- 00:03:00,713
Three Chairs down to my left, we have Kim Hayes.
00:03:01,047 -- 00:03:04,216
Kim is the Global Head of Market Conduct
00:03:04,216 -- 00:03:06,218
Compliance for Manulife.
00:03:06,218 -- 00:03:08,588
Her primary responsibility
00:03:08,588 -- 00:03:11,290
is to provide leadership, direction
00:03:11,290 -- 00:03:13,559
and support of the Market Conduct
00:03:13,559 -- 00:03:16,028
compliance departments across the globe
00:03:16,028 -- 00:03:17,196
around the execution
00:03:17,196 -- 00:03:17,830
of the company's
00:03:17,830 -- 00:03:22,435
Market Conduct Compliance and Examination programs.
00:03:22,435 -- 00:03:25,671
Immediate to my left, we have Eric Wachtel.
00:03:25,671 -- 00:03:28,507
Eric is the Chief Compliance Officer
00:03:28,507 -- 00:03:31,243
for IDC Worldsource Insurance Network.
00:03:31,243 -- 00:03:36,248
There are large national MGA with 13 offices across Canada.
00:03:36,482 -- 00:03:40,119
He's also the Compliance Co-chair for CAILBA,
00:03:40,119 -- 00:03:42,321
the Canadian Association of Insurance Life
00:03:42,321 -- 00:03:43,823
Brokerage Agencies.
00:03:43,823 -- 00:03:46,058
So I don't have to pay the five bucks,
00:03:46,058 -- 00:03:49,161
and sits on numerous industry compliance committees,
00:03:50,830 -- 00:03:53,499
including the FSRA,
00:03:53,499 -- 00:03:56,368
Life and Health Stakeholder Advisory
00:03:56,368 -- 00:03:58,971
Committee. Between Eric and Kim,
00:03:58,971 -- 00:04:02,408
I have my esteemed colleague Swati Agrawal.
00:04:02,408 -- 00:04:04,810
Swati is the Director of Life and Health Insurance
00:04:04,810 -- 00:04:08,114
Companies and National Supervision at FSRA.
00:04:08,114 -- 00:04:10,416
She directs the development, design
00:04:10,416 -- 00:04:13,319
and implementation of regulatory compliance
00:04:13,319 -- 00:04:15,454
and end to end thematic reviews
00:04:15,454 -- 00:04:18,557
for insurance companies and their distribution partners.
00:04:18,557 -- 00:04:21,527
Swati is Ontario's lead for cooperative
00:04:21,527 -- 00:04:23,195
supervisory initiatives
00:04:23,195 -- 00:04:25,131
performed through the Canadian Council
00:04:25,131 -- 00:04:27,132
of Insurance Regulators,
00:04:27,132 -- 00:04:29,768
and she is also a Canadian representative
00:04:29,768 -- 00:04:32,905
at the International Association of Insurance Supervisors
00:04:32,905 -- 00:04:35,274
Market Conduct Working Group.
00:04:35,274 -- 00:04:36,909
I have to read this one out though. It's fun.
00:04:36,909 -- 00:04:41,914
The IAISMCWG.
00:04:42,181 -- 00:04:44,350
Where,
00:04:44,350 -- 00:04:45,184
I'm not done,
00:04:45,184 -- 00:04:50,289
where she, co-leads the Diversity, Equity and Inclusion,
00:04:50,289 -- 00:04:54,493
the DEI
00:04:54,493 -- 00:04:56,996
strategic initiative to evaluate
00:04:56,996 -- 00:05:00,232
how greater consideration of DEI
00:05:00,232 -- 00:05:02,568
can lead to better consumer outcomes.
00:05:02,568 -- 00:05:06,305
And finally, at the end of the stage here,
00:05:06,305 -- 00:05:07,573
we have Robert Prior.
00:05:09,275 -- 00:05:10,509
Robert is
00:05:10,509 -- 00:05:11,944
Senior Manager of Market
00:05:11,944 -- 00:05:16,949
Conduct of Life and Health Insurance Agents at FSRA.
00:05:17,149 -- 00:05:20,052
Robert joined FSRA around the same time as me.
00:05:20,052 -- 00:05:21,487
I think he came in 30 days
00:05:21,487 -- 00:05:23,255
before I did or something like that.
00:05:23,255 -- 00:05:26,258
So we were brought in to FSRA together
00:05:26,258 -- 00:05:27,559
in late 2020
00:05:27,559 -- 00:05:30,162
to establish and lead a new and dedicated
00:05:30,162 -- 00:05:32,798
Market Conduct Life and Health Insurance Agent Unit.
00:05:32,798 -- 00:05:35,000
I know many of you have gotten to know Robert
00:05:35,000 -- 00:05:37,636
over the course of the last couple of years,
00:05:37,636 -- 00:05:39,505
and you would understand
00:05:39,505 -- 00:05:41,874
how seriously and, how well he's
00:05:41,874 -- 00:05:43,876
executing on his mandate
00:05:43,876 -- 00:05:47,246
to supervise the compliance and business practices
00:05:47,246 -- 00:05:47,913
of the over
00:05:47,913 -- 00:05:50,049
60,000 life license agents
00:05:50,049 -- 00:05:54,253
that we have in the province of Ontario. Panel,
00:05:54,253 -- 00:05:57,856
our topic today is keeping the focus on consumers.
00:05:59,091 -- 00:06:01,660
What does strong conduct, culture and effective
00:06:01,660 -- 00:06:04,263
oversight in Life in Health Insurance look like?
00:06:04,263 -- 00:06:07,332
And I was so pleased in the plenary sessions this morning
00:06:07,332 -- 00:06:09,568
to really hear that messaging
00:06:09,568 -- 00:06:13,005
about keeping our mandate focused on consumers
00:06:13,005 -- 00:06:14,873
and focused on good outcomes
00:06:14,873 -- 00:06:18,644
for consumers in every one of the plenary sessions.
00:06:18,644 -- 00:06:21,313
And I think we'll probably just be continuing that theme
00:06:21,313 -- 00:06:23,482
throughout our discussion today.
00:06:23,482 -- 00:06:25,117
I think this topic really speaks
00:06:25,117 -- 00:06:26,952
to the essence of Life and Health Insurance,
00:06:26,952 -- 00:06:29,521
which is really that promise to pay,
00:06:29,521 -- 00:06:31,590
when something terrible, like a death
00:06:31,590 -- 00:06:32,691
or an illness
00:06:32,691 -- 00:06:37,696
happens to a consumer or to a member of their family.
00:06:38,664 -- 00:06:40,966
Consumers want certainty
00:06:40,966 -- 00:06:44,069
that they are covered and that their claim will be paid
00:06:44,069 -- 00:06:46,538
should that terrible event occur.
00:06:46,538 -- 00:06:47,205
In short,
00:06:47,205 -- 00:06:50,142
they expect life agents, intermediaries
00:06:50,142 -- 00:06:52,711
and insurers to treat them fairly.
00:06:52,711 -- 00:06:54,279
And adopting a culture of fair
00:06:54,279 -- 00:06:55,380
treatment of customers
00:06:55,380 -- 00:06:57,516
not only helps the industry to comply
00:06:57,516 -- 00:06:59,685
with regulatory expectations,
00:06:59,685 -- 00:07:03,055
but also to stay focused on protecting customers
00:07:03,055 -- 00:07:04,723
in their time of greatest need,
00:07:04,723 -- 00:07:06,925
which is the ultimate purpose of insurance.
00:07:06,925 -- 00:07:07,960
And this really leads me
00:07:07,960 -- 00:07:10,329
to our first question for the panel,
00:07:10,329 -- 00:07:15,267
which is what is the role of the regulator, the insurer,
00:07:15,267 -- 00:07:17,502
the MGA, and the agent
00:07:19,071 -- 00:07:19,738
in staying
00:07:19,738 -- 00:07:24,743
focused on consumers and achieving fair outcomes?
00:07:24,743 -- 00:07:26,244
And
00:07:26,244 -- 00:07:31,249
Swati, we had, you leading us off in this question.
00:07:31,550 -- 00:07:34,619
Hi, everyone. You can hear me. Okay.
00:07:34,619 -- 00:07:37,489
So the question is what is the role of the regulator,
00:07:37,489 -- 00:07:41,393
the insurance companies, the MGAs and all of us
00:07:41,393 -- 00:07:45,030
when it comes to the consumer? Right.
00:07:45,030 -- 00:07:47,799
So I have an interesting story.
00:07:47,799 -- 00:07:48,400
Just last
00:07:48,400 -- 00:07:50,502
Christmas, Beata Morris,
00:07:50,502 -- 00:07:53,905
she's the Director of Property and Casualty
00:07:53,905 -- 00:07:55,440
Supervision,
00:07:55,440 -- 00:07:59,377
and she's in the next room moderating, similar session.
00:07:59,377 -- 00:08:04,349
She gave me a momentum, which said, I am the regulator,
00:08:04,483 -- 00:08:07,118
I have superpowers.
00:08:07,118 -- 00:08:09,488
And, you know, when you're
00:08:09,488 -- 00:08:10,755
enjoying your holidays
00:08:10,755 -- 00:08:13,158
and somebody gives you something like that, it's a feel
00:08:13,158 -- 00:08:13,959
good thing, right?
00:08:13,959 -- 00:08:15,427
You feel nice. Wow.
00:08:15,427 -- 00:08:17,996
Do I have superpowers, really?
00:08:17,996 -- 00:08:20,298
Is that what a regulator is?
00:08:20,298 -- 00:08:22,868
And then you start pondering that,
00:08:22,868 -- 00:08:26,838
what does it really mean to have a superpower?
00:08:26,838 -- 00:08:30,075
You know what really drives this kind of superpower?
00:08:30,075 -- 00:08:33,111
That we assume somewhere we have in our mind.
00:08:34,179 -- 00:08:38,750
And that takes me back to when FSRA launched.
00:08:38,750 -- 00:08:40,285
So five years back
00:08:40,285 -- 00:08:43,955
when FSRA launched, you know, it was a white canvas for us.
00:08:43,955 -- 00:08:44,956
We were just thinking,
00:08:44,956 -- 00:08:49,194
what is it that we really want to do in this sector?
00:08:49,194 -- 00:08:50,662
And at that point in time,
00:08:50,662 -- 00:08:53,098
I remember having tons of conversations
00:08:53,098 -- 00:08:54,899
with Kim, with Eric,
00:08:54,899 -- 00:08:56,935
with so many of you in the room
00:08:56,935 -- 00:09:00,639
where we said the if we really want to regulate the sector,
00:09:00,639 -- 00:09:05,243
we have to look into the entire ecosystem, right?
00:09:05,243 -- 00:09:07,112
It wasn't just good enough
00:09:07,112 -- 00:09:09,414
to only look at insurance companies.
00:09:09,414 -- 00:09:12,684
It wasn't just good enough to only look at agents.
00:09:12,684 -- 00:09:13,418
In fact, by then
00:09:13,418 -- 00:09:16,187
we didn't even have a full blown agent team,
00:09:16,187 -- 00:09:19,691
and we had to look into the entire sales process,
00:09:19,691 -- 00:09:23,194
because every component of the sales process
00:09:23,194 -- 00:09:26,865
has a cascading effect on what really happens
00:09:26,865 -- 00:09:28,767
in the end to the consumer.
00:09:30,068 -- 00:09:31,436
So that is where our journey
00:09:31,436 -- 00:09:32,470
started,
00:09:32,470 -- 00:09:36,908
and that is what we referred to as end to end distribution.
00:09:36,908 -- 00:09:39,244
And that is when we actually started
00:09:39,244 -- 00:09:40,945
doing a lot of different studies
00:09:40,945 -- 00:09:43,114
through the different layers and layers
00:09:43,114 -- 00:09:46,451
which exist in the Life Insurance industry.
00:09:46,451 -- 00:09:48,686
Now, if I reflect back, you know,
00:09:48,686 -- 00:09:50,722
have we done a lot of stakeholder
00:09:50,722 -- 00:09:53,658
consultations in the process? Yes.
00:09:53,658 -- 00:09:56,194
Have we collected a lot of data structured
00:09:56,194 -- 00:09:58,096
and unstructured? Yes.
00:09:58,096 -- 00:10:00,598
But the biggest bang for our buck
00:10:00,598 -- 00:10:01,432
actually has
00:10:01,432 -- 00:10:03,868
been going out on the field
00:10:03,868 -- 00:10:06,738
and conducting proactive supervision.
00:10:06,738 -- 00:10:08,439
Because when we go out in the field
00:10:08,439 -- 00:10:09,174
and we do this
00:10:09,174 -- 00:10:10,575
proactive supervision,
00:10:10,575 -- 00:10:14,512
that is when we collect a lot of empirical evidence
00:10:14,512 -- 00:10:16,281
and that empirical evidence
00:10:16,281 -- 00:10:19,350
validates, you know, the different types of deficiencies
00:10:19,350 -- 00:10:22,120
and gaps that we are seeing in the marketplace.
00:10:22,120 -- 00:10:24,322
So I think the superpower came
00:10:24,322 -- 00:10:26,758
from a combination of a variety of things,
00:10:26,758 -- 00:10:29,260
but actually going out on the field
00:10:29,260 -- 00:10:32,263
and learning what the different businesses were doing,
00:10:32,263 -- 00:10:34,599
what the different layers and players were doing,
00:10:34,599 -- 00:10:37,001
and how it really impacts the consumer.
00:10:38,503 -- 00:10:42,006
So fast forward, you know, five years now,
00:10:42,006 -- 00:10:44,609
we are in a position where through the studies
00:10:44,609 -- 00:10:46,411
of all the layers and players,
00:10:46,411 -- 00:10:49,447
we've been able to determine the root cause
00:10:49,447 -- 00:10:52,450
of why consumer harm happens.
00:10:52,450 -- 00:10:54,185
We've been able to determine
00:10:54,185 -- 00:10:56,054
how consumers are being harmed,
00:10:56,054 -- 00:10:58,723
how vulnerable consumers are being treated,
00:10:58,723 -- 00:11:01,326
and how a better treatment of diverse,
00:11:01,326 -- 00:11:04,028
vulnerable, racialized minority
00:11:04,028 -- 00:11:06,898
consumers is so important in what we do.
00:11:06,898 -- 00:11:09,100
Through a combination of thematic studies,
00:11:09,100 -- 00:11:12,437
which we did at the insurer level, at the MGA level,
00:11:12,437 -- 00:11:14,405
as well as at the agents level,
00:11:14,405 -- 00:11:16,607
through Robert and his team.
00:11:16,607 -- 00:11:20,645
So with that in the mindset, you know, now as a regulator,
00:11:20,645 -- 00:11:22,680
we are moving from what I call
00:11:22,680 -- 00:11:25,750
as the discovery phase to a corrective phase.
00:11:25,750 -- 00:11:27,585
We've discovered a lot of issues,
00:11:27,585 -- 00:11:30,288
but now we have to correct those issues.
00:11:30,288 -- 00:11:32,290
And I wouldn't get into the details
00:11:32,290 -- 00:11:34,625
of how that correction has to happen.
00:11:34,625 -- 00:11:38,162
But we've released a publication that explains a six point
00:11:38,162 -- 00:11:41,399
plan of how we plan to correct the deficiencies
00:11:41,399 -- 00:11:43,401
that we've seen in the marketplace.
00:11:43,401 -- 00:11:47,171
And I do believe that when those deficiencies get corrected
00:11:47,171 -- 00:11:48,439
and when those deficiencies
00:11:48,439 -- 00:11:51,275
get corrected for the consumers at large,
00:11:51,275 -- 00:11:53,444
that is when, just not a regulator,
00:11:53,444 -- 00:11:56,347
but we as an entire industry,
00:11:56,347 -- 00:12:00,017
can claim to have achieved some kind of superpower,
00:12:00,017 -- 00:12:01,619
a superpower that will come
00:12:01,619 -- 00:12:04,655
from doing the right thing by the consumer
00:12:04,655 -- 00:12:06,891
and taking care of the promises
00:12:06,891 -- 00:12:08,159
that we all have made,
00:12:08,159 -- 00:12:09,660
either as a regulator
00:12:09,660 -- 00:12:13,598
or as an industry member, insurance company, or MGA.
00:12:13,598 -- 00:12:16,867
So that is what I think is the role of a regulator,
00:12:16,867 -- 00:12:19,170
an aspiration to be a superpower
00:12:19,170 -- 00:12:20,805
by collaborating with all of you.
00:12:22,540 -- 00:12:23,474
Thanks, Swati.
00:12:23,474 -- 00:12:24,742
Kim, you were going to jump in
00:12:24,742 -- 00:12:28,112
and talk about your superpower as a company.
00:12:28,112 -- 00:12:30,081
Don't have superpower written on my sheet here,
00:12:30,081 -- 00:12:32,850
but I do like the analogy.
00:12:32,850 -- 00:12:34,118
I'm going to look for that memento.
00:12:34,118 -- 00:12:36,420
I think the only one that I've received from a compliance
00:12:36,420 -- 00:12:38,255
perspective is a mug that says,
00:12:38,255 -- 00:12:41,859
don't make me use my compliance voice.
00:12:41,859 -- 00:12:45,696
Which my daughter would attribute to as my mom voice.
00:12:45,696 -- 00:12:46,597
So anyway,
00:12:46,597 -- 00:12:48,399
thank you for the opportunity
00:12:48,399 -- 00:12:51,369
to be here and speak with you today.
00:12:51,369 -- 00:12:54,005
And really enjoy, presenting.
00:12:54,005 -- 00:12:56,907
And it's great to be here with my colleagues.
00:12:56,907 -- 00:12:58,943
So from an insurance company perspective,
00:12:58,943 -- 00:13:03,114
obviously we are one component of that distribution.
00:13:03,114 -- 00:13:05,549
And, you know, what are we supposed to have?
00:13:05,549 -- 00:13:06,517
We heard it this morning,
00:13:06,517 -- 00:13:09,920
a reasonably designed compliance program.
00:13:09,920 -- 00:13:11,889
Well, what does that mean?
00:13:11,889 -- 00:13:13,124
How does that operate?
00:13:13,124 -- 00:13:15,459
How do we take the fair treatment of customers
00:13:15,459 -- 00:13:17,695
into consideration, as we're looking at that?
00:13:19,397 -- 00:13:20,998
We've talked about it,
00:13:20,998 -- 00:13:22,133
like my programs,
00:13:22,133 -- 00:13:24,034
Manulife are designed around screening,
00:13:24,034 -- 00:13:27,371
monitoring and reporting advisors.
00:13:27,371 -- 00:13:31,609
Part of that is educating them,
00:13:31,609 -- 00:13:33,310
talking to them.
00:13:33,310 -- 00:13:34,111
Unfortunately,
00:13:34,111 -- 00:13:36,280
a lot of it is about examining
00:13:36,280 -- 00:13:39,583
issues and challenges that present to us.
00:13:39,583 -- 00:13:41,619
But I would say specifically in relation
00:13:41,619 -- 00:13:46,590
to FTC expectations and yes, I owe $5.
00:13:46,891 -- 00:13:49,293
it's a lot of it's been education
00:13:49,293 -- 00:13:51,729
because I don't think that they saw that
00:13:51,729 -- 00:13:53,631
as something new for them.
00:13:53,631 -- 00:13:54,732
That's what they were doing.
00:13:54,732 -- 00:13:57,568
That's what they do when they sit in front of customers,
00:13:57,568 -- 00:13:59,770
is they believe that they treat them fairly.
00:13:59,770 -- 00:14:01,872
So it was about embedding that language
00:14:01,872 -- 00:14:03,440
in our code of conduct
00:14:03,440 -- 00:14:07,578
in the business reviews that we do with advisors.
00:14:07,578 -- 00:14:10,881
And then internally at Manulife,
00:14:10,881 -- 00:14:13,450
a lot of it was about education
00:14:13,450 -- 00:14:16,987
from start to finish, that entire customer journey.
00:14:16,987 -- 00:14:20,357
So from product design and understanding
00:14:20,357 -- 00:14:22,493
who the best person is for our customer, or,
00:14:22,493 -- 00:14:24,295
for that particular product,
00:14:24,295 -- 00:14:27,731
through to, the marketing materials,
00:14:27,731 -- 00:14:33,304
to training on that product, to claims, to then,
00:14:34,071 -- 00:14:37,207
you know, complaints and issues along those lines.
00:14:37,207 -- 00:14:39,677
So it's really been an integration,
00:14:39,677 -- 00:14:42,346
of a lot of factors over the last number of years
00:14:42,346 -- 00:14:43,847
to ensure that they're all there.
00:14:45,849 -- 00:14:48,585
And during audits and reviews, it's validating,
00:14:48,585 -- 00:14:50,821
you know, that our advisors are understanding it.
00:14:50,821 -- 00:14:53,424
It's helping our MGAs understand it.
00:14:53,424 -- 00:14:55,259
I think that when the language first came out,
00:14:55,259 -- 00:14:58,262
it wasn't necessarily well understood.
00:14:58,262 -- 00:15:00,064
But we've had lots of opportunity
00:15:00,064 -- 00:15:01,498
for discussion and dialogue.
00:15:01,498 -- 00:15:06,103
So we're flexing our superpowers, our wings.
00:15:06,103 -- 00:15:09,473
Is that a good one? Okay.
00:15:09,473 -- 00:15:10,374
Thanks, Kim.
00:15:10,374 -- 00:15:12,943
Eric, do you want to jump in from the MGA
00:15:12,943 -- 00:15:14,211
and agent perspective?
00:15:14,211 -- 00:15:16,046
Yeah, and it's great,
00:15:16,046 -- 00:15:18,615
just to echo, it's great to be on this
00:15:18,615 -- 00:15:21,718
end to end distribution panel here,
00:15:21,718 -- 00:15:23,220
for this important discussion.
00:15:23,220 -- 00:15:25,656
So, you know, for the most part,
00:15:25,656 -- 00:15:27,591
MGAs are not client facing.
00:15:27,591 -- 00:15:28,025
You know,
00:15:28,025 -- 00:15:29,526
we heard Mark White this morning
00:15:29,526 -- 00:15:32,796
talk about how not many consumers know what FSRA is yet.
00:15:32,796 -- 00:15:34,965
And I think even less consumers know
00:15:34,965 -- 00:15:37,534
what a Managing General Agency is.
00:15:37,534 -- 00:15:40,337
So but in terms of the role of MGAs
00:15:40,337 -- 00:15:43,373
in promoting positive FTC outcomes,
00:15:43,373 -- 00:15:45,943
three simple words, right? Knowing our advisor,
00:15:47,544 -- 00:15:49,513
we recognize that the carrier,
00:15:49,513 -- 00:15:51,548
you know, Manulife or whoever
00:15:51,548 -- 00:15:53,483
it is, has a powerful lens
00:15:53,483 -- 00:15:55,052
into the type of cases
00:15:55,052 -- 00:15:57,487
that an advisor is writing with them,
00:15:57,487 -- 00:15:59,623
but with MGAs, to the extent
00:15:59,623 -- 00:16:00,924
that we have advisors
00:16:00,924 -- 00:16:05,329
who have multiple carrier contracts with us, you know,
00:16:05,329 -- 00:16:07,464
certainly we have a wider lens
00:16:07,464 -- 00:16:11,234
into the business practices of that advisor, their trends,
00:16:11,234 -- 00:16:13,904
their knowledge of FTC
00:16:13,904 -- 00:16:17,107
and the unique challenges they may be,
00:16:17,107 -- 00:16:18,809
facing.
00:16:18,809 -- 00:16:20,077
Excuse me.
00:16:20,077 -- 00:16:22,713
So, you know, what are we doing to promote FTC?
00:16:22,713 -- 00:16:24,581
Well, like, one word Kim used
00:16:24,581 -- 00:16:27,184
there was training and education.
00:16:27,184 -- 00:16:29,686
So this is on the proactive side, right?
00:16:29,686 -- 00:16:32,823
As MGAs, we offer training and education.
00:16:32,823 -- 00:16:35,258
Which advisors are attending those?
00:16:35,258 -- 00:16:37,427
And certainly it's, it's also a boon
00:16:37,427 -- 00:16:39,930
if you have online training in education.
00:16:39,930 -- 00:16:44,000
So you can easily draw up reports of who's attending,
00:16:44,000 -- 00:16:46,336
how long they're taking on each course.
00:16:46,336 -- 00:16:50,073
Did they finish the compliance course and earn the CE credit
00:16:50,073 -- 00:16:51,007
at the end of that?
00:16:51,007 -- 00:16:52,642
But it's a good indicator
00:16:52,642 -- 00:16:55,946
to us to see, you know, who is attending these courses,
00:16:55,946 -- 00:16:57,080
who's taking an interest,
00:16:57,080 -- 00:16:58,648
who's engaged in them and who's not.
00:17:00,283 -- 00:17:00,650
Similarly,
00:17:00,650 -- 00:17:01,718
who's, who's
00:17:01,718 -- 00:17:05,822
utilizing the MGAs, the tools, the compliance tools
00:17:05,822 -- 00:17:09,526
and resources that we offer as an MGA and,
00:17:09,526 -- 00:17:10,961
you know, the, the
00:17:10,961 -- 00:17:11,661
the tools
00:17:11,661 -- 00:17:14,097
that promote frequent client contact,
00:17:14,097 -- 00:17:17,300
like client electronic newsletters,
00:17:17,300 -- 00:17:21,404
client relationship management software,
00:17:21,404 -- 00:17:24,174
and all the different cybersecurity tools
00:17:24,174 -- 00:17:27,010
that advisors can adopt in their practice.
00:17:27,010 -- 00:17:31,348
So is the advisor or are the advisors aligned with our MGA?
00:17:31,348 -- 00:17:34,184
You know, are they largely absent from engaging on these?
00:17:34,184 -- 00:17:35,952
And, and that's not automatically
00:17:35,952 -- 00:17:37,521
an indicator that there's a problem.
00:17:37,521 -- 00:17:40,824
But, you know, some advisors are an island unto themselves.
00:17:40,824 -- 00:17:44,227
And some of the most professional advisors are like that.
00:17:44,227 -- 00:17:46,863
But it's still something for us to,
00:17:46,863 -- 00:17:47,163
you know,
00:17:47,163 -- 00:17:48,498
keep an eye on
00:17:48,498 -- 00:17:53,003
and, and, and celebrate the advisors who are participating.
00:17:53,003 -- 00:17:58,008
And one positive thing I can say through the MGA lens
00:17:58,041 -- 00:18:04,114
is increasingly we have advisors or advisor groups or AGAs,
00:18:05,148 -- 00:18:06,216
who will
00:18:06,216 -- 00:18:07,083
ask us to come and
00:18:07,083 -- 00:18:09,786
present to them, you know, can we do a luncheon learn?
00:18:09,786 -- 00:18:12,922
That didn't used to happen even 3 to 5 years ago. Rarely
00:18:12,922 -- 00:18:14,557
it happened. Now...
00:18:14,557 -- 00:18:17,594
So it's, it's just an example of, like Kim said,
00:18:17,594 -- 00:18:20,697
FTC like advisors thought they knew what it was,
00:18:20,697 -- 00:18:24,367
but they're getting a better picture of what it is now.
00:18:24,367 -- 00:18:26,036
And they're engaged.
00:18:26,036 -- 00:18:30,340
So another thing MGAs can do in our role to promote FTC
00:18:30,340 -- 00:18:32,442
on the proactive side is
00:18:32,442 -- 00:18:34,044
the advisor practice reviews
00:18:34,044 -- 00:18:36,379
that insurance companies are doing on advisors.
00:18:36,379 -- 00:18:40,550
You know, at our MGA, we've had almost 300 advisors
00:18:40,550 -- 00:18:41,317
and mainstream
00:18:41,317 -- 00:18:42,952
advisors who are producing, who,
00:18:42,952 -- 00:18:46,790
who have been subject to an advisor practice review.
00:18:46,790 -- 00:18:48,158
And again,
00:18:48,158 -- 00:18:48,458
you know,
00:18:48,458 -- 00:18:50,760
we celebrate the successes, the advisors
00:18:50,760 -- 00:18:53,063
that pass those reviews with flying colors,
00:18:53,063 -- 00:18:55,465
you know, all green, all greens on their report.
00:18:56,499 -- 00:18:59,002
But, you know, we want to look at that and see is
00:18:59,002 -- 00:19:01,204
are there any gaps, did the advisor fail
00:19:01,204 -- 00:19:03,740
certain sections of that APR?
00:19:03,740 -- 00:19:06,576
Do they need to utilize some of our tools and templates
00:19:06,576 -- 00:19:09,446
and adopt them in the practice?
00:19:09,446 -- 00:19:12,048
And, you know, we view this as an opportunity
00:19:12,048 -- 00:19:13,349
to get in front of the advisor
00:19:13,349 -- 00:19:15,785
with our business development executives
00:19:15,785 -- 00:19:19,289
and, underline with them the importance of these APRs
00:19:19,289 -- 00:19:20,423
and passing them.
00:19:20,423 -- 00:19:23,359
And just anecdotally, another thing, positive thing
00:19:23,359 -- 00:19:25,495
that's come out of those is,
00:19:25,495 -- 00:19:26,129
you know, we
00:19:26,129 -- 00:19:27,197
I heard this morning
00:19:27,197 -- 00:19:29,732
succession planning and advisors who are aging
00:19:29,732 -- 00:19:32,168
and occasionally a, you know, an advisor,
00:19:32,168 -- 00:19:34,504
perhaps an older advisor goes through
00:19:34,504 -- 00:19:37,307
an advisor practice review and does not pass.
00:19:37,307 -- 00:19:39,275
And when we engage with that advisor,
00:19:39,275 -- 00:19:42,645
we realize it was almost a silent cry for help.
00:19:42,645 -- 00:19:44,881
Like they, they want to retire.
00:19:44,881 -- 00:19:46,783
They're just very loyal to their clients.
00:19:46,783 -- 00:19:49,385
They're not really keeping up with their knowledge.
00:19:49,385 -- 00:19:52,956
And they need our help with succession planning
00:19:52,956 -- 00:19:56,025
or what we a more positive spin we put on it is,
00:19:56,025 -- 00:19:57,860
business continuity
00:19:57,860 -- 00:19:58,328
planning,
00:19:58,328 -- 00:20:00,296
because that way the older advisor feels like
00:20:00,296 -- 00:20:03,700
I can stay involved in continuing,
00:20:03,700 -- 00:20:06,169
this service for my clients, but perhaps align them.
00:20:06,169 -- 00:20:09,105
And it's great when, when, MGAs
00:20:09,105 -- 00:20:11,074
we can start thinking about that
00:20:11,074 -- 00:20:13,409
and introducing older advisors
00:20:13,409 -- 00:20:15,445
to younger advisors and various programs.
00:20:15,445 -- 00:20:17,814
So a couple other things I can state,
00:20:17,814 -- 00:20:20,950
but I want to give Robert a chance to talk. So.
00:20:25,388 -- 00:20:29,692
Thank you very much.
00:20:29,692 -- 00:20:32,662
I promised Erica I wouldn't wrapper saying so.
00:20:32,662 -- 00:20:34,997
I’ll hold that because she's giving me the eyeball right now.
00:20:34,997 -- 00:20:38,935
Like, don't you dare.
00:20:38,935 -- 00:20:40,503
The beauty of going,
00:20:40,503 -- 00:20:42,672
last when you have such brilliant colleagues,
00:20:42,672 -- 00:20:44,607
presenting ahead is I could basically just say ditto
00:20:44,607 -- 00:20:48,344
like that. You know, that's. I agree with all of you.
00:20:48,344 -- 00:20:49,579
From an agent perspective
00:20:49,579 -- 00:20:51,214
that was mentioned earlier, as you know,
00:20:51,214 -- 00:20:54,984
there are 66,000 agents in the Ontario space right now.
00:20:54,984 -- 00:20:59,322
And I have a wonderful, strong team of ten.
00:20:59,322 -- 00:21:02,558
So what we have to look at and what the focus has been
00:21:02,558 -- 00:21:02,925
and what
00:21:02,925 -- 00:21:05,361
we're looking at end to end distribution is
00:21:05,361 -- 00:21:08,397
we have to look at who's at the front line at 66,000.
00:21:08,397 -- 00:21:11,200
So we need to make sure that suitability
00:21:11,200 -- 00:21:13,569
of an agent to be licensed is a priority.
00:21:13,569 -- 00:21:16,005
Suitability of the sale has to be a priority.
00:21:16,005 -- 00:21:18,140
And how do we demonstrate
00:21:18,140 -- 00:21:21,210
what is working and what's not working? And that's to be,
00:21:22,712 -- 00:21:25,615
you know, evidence informed and risk based.
00:21:25,615 -- 00:21:28,584
So we focus our resources to where the risk is greatest.
00:21:28,584 -- 00:21:32,388
We have clear and concise evidence that gets reported
00:21:32,388 -- 00:21:36,425
transparently and is shared amongst everybody in this room.
00:21:36,425 -- 00:21:37,660
So we can all compare notes
00:21:37,660 -- 00:21:39,996
and say we're seeing that to where we're not seeing that,
00:21:39,996 -- 00:21:41,864
or even the perhaps this is the anomaly.
00:21:41,864 -- 00:21:43,966
So I think that's one of the major changes we're seeing
00:21:43,966 -- 00:21:47,303
is that incredibly collaborative approach to being,
00:21:47,303 -- 00:21:48,904
you know, a very evidence focused,
00:21:48,904 -- 00:21:53,909
focused, compliance industry, not just regulator.
00:21:54,176 -- 00:21:55,111
Thanks, Robert.
00:21:55,111 -- 00:21:58,714
And, you know, the evil I worked as I was,
00:21:58,714 -- 00:21:59,081
it's,
00:21:59,081 -- 00:21:59,949
my superpower
00:21:59,949 -- 00:22:03,152
today is supposed to be keeping this panel on time.
00:22:03,152 -- 00:22:05,221
And, so far, so good.
00:22:05,221 -- 00:22:06,722
So,
00:22:06,722 -- 00:22:09,659
thanks, everyone, for your comments on that question.
00:22:09,659 -- 00:22:12,762
And, why don't we move it along?
00:22:12,762 -- 00:22:16,265
This kind of builds on this concept of,
00:22:16,265 -- 00:22:20,803
end to end oversight and fair treatment of consumers.
00:22:20,803 -- 00:22:23,305
When we look at Life and Health Insurance,
00:22:23,305 -- 00:22:24,807
really, you know, one of the key
00:22:24,807 -- 00:22:27,610
defining aspects of the products
00:22:27,610 -- 00:22:29,545
are that they're very long term
00:22:29,545 -- 00:22:31,747
in nature, generally speaking.
00:22:31,747 -- 00:22:33,015
And it's vital
00:22:33,015 -- 00:22:36,519
then that consumers are able to access advice
00:22:36,519 -- 00:22:38,521
to ensure that the products
00:22:38,521 -- 00:22:39,288
that they purchase
00:22:39,288 -- 00:22:40,956
today are suitable
00:22:40,956 -- 00:22:44,894
and will be there to protect their, future financial needs.
00:22:44,894 -- 00:22:46,562
So if we think about that role,
00:22:46,562 -- 00:22:47,096
that key
00:22:47,096 -- 00:22:48,230
role that Life and Health
00:22:48,230 -- 00:22:51,400
Insurance has in ensuring the financial security
00:22:51,400 -- 00:22:53,369
of so many Ontarians,
00:22:53,369 -- 00:22:54,804
how has your approach
00:22:54,804 -- 00:22:58,207
to ensuring that customers are treated fairly evolved
00:22:58,207 -- 00:23:03,179
since the CCIR and FSRA Guidances were adopted?
00:23:03,279 -- 00:23:06,148
Eric, I think you were going to kick us off here.
00:23:06,148 -- 00:23:06,916
Yeah, sure.
00:23:06,916 -- 00:23:10,753
So, you know, we I talked about the training and education.
00:23:10,753 -- 00:23:12,154
Well, that's only increasing.
00:23:12,154 -- 00:23:13,722
I know at many MGAs
00:23:13,722 -- 00:23:16,625
and in conjunction with our carrier partners,
00:23:16,625 -- 00:23:17,393
holding events,
00:23:18,427 -- 00:23:19,929
and then taking a great interest
00:23:19,929 -- 00:23:21,931
in advisor APRs,
00:23:21,931 -- 00:23:25,467
which the frequency of which are only going to increase.
00:23:25,467 -- 00:23:29,939
So two other things is, is the staff training
00:23:29,939 -- 00:23:31,307
at the MGA level.
00:23:31,307 -- 00:23:35,210
So all MGAs, you know, we have new business staff
00:23:35,210 -- 00:23:40,215
and, you know, just having more and more frequent,
00:23:41,317 -- 00:23:42,851
training sessions with our staff
00:23:42,851 -- 00:23:46,422
so that they start to adopt that compliance lens
00:23:46,422 -- 00:23:48,657
when they're, when they're ingesting business
00:23:48,657 -- 00:23:50,092
into our systems.
00:23:50,092 -- 00:23:51,660
So teaching them how to do that,
00:23:51,660 -- 00:23:53,362
and certainly many of the MGAs
00:23:53,362 -- 00:23:55,431
that I'm involved with at CAILBA,
00:23:55,431 -- 00:23:58,400
will use a model where each Case Coordinator
00:23:58,400 -- 00:23:59,802
or Case Specialist
00:23:59,802 -- 00:24:01,403
who ingests business,
00:24:01,403 -- 00:24:02,738
you know, receives it
00:24:02,738 -- 00:24:04,006
and puts it into our own system
00:24:04,006 -- 00:24:06,308
and forwards it on to the carriers,
00:24:06,308 -- 00:24:08,744
that they deal with their own group of advisors.
00:24:08,744 -- 00:24:10,245
So whether it's 100 advisors
00:24:10,245 -- 00:24:11,613
or 150 advisors,
00:24:11,613 -- 00:24:13,749
so they start to know their advisors
00:24:13,749 -- 00:24:15,984
trends, their ups, their downs.
00:24:15,984 -- 00:24:18,087
And, and that's a good model to adapt.
00:24:18,087 -- 00:24:20,055
But getting back, I'm
00:24:20,055 -- 00:24:21,790
not going to get into a whole checklist of,
00:24:21,790 -- 00:24:23,025
you know, what,
00:24:23,025 -- 00:24:24,727
a Case Coordinator will do
00:24:24,727 -- 00:24:26,895
when they receive a piece of business.
00:24:26,895 -- 00:24:28,464
But just teaching them things
00:24:28,464 -- 00:24:30,332
about like, little warning flags
00:24:30,332 -- 00:24:34,036
that may require them to flag that up to compliance
00:24:34,036 -- 00:24:35,904
or to the business
00:24:35,904 -- 00:24:38,941
Development Executive who works with that advisor.
00:24:38,941 -- 00:24:39,675
So things like,
00:24:40,642 -- 00:24:43,245
client income to premium ratio,
00:24:43,245 -- 00:24:45,914
you know, is it, is it looking very, very high.
00:24:45,914 -- 00:24:47,616
So the premium for this case is
00:24:47,616 -- 00:24:49,685
is it a very large percent of that client's
00:24:49,685 -- 00:24:51,386
gross income.
00:24:51,386 -- 00:24:54,990
High rates of return quoted on universal life,
00:24:54,990 -- 00:24:56,358
especially if it's YRT
00:24:56,358 -- 00:24:57,826
and if there's a guaranteed early
00:24:57,826 -- 00:25:01,497
or if there's an illustrated early off set of payment.
00:25:01,497 -- 00:25:03,098
You know, the, or even something
00:25:03,098 -- 00:25:06,068
as mundane as, are all the health questions always answered?
00:25:06,068 -- 00:25:07,536
No.
00:25:07,536 -- 00:25:10,405
You know, is the advisor maybe getting lazy,
00:25:10,405 -- 00:25:12,908
looking at these and just kind of rushing to the end.
00:25:12,908 -- 00:25:15,577
So we view these as opportunities,
00:25:15,577 -- 00:25:16,612
you know, to,
00:25:16,612 -- 00:25:18,146
to get in front of advisors,
00:25:18,146 -- 00:25:19,481
especially with, again,
00:25:19,481 -- 00:25:21,350
from the business development executive
00:25:21,350 -- 00:25:22,985
just to do a temperature check.
00:25:22,985 -- 00:25:25,687
Hey, we noticed this and we noticed that. And guess what?
00:25:25,687 -- 00:25:27,189
If we're noticing it,
00:25:27,189 -- 00:25:29,191
probably Kim's team is noticing
00:25:29,191 -- 00:25:30,859
it too at the carrier level.
00:25:30,859 -- 00:25:33,295
So you know, you're going down a path here
00:25:33,295 -- 00:25:36,031
that you may be engaging in self harm.
00:25:36,031 -- 00:25:38,533
And this might not have good outcomes for the client too.
00:25:38,533 -- 00:25:40,068
So maybe we need a reset here.
00:25:40,068 -- 00:25:42,337
So, it's a, it's a great opportunity
00:25:42,337 -- 00:25:46,008
for us to increase the frequency of those contacts.
00:25:46,008 -- 00:25:48,744
And with our advisors get in front of them
00:25:48,744 -- 00:25:51,346
sometimes help them with some corrective actions,
00:25:51,346 -- 00:25:54,383
point them to a course they can take to get up to speed.
00:25:55,450 -- 00:25:56,618
And by the way, I,
00:25:56,618 -- 00:25:56,885
you know,
00:25:56,885 -- 00:25:58,220
I feel like,
00:25:58,220 -- 00:25:59,888
at the insurance company level two
00:25:59,888 -- 00:26:02,124
at their business ingestion departments.
00:26:02,124 -- 00:26:05,160
That's not a bad thing at that level as well for,
00:26:05,160 -- 00:26:07,529
you know, new business people to understand that,
00:26:07,529 -- 00:26:08,663
yes, administratively,
00:26:08,663 -- 00:26:10,132
you know, you're doing this function,
00:26:10,132 -- 00:26:13,068
but there are key flags you can,
00:26:13,068 -- 00:26:16,338
you can raise with your manager as well.
00:26:16,338 -- 00:26:17,973
You know, these reasonability tests.
00:26:17,973 -- 00:26:22,477
So, so that can help improve, FTC outcomes.
00:26:22,477 -- 00:26:26,047
And then the second thing I talked about reactively
00:26:26,047 -- 00:26:30,786
is careful and organized complaint tracking.
00:26:30,786 -- 00:26:31,186
Okay.
00:26:31,186 -- 00:26:32,320
So, you know,
00:26:32,320 -- 00:26:35,924
looking for advisor trends, AGA trends
00:26:35,924 -- 00:26:38,026
or even just market trends.
00:26:38,026 -- 00:26:38,393
You know,
00:26:38,393 -- 00:26:39,127
is there
00:26:39,127 -- 00:26:41,696
a certain advisor that's had a complaint
00:26:41,696 -- 00:26:44,266
from two different insurance companies?
00:26:44,266 -- 00:26:45,834
Is there an AGA
00:26:45,834 -- 00:26:47,435
where they
00:26:47,435 -- 00:26:49,271
there's some complaints coming in
00:26:49,271 -- 00:26:52,374
pertinent to advisors with that AGA?
00:26:52,374 -- 00:26:53,875
Or is there just a certain product,
00:26:53,875 -- 00:26:55,277
like the new chargeback series,
00:26:55,277 -- 00:26:57,546
or are we noticing complaints with that?
00:26:57,546 -- 00:26:58,547
So, you know,
00:26:58,547 -- 00:27:00,515
we try to, at RGA,
00:27:00,515 -- 00:27:01,583
we try to follow,
00:27:01,583 -- 00:27:03,285
you know, categorize complaints similar
00:27:03,285 -- 00:27:05,720
to what Robert's team would do.
00:27:05,720 -- 00:27:08,557
So you know, our, our categories, our business practice.
00:27:08,557 -- 00:27:10,158
So is this a business practice complaint?
00:27:10,158 -- 00:27:14,829
Something to do with privacy, EML, or, or something like that.
00:27:14,829 -- 00:27:17,365
Is it a financial stability complaint?
00:27:17,365 -- 00:27:18,566
You know, is, is a carrier
00:27:19,801 -- 00:27:21,102
emailing us saying
00:27:21,102 -- 00:27:24,639
so-and-so advisors credit score has fallen below 600?
00:27:24,639 -- 00:27:28,476
Can you please talk to the advisor, see what's happening?
00:27:28,476 -- 00:27:30,312
Is it a license and E&O complaint?
00:27:30,312 -- 00:27:33,448
You know, did a carrier, did, did an advisor write a case
00:27:33,448 -- 00:27:36,084
out of their province of license?
00:27:36,084 -- 00:27:38,486
Or was there a lapse in, you know, something like that?
00:27:38,486 -- 00:27:40,955
And then, is it a market conduct complaint?
00:27:40,955 -- 00:27:43,591
You know, just the overall conduct to the advisor?
00:27:43,591 -- 00:27:48,029
Or a sales practice, specific to a sale?
00:27:48,029 -- 00:27:50,098
So, you know, by looking at these things
00:27:50,098 -- 00:27:51,666
and I just have to say, a
00:27:51,666 -- 00:27:53,601
complaint may be too strong a word.
00:27:53,601 -- 00:27:54,903
Maybe it's not the best word
00:27:54,903 -- 00:27:59,708
because there's low, medium, high level complaints.
00:27:59,708 -- 00:28:02,977
You know, generally traditionally a complaint is a client
00:28:02,977 -- 00:28:05,280
is unhappy with the performance of a product.
00:28:05,280 -- 00:28:08,049
Maybe it's a Manulife product. They call Manulife.
00:28:08,049 -- 00:28:10,185
Kim's team calls our team.
00:28:10,185 -- 00:28:12,854
We go get the advisor file. Okay.
00:28:12,854 -- 00:28:14,055
Not a single you out.
00:28:14,055 -- 00:28:15,890
I'm saying that never happens.
00:28:15,890 -- 00:28:17,859
It happens. No, not at all.
00:28:17,859 -- 00:28:20,562
But, you know, they can be advisor concerns.
00:28:20,562 -- 00:28:21,729
But my point
00:28:21,729 -- 00:28:23,798
is, you know, it's very important
00:28:23,798 -- 00:28:28,503
for us to track these and understand where the patterns are
00:28:28,503 -- 00:28:31,506
so that we can, again, have those corrective discussions
00:28:31,506 -- 00:28:34,142
or design some compliance programs
00:28:34,142 -- 00:28:36,344
to fill a gap that might be out there.
00:28:36,344 -- 00:28:39,848
So yeah, I think I'll leave it at that.
00:28:39,848 -- 00:28:42,283
Kim, do you want to jump in and sort of build
00:28:42,283 -- 00:28:45,753
on Eric's comments on MGAs with insurer initiatives?
00:28:45,753 -- 00:28:47,388
Sure, absolutely. Thanks, Erica.
00:28:47,388 -- 00:28:51,993
So since 2018 and I first met Swati, well,
00:28:51,993 -- 00:28:53,228
one of the first times,
00:28:53,228 -- 00:28:54,729
coming into the Manulife office
00:28:54,729 -- 00:28:56,798
to do a fair treatment of customers audit,
00:28:58,266 -- 00:28:59,634
lots of things have changed.
00:28:59,634 -- 00:29:03,404
We have a fair treatment of customers policy,
00:29:03,404 -- 00:29:07,542
that promotes the importance of that process from,
00:29:07,542 -- 00:29:09,277
as I said, through that customer journey.
00:29:09,277 -- 00:29:11,379
So the beginning of the product design
00:29:11,379 -- 00:29:16,384
right through to the complaints, and, and claims process.
00:29:17,118 -- 00:29:21,456
We've embedded language, as I mentioned earlier
00:29:21,456 -- 00:29:23,725
in our code of conduct, in our business practice
00:29:23,725 -- 00:29:26,494
reviews or advisor practice reviews.
00:29:26,494 -- 00:29:28,663
Same thing, different title,
00:29:28,663 -- 00:29:30,465
different acronym in this industry.
00:29:30,465 -- 00:29:34,936
But in into that work that we do with our advisors.
00:29:34,936 -- 00:29:36,437
We do have some courses,
00:29:36,437 -- 00:29:39,607
so we have a fair treatment of customers.
00:29:39,607 -- 00:29:44,579
CE Learning Center, one hour continuing education credit,
00:29:44,979 -- 00:29:48,816
on our website that,
00:29:48,816 -- 00:29:50,918
surprisingly gets like four
00:29:50,918 -- 00:29:53,287
and 500 views a year,
00:29:53,287 -- 00:29:56,424
which I think is absolutely fantastic.
00:29:56,424 -- 00:29:59,127
But some of the things that we've done internally,
00:29:59,127 -- 00:30:01,429
are, you know, things that you were chatting about,
00:30:01,429 -- 00:30:02,029
Eric, it's
00:30:02,029 -- 00:30:05,733
ensuring that the escalations from our complaints team
00:30:05,733 -- 00:30:08,536
or our underwriting teams or our sales
00:30:08,536 -- 00:30:12,173
teams are coming into the compliance area for
00:30:12,173 -- 00:30:13,741
evaluation and review.
00:30:15,076 -- 00:30:17,378
We have created an entire
00:30:17,378 -- 00:30:22,917
risk based methodology tool, that we are do...
00:30:22,917 -- 00:30:26,420
that we are using data from all sorts of areas in our business
00:30:26,420 -- 00:30:28,689
to then select the advisors
00:30:28,689 -- 00:30:31,659
that we might want to come out and visit.
00:30:31,659 -- 00:30:34,328
And we're proactively reaching out to our MGA partners.
00:30:34,328 -- 00:30:35,429
So to yourself, Eric,
00:30:35,429 -- 00:30:36,364
and to some of the others
00:30:36,364 -- 00:30:37,398
that are in the room
00:30:37,398 -- 00:30:38,099
to say
00:30:38,099 -- 00:30:40,134
we're going to go and do a business practice
00:30:40,134 -- 00:30:42,036
review with this particular advisor.
00:30:42,036 -- 00:30:43,938
Did you want to come in, hang out with us
00:30:43,938 -- 00:30:47,074
and go through this process with us?
00:30:47,074 -- 00:30:49,644
Most cases we're getting a positive yes.
00:30:49,644 -- 00:30:51,579
Which I think is, is an advantage
00:30:51,579 -- 00:30:53,314
because it's helping
00:30:53,314 -- 00:30:57,518
the MGAs understand the expectations that the insurers have.
00:30:57,518 -- 00:30:59,453
But as you point out, Eric, it's
00:30:59,453 -- 00:31:01,656
also giving the advisors that opportunity
00:31:01,656 -- 00:31:03,658
to put their hands up and say,
00:31:03,658 -- 00:31:05,593
we might need some more help, right?
00:31:05,593 -- 00:31:07,962
Or, we might need to be able to,
00:31:07,962 -- 00:31:09,096
you know, put some additional,
00:31:10,331 -- 00:31:15,336
templates in their office and things like that.
00:31:15,670 -- 00:31:17,905
Board reporting. It's Board
00:31:17,905 -- 00:31:20,107
reporting time, friends.
00:31:20,107 -- 00:31:23,477
It's like, everything I'm doing these days,
00:31:23,477 -- 00:31:26,614
we speak to fair treatment of customers.
00:31:26,614 -- 00:31:30,251
We have a new sales conduct risk metric
00:31:30,251 -- 00:31:31,752
that is going in our Board
00:31:31,752 -- 00:31:33,688
reporting for the very first time,
00:31:33,688 -- 00:31:36,023
this quarter, in 2024.
00:31:36,023 -- 00:31:40,327
This is a request both from OSFI and our Board.
00:31:40,327 -- 00:31:42,063
So we are taking information
00:31:42,063 -- 00:31:47,068
that is being collected globally about conduct,
00:31:47,334 -- 00:31:51,605
and putting risk statement in our Board report.
00:31:51,605 -- 00:31:55,843
I'll let you know what it says after we figured it out.
00:31:55,843 -- 00:31:57,278
because we're still in the process
00:31:57,278 -- 00:31:58,813
of gathering all of that data,
00:31:58,813 -- 00:32:01,816
but things that are included in that,
00:32:01,816 -- 00:32:03,651
which is really interesting,
00:32:03,651 -- 00:32:05,486
is complaints
00:32:05,486 -- 00:32:06,787
that we've kind of talked about here
00:32:06,787 -- 00:32:10,391
conduct issues, which, of course, we can all appreciate
00:32:10,391 -- 00:32:13,327
regulatory findings that are related to sales
00:32:13,327 -- 00:32:16,130
conduct and internal audit
00:32:16,130 -- 00:32:18,699
findings that are related to sales conduct.
00:32:18,699 -- 00:32:20,434
So all of these are newer things
00:32:20,434 -- 00:32:21,869
that we are putting into place.
00:32:23,671 -- 00:32:26,106
And the last thing that I would probably speak to
00:32:26,106 -- 00:32:28,642
is we have a new incentive committee.
00:32:28,642 -- 00:32:30,244
This is specifically
00:32:30,244 -- 00:32:32,980
come out of the various pieces of guidance
00:32:32,980 -- 00:32:35,749
that we've had around, fair treatment of customers.
00:32:35,749 -- 00:32:38,252
So Manulife has stood up and incentives committee.
00:32:38,252 -- 00:32:43,958
So, any new incentive programs, campaigns, time limited...
00:32:44,758 -- 00:32:48,662
Bonuses have to go through a committee approval.
00:32:48,662 -- 00:32:50,497
And then there is a tracking process
00:32:50,497 -- 00:32:52,433
because very selfishly,
00:32:52,433 -- 00:32:54,768
the Market Conduct team wants to ingest that.
00:32:54,768 -- 00:32:56,337
I would like to know when we are doing
00:32:56,337 -- 00:32:58,739
an investigation on the advisor, an advisor,
00:32:58,739 -- 00:33:01,809
whether or not they have received compensation
00:33:01,809 -- 00:33:04,678
that's above and beyond the regular grid.
00:33:04,678 -- 00:33:07,047
Did that inform their sales practices
00:33:07,047 -- 00:33:08,048
in a different fashion?
00:33:08,048 -- 00:33:09,984
So we're looking at those things,
00:33:09,984 -- 00:33:12,086
in a bit of a different way,
00:33:12,086 -- 00:33:15,689
using some technologies and some advancements to,
00:33:15,689 -- 00:33:18,125
to analyze all of that work.
00:33:18,125 -- 00:33:21,228
So, we're bored. Thanks Kim.
00:33:21,228 -- 00:33:23,364
So I think we've heard a lot of,
00:33:23,364 -- 00:33:24,598
from Kim and Eric
00:33:24,598 -- 00:33:25,366
about
00:33:25,366 -- 00:33:28,235
how their organizations have evolved
00:33:28,235 -- 00:33:28,702
in terms
00:33:28,702 -- 00:33:31,171
of some of the oversight practices and monitoring,
00:33:31,171 -- 00:33:34,708
but sometimes, sometimes
00:33:34,708 -- 00:33:36,877
practices get reported to the regulator.
00:33:36,877 -- 00:33:38,746
Robert, do you want to jump in
00:33:38,746 -- 00:33:40,814
and talk about the evolution of the LAMR?
00:33:42,649 -- 00:33:43,484
My favorite topic.
00:33:43,484 -- 00:33:45,219
And I could talk all afternoon and you know that.
00:33:45,219 -- 00:33:48,489
So please shut me down.
00:33:48,489 -- 00:33:52,593
So the LAMR or the Life Agent Misconduct report
00:33:52,593 -- 00:33:54,628
Some of you may recall something called a LARF,
00:33:54,628 -- 00:33:56,196
A Life Agent Reporting Form
00:33:56,196 -- 00:33:58,499
that's, document, an excellent document
00:33:58,499 -- 00:33:59,500
developed by the CLHIA.
00:33:59,500 -- 00:34:01,568
It's been in use for 20 plus years.
00:34:01,568 -- 00:34:03,637
The industry knows it well.
00:34:03,637 -- 00:34:06,507
The LARF is 24 data points.
00:34:06,507 -- 00:34:10,110
In the, in the main hall,
00:34:10,110 -- 00:34:12,846
we were hearing, you know, the obligations of the insurers,
00:34:12,846 -- 00:34:15,649
you know, to have a reasonable system of compliance,
00:34:15,649 -- 00:34:18,252
reasonable system of oversight of agents.
00:34:18,252 -- 00:34:19,887
And there's also a piece of the act that says
00:34:19,887 -- 00:34:22,756
that there is an obligation for insurance companies
00:34:22,756 -- 00:34:25,325
to report unsuitable agents to the regulator.
00:34:25,325 -- 00:34:27,327
And that's traditionally been done through the LARF
00:34:27,327 -- 00:34:29,596
as a convenient methodology.
00:34:29,596 -- 00:34:31,531
So the LAMR has been developed
00:34:31,531 -- 00:34:34,968
with a little bit more of a, of a FTC lens.
00:34:34,968 -- 00:34:38,472
So there's 141 data points in the LAMR.
00:34:38,472 -- 00:34:41,341
It's online, it’s convenient uploading all that sort of stuff.
00:34:41,341 -- 00:34:42,976
That's just a burden reduction thing.
00:34:42,976 -- 00:34:44,244
But I think what matters most
00:34:44,244 -- 00:34:48,982
is that there's 141 data points, to allow reporting.
00:34:48,982 -- 00:34:51,785
And we have done a lot of stakeholder
00:34:51,785 -- 00:34:53,787
engagement in the development of the LAMR
00:34:53,787 -- 00:34:55,188
as well as since we've launched it
00:34:55,188 -- 00:34:57,958
in terms of understanding what, what it means and what,
00:34:57,958 -- 00:35:00,227
and what the industries expectations of it are.
00:35:01,928 -- 00:35:03,797
So basically the question is, is like,
00:35:03,797 -- 00:35:05,332
do you want us to report this?
00:35:05,332 -- 00:35:06,433
Do you want to report to that?
00:35:06,433 -- 00:35:07,901
Do you want this every time?
00:35:07,901 -- 00:35:09,870
You know, I believe I've even heard.
00:35:09,870 -- 00:35:13,540
Be careful what you wish for. In terms of, like, what type?
00:35:13,540 -- 00:35:14,975
What's going to be reported?
00:35:14,975 -- 00:35:15,742
That might’ve been me.
00:35:15,742 -- 00:35:17,044
I, I'm pretty sure it was you.
00:35:17,044 -- 00:35:18,045
And I think that's why I said it
00:35:18,045 -- 00:35:20,981
while you're sitting right beside me. So,
00:35:20,981 -- 00:35:22,482
but basically
00:35:22,482 -- 00:35:23,050
a response
00:35:23,050 -- 00:35:25,685
that I've been given, I've been giving is
00:35:25,685 -- 00:35:26,853
you have an obligation
00:35:26,853 -- 00:35:28,522
for a reasonable system of compliance.
00:35:28,522 -- 00:35:31,224
You have an obligation to report an unsuitable agent.
00:35:31,224 -- 00:35:33,460
If you find an agent so unsuitable
00:35:33,460 -- 00:35:36,029
that you terminate their contract,
00:35:36,029 -- 00:35:37,798
we may want to hear about it.
00:35:37,798 -- 00:35:40,867
But what's also important is, is that the act only contains
00:35:40,867 -- 00:35:43,870
so many actionable items for us as well.
00:35:43,870 -- 00:35:45,305
So you could report something
00:35:45,305 -- 00:35:47,974
that may not meet that threshold of us
00:35:47,974 -- 00:35:50,377
being able to revoke a license, let's say.
00:35:50,377 -- 00:35:52,979
But it's still, a risk identifier.
00:35:52,979 -- 00:35:55,582
It still gives us pause to red flag
00:35:55,582 -- 00:35:57,717
to conduct an examination.
00:35:57,717 -- 00:35:58,451
but more importantly,
00:35:58,451 -- 00:36:00,587
it builds data on that particular topic.
00:36:01,855 -- 00:36:04,357
Those, that data that we build is
00:36:04,357 -- 00:36:05,892
something that will inform
00:36:05,892 -- 00:36:07,727
our proactive supervision programs,
00:36:07,727 -- 00:36:09,930
that will inform policy initiatives.
00:36:09,930 -- 00:36:13,266
But like I said previously to, it's all shared.
00:36:13,266 -- 00:36:14,768
We're publishing on all of this
00:36:14,768 -- 00:36:17,837
to say what we're finding to say. This isn't anecdotal.
00:36:17,837 -- 00:36:20,740
This isn't just, you know, the industry is seeing this.
00:36:20,740 -- 00:36:22,042
It's not just the regulator saying
00:36:22,042 -- 00:36:23,910
this is what the industry is reporting.
00:36:23,910 -- 00:36:25,345
So that's that collaborative approach
00:36:25,345 -- 00:36:27,113
that we're really, really seeing the change there.
00:36:27,113 -- 00:36:28,582
And so that the idea that,
00:36:28,582 -- 00:36:31,384
you know, this is FTC driven and it's principles-based
00:36:31,384 -- 00:36:32,619
regulation driven,
00:36:32,619 -- 00:36:36,856
I'm not asking you to fill out a prescriptive form.
00:36:36,856 -- 00:36:37,624
And here is that
00:36:37,624 -- 00:36:40,794
although there are checkboxes but it's not a checkbox,
00:36:40,794 -- 00:36:41,795
you know, a task.
00:36:41,795 -- 00:36:43,630
It is like, you know, report what works for you.
00:36:43,630 -- 00:36:45,131
So if you're reporting things, for example,
00:36:45,131 -- 00:36:47,067
like borrowing money from a client,
00:36:47,067 -- 00:36:49,202
strictly speaking, that's not a contravention of the act.
00:36:49,202 -- 00:36:51,504
But boy, it's a risk concern isn't it?
00:36:51,504 -- 00:36:52,739
And we want to hear about it.
00:36:52,739 -- 00:36:55,041
And I'm sure I know that most,
00:36:55,041 -- 00:36:56,943
if not all insurer contracts,
00:36:56,943 -- 00:36:58,211
sales contracts with their agents.
00:36:58,211 -- 00:36:59,145
You're says right there
00:36:59,145 -- 00:37:00,847
you're not allowed to borrow money from a client, right.
00:37:00,847 -- 00:37:02,749
That, one of many examples.
00:37:02,749 -- 00:37:05,018
So with that data now coming in through the LAMR, it's
00:37:05,018 -- 00:37:06,319
something we can report back.
00:37:06,319 -- 00:37:08,655
And again, sort of implementing those changes.
00:37:08,655 -- 00:37:09,322
That requires
00:37:09,322 -- 00:37:11,858
a 100% collaboration between the industry
00:37:11,858 -- 00:37:13,126
and a willingness to do that,
00:37:13,126 -- 00:37:15,428
because the industry could very easily to say,
00:37:15,428 -- 00:37:17,931
why would I report something you can't do anything about,
00:37:18,898 -- 00:37:20,233
which is fair comment.
00:37:20,233 -- 00:37:21,201
So we're just saying
00:37:21,201 -- 00:37:23,737
if we are FTC based as an industry,
00:37:23,737 -- 00:37:27,207
if we are principles-based as an industry,
00:37:27,207 -- 00:37:30,009
then we need to share this data
00:37:30,009 -- 00:37:32,378
to, to, to implement these changes that everybody
00:37:32,378 -- 00:37:34,681
wants to see, to protect consumers in the end.
00:37:34,681 -- 00:37:38,151
And the response has been amazing,
00:37:38,151 -- 00:37:38,618
to the point
00:37:38,618 -- 00:37:42,455
that, I mean, our, our landers have more than doubled
00:37:42,455 -- 00:37:45,492
since FSRA's inception and it's trending upwards as well.
00:37:45,492 -- 00:37:48,428
So thank you for,
00:37:48,428 -- 00:37:52,532
for sharing in the vision and participating in the vision.
00:37:52,532 -- 00:37:56,135
I just want a, a quick shout out for that, Robert.
00:37:56,135 -- 00:37:57,937
And I don't know how many in the audience
00:37:57,937 -- 00:37:59,472
from the MGA community
00:37:59,472 -- 00:38:02,275
or carrier community have filed a LAMR,
00:38:02,275 -- 00:38:06,412
but it's really not, egregious at all in terms of workload.
00:38:06,412 -- 00:38:09,215
So compliments to Robert's team
00:38:09,215 -- 00:38:12,852
who, who designed it and the responsiveness as well.
00:38:14,120 -- 00:38:15,655
We recently had to file a
00:38:15,655 -- 00:38:20,660
LAMR and heard back from Debbie Scott within 36 hours.
00:38:21,094 -- 00:38:25,031
So you know, the message there is, it's very easy to do.
00:38:25,031 -- 00:38:27,300
You don't have to psych yourself up, and,
00:38:27,300 -- 00:38:32,305
and FSRA is definitely responding to these, so kudos.
00:38:33,072 -- 00:38:33,906
Thanks, Eric.
00:38:33,906 -- 00:38:38,177
Now, our number of resources Robert will double to 20.
00:38:38,177 -- 00:38:41,948
Eric has put in a plug here for additional resources.
00:38:41,948 -- 00:38:43,082
So very effective.
00:38:43,082 -- 00:38:44,283
We'll get a lot more LAMRs,
00:38:44,283 -- 00:38:48,788
Eric, that's the bottom line, right?
00:38:48,788 -- 00:38:49,288
Thanks. Yeah.
00:38:49,288 -- 00:38:51,557
Just one last little thing as well is, you know,
00:38:51,557 -- 00:38:54,627
the regulation says insurers must report.
00:38:54,627 -- 00:38:56,829
It doesn't say MGAs, must report.
00:38:56,829 -- 00:38:58,831
And yet the MGAs are reporting,
00:38:58,831 -- 00:38:59,298
you know,
00:38:59,298 -- 00:39:01,267
they don't necessarily have safe harbour,
00:39:01,267 -- 00:39:02,468
but that it shows
00:39:02,468 -- 00:39:03,503
the level
00:39:03,503 -- 00:39:04,971
of commitment in the end
00:39:04,971 -- 00:39:06,406
distribution level to,
00:39:06,406 -- 00:39:08,508
you know, to support consumer protection,
00:39:08,508 -- 00:39:10,209
that I'm getting MGAs filing
00:39:10,209 -- 00:39:11,711
LAMRs. That's very rewarding.
00:39:11,711 -- 00:39:14,814
And it says a lot about, about the industry.
00:39:14,814 -- 00:39:16,516
Great. Thanks.
00:39:16,516 -- 00:39:17,683
And you know, Robert
00:39:17,683 -- 00:39:20,019
has some key members of his team here today
00:39:20,019 -- 00:39:22,522
who've been instrumental in developing the LAMR.
00:39:22,522 -- 00:39:26,559
So it's great to hear the feedback, through the panel.
00:39:26,559 -- 00:39:28,895
And, thanks to MGAs
00:39:28,895 -- 00:39:31,297
and insurers for continuing to file those with us.
00:39:31,297 -- 00:39:32,498
But we've got Sam,
00:39:32,498 -- 00:39:35,935
who's really been leading on developing the LAMR
00:39:35,935 -- 00:39:37,837
and Andy and Debbie in the room.
00:39:37,837 -- 00:39:39,405
So if you've got,
00:39:39,405 -- 00:39:44,410
more comments and questions about the LAMR as a tool,
00:39:44,410 -- 00:39:45,878
or how we're using it,
00:39:45,878 -- 00:39:47,947
you know, you've got great people to,
00:39:47,947 -- 00:39:50,049
consult with here today in the room.
00:39:51,083 -- 00:39:53,252
And I think the LAMR,
00:39:53,252 -- 00:39:54,220
Eric and Kim,
00:39:54,220 -- 00:39:56,289
your comments about how your programs
00:39:56,289 -- 00:39:56,889
have evolved,
00:39:56,889 -- 00:39:59,358
that really speaks to first,
00:39:59,358 -- 00:40:00,660
we heard it in the plenary,
00:40:00,660 -- 00:40:02,395
that role of data
00:40:02,395 -- 00:40:06,699
in terms of helping us to get an expert view
00:40:06,699 -- 00:40:08,367
of what's happening in the Life
00:40:08,367 -- 00:40:10,436
and Health Insurance sector,
00:40:10,436 -- 00:40:11,470
as a regulator,
00:40:11,470 -- 00:40:13,706
but also as insurers and MGAs
00:40:13,706 -- 00:40:16,042
and really assisting with both our proactive
00:40:16,042 -- 00:40:17,977
and reactive supervision.
00:40:17,977 -- 00:40:20,613
And it also, I think, speaks to,
00:40:20,613 -- 00:40:22,381
the evolution or kind of the journey
00:40:22,381 -- 00:40:25,718
that we're on with FTC and trying to get,
00:40:25,718 -- 00:40:28,854
fair outcomes for consumers.
00:40:28,854 -- 00:40:30,356
And I think that's so important
00:40:30,356 -- 00:40:32,325
because fair treatment of customers
00:40:32,325 -- 00:40:34,627
as a principal, as our North Star,
00:40:34,627 -- 00:40:35,227
we often say at FSRA,
00:40:35,227 -- 00:40:39,699
it really helps us to remember that behind every policy,
00:40:39,699 -- 00:40:40,566
there's a person
00:40:40,566 -- 00:40:42,101
and often a family
00:40:42,101 -- 00:40:45,971
and their own story and reason for needing insurance.
00:40:45,971 -- 00:40:48,874
And, so we've talked about kind of how we've evolved.
00:40:48,874 -- 00:40:51,077
Let's talk about, today's initiative.
00:40:51,077 -- 00:40:53,379
So what are your current priorities
00:40:53,379 -- 00:40:56,649
in relation to treating consumers fairly?
00:40:56,649 -- 00:40:59,285
And I think, Kim, you were going to jump off on this one.
00:40:59,285 -- 00:41:02,121
I was thanks, Erica. Yeah, absolutely.
00:41:02,121 -- 00:41:03,456
So, and we heard a lot about it
00:41:03,456 -- 00:41:05,257
this morning in the digital advancements
00:41:05,257 -- 00:41:08,627
and the use of AI and all of these tools.
00:41:08,627 -- 00:41:10,329
About three and a half years ago,
00:41:10,329 -- 00:41:12,631
I was really fortunate and hired,
00:41:12,631 -- 00:41:15,568
a gentleman on my team who is a data analyst.
00:41:15,568 -- 00:41:17,336
He's actually now a data scientist.
00:41:18,437 -- 00:41:20,906
And his role was to
00:41:20,906 -- 00:41:25,911
transform the way my department was doing work.
00:41:26,812 -- 00:41:30,649
We were very papers-based, paper-based.
00:41:30,649 -- 00:41:34,987
And we've moved to be very digital.
00:41:34,987 -- 00:41:39,892
Because as much as you have 66,000, I believe you said
00:41:39,892 -- 00:41:43,329
Manulife has over 100,000 just in Canada.
00:41:43,329 -- 00:41:46,065
That's a lot of advisors to have eyes on.
00:41:46,065 -- 00:41:48,200
So what better way to
00:41:48,200 -- 00:41:50,603
to do this in a more efficient manner,
00:41:50,603 -- 00:41:52,371
but to use technology.
00:41:52,371 -- 00:41:54,940
So we have a variety of graph
00:41:54,940 -- 00:41:57,009
analytics tools that we use
00:41:57,009 -- 00:42:00,312
that look to conflicts of interest.
00:42:00,312 -- 00:42:03,983
So if an advisor is the beneficiary on one policy,
00:42:03,983 -- 00:42:08,287
chances are they're likely the beneficiary on a few others.
00:42:08,287 -- 00:42:13,225
We can easily see that now. We use graph analytics to see
00:42:13,225 -- 00:42:18,397
is the advisor using their own IP address to DocuSign
00:42:19,598 -- 00:42:22,368
paperwork? Because electronic signatures
00:42:22,368 -- 00:42:25,237
have become the way we operate.
00:42:25,237 -- 00:42:26,605
You can buy a house
00:42:26,605 -- 00:42:28,641
with your electronic signature on a phone.
00:42:28,641 -- 00:42:30,809
That blows my mind, right?
00:42:30,809 -- 00:42:32,945
There's an importance behind your signature.
00:42:32,945 -- 00:42:34,480
We need to make sure that advisors
00:42:34,480 -- 00:42:37,049
and clients continue to understand that.
00:42:37,049 -- 00:42:41,820
So we've looked to use those advancements,
00:42:41,820 -- 00:42:44,490
for our monitoring and our oversight.
00:42:44,490 -- 00:42:46,258
We also look at it to see
00:42:46,258 -- 00:42:47,226
is this advisor
00:42:47,226 -- 00:42:48,260
just doing something
00:42:48,260 -- 00:42:51,029
that's really anomalous to the rest of the,
00:42:51,029 -- 00:42:52,664
to the community?
00:42:52,664 -- 00:42:54,967
And perhaps once we go and get the story,
00:42:54,967 -- 00:42:57,236
we go, great, thanks.
00:42:57,236 -- 00:42:58,804
You've got all the documentation.
00:42:58,804 -- 00:43:02,508
It really is an appropriate,
00:43:02,508 -- 00:43:04,710
based...needs-based sale.
00:43:04,710 -- 00:43:06,945
It works for that particular client
00:43:06,945 -- 00:43:08,280
or that particular community.
00:43:08,280 -- 00:43:09,882
And now we have no issues,
00:43:09,882 -- 00:43:13,085
but we've been proactively able to address that,
00:43:13,085 -- 00:43:16,388
with the advisor and the MGA in advance.
00:43:16,388 -- 00:43:19,958
So those are some pretty unique, ways
00:43:19,958 -- 00:43:23,028
that we've started to alter the way
00:43:23,028 -- 00:43:25,297
that we do our monitoring and our,
00:43:25,297 -- 00:43:28,066
our oversight of our advisors.
00:43:28,066 -- 00:43:30,602
I would tell you on my wish list for 2024
00:43:30,602 -- 00:43:33,805
is to advance our business practice review program
00:43:33,805 -- 00:43:35,741
or our internal audit program,
00:43:35,741 -- 00:43:37,709
the fact that we are in 2024
00:43:37,709 -- 00:43:41,046
and using an Excel spreadsheet just drives me crazy.
00:43:41,980 -- 00:43:43,749
So, you know, I've, I've
00:43:43,749 -- 00:43:44,349
got the team
00:43:44,349 -- 00:43:46,919
turning their mind to something along those lines
00:43:46,919 -- 00:43:48,353
that can be a little bit
00:43:48,353 -- 00:43:49,688
more interactive,
00:43:49,688 -- 00:43:52,991
that can use some of these lovely technologies
00:43:52,991 -- 00:43:53,959
to say, oh, well,
00:43:53,959 -- 00:43:55,594
we found the advisor
00:43:55,594 -- 00:43:57,296
doesn't know what we mean when we say,
00:43:57,296 -- 00:43:59,865
do you use your advisor disclosure
00:43:59,865 -- 00:44:02,134
and it automatically populates the findings
00:44:02,134 -- 00:44:03,502
so that the team isn't cutting
00:44:03,502 -- 00:44:05,437
and pasting for word documents.
00:44:05,437 -- 00:44:08,674
So, ask me a year from now how far we got
00:44:08,674 -- 00:44:09,708
and really hopeful
00:44:09,708 -- 00:44:11,476
that we're going to have some time
00:44:11,476 -- 00:44:15,213
this year to, to make some changes there.
00:44:15,213 -- 00:44:17,849
So I think that's maybe where I'll stop, Erica.
00:44:17,849 -- 00:44:18,684
Thanks, Kim.
00:44:18,684 -- 00:44:19,117
Swati,
00:44:19,117 -- 00:44:21,920
can you tie this into the work that we're doing at FSRA
00:44:21,920 -- 00:44:25,190
on the international stage, as well as our current MGA
00:44:25,190 -- 00:44:26,391
supervision priorities?
00:44:27,893 -- 00:44:28,760
Thanks, Erica.
00:44:28,760 -- 00:44:31,596
A lot of things, Kim, that you mentioned,
00:44:31,596 -- 00:44:34,933
I've heard it from Robert.
00:44:34,933 -- 00:44:38,170
It was like a déjà vu because it freaks him out
00:44:38,170 -- 00:44:40,172
to have Excel spreadsheets.
00:44:40,172 -- 00:44:43,041
When you said Excel, I got the shivers.
00:44:43,041 -- 00:44:44,810
And I know Sam and Debbie.
00:44:44,810 -- 00:44:46,378
They've been working very hard
00:44:46,378 -- 00:44:48,847
exactly to the mechanism that you mentioned.
00:44:48,847 -- 00:44:52,484
So we mentioned about LAMR as an evolution.
00:44:52,484 -- 00:44:54,686
I still think it's a continuing,
00:44:54,686 -- 00:44:55,821
you know, priority,
00:44:55,821 -- 00:44:58,356
which will take many different shapes and forms as
00:44:58,356 -- 00:45:02,027
and when we receive more from the industry.
00:45:02,027 -- 00:45:04,696
when we talk about the institutional side,
00:45:04,696 -- 00:45:07,332
there are two things that I would like to highlight.
00:45:07,332 -- 00:45:09,601
The first thing is, you know,
00:45:09,601 -- 00:45:13,505
I said that in the last five years we've been zooming in.
00:45:13,505 -- 00:45:15,307
So we look into insurance companies,
00:45:15,307 -- 00:45:16,508
we look into MGAs,
00:45:16,508 -- 00:45:18,477
we look into specific business models,
00:45:18,477 -- 00:45:21,046
we look into specific business practices.
00:45:21,046 -- 00:45:22,981
We've been reporting on that.
00:45:22,981 -- 00:45:25,817
So we keep like peeling the layers of an onion.
00:45:25,817 -- 00:45:28,186
You know, we are like zooming in, in, in.
00:45:28,186 -- 00:45:33,191
But now after five years, it's time that we also zoom out.
00:45:33,325 -- 00:45:34,326
And what I mean by
00:45:34,326 -- 00:45:39,497
zooming out is in Ontario, MGAs is not a specific
00:45:39,664 -- 00:45:41,499
licensing class.
00:45:41,499 -- 00:45:43,568
So we as regulators,
00:45:43,568 -- 00:45:44,469
you know, this morning
00:45:44,469 -- 00:45:46,638
we heard that we should be able to measure
00:45:46,638 -- 00:45:49,040
what we are about to monitor.
00:45:49,040 -- 00:45:51,409
We don't know who all the MGAs are.
00:45:51,409 -- 00:45:53,278
We don't know what their different business
00:45:53,278 -- 00:45:56,214
models are or what their product composition are.
00:45:56,214 -- 00:45:58,750
We don't know exactly which insurance companies
00:45:58,750 -- 00:46:00,986
are contracted with which MGAs.
00:46:00,986 -- 00:46:02,520
So I think as a regulator,
00:46:02,520 -- 00:46:05,824
it's very important for us to know what I call
00:46:05,824 -- 00:46:07,826
as our backyard, right?
00:46:07,826 -- 00:46:10,328
Because until we don't know what our backyard is,
00:46:10,328 -- 00:46:11,529
until we don't know what our
00:46:11,529 -- 00:46:12,330
universe is,
00:46:12,330 -- 00:46:14,799
until we don't know how we can measure
00:46:14,799 -- 00:46:18,803
what we are about to monitor, how are we going to proceed?
00:46:18,803 -- 00:46:19,471
Right.
00:46:19,471 -- 00:46:21,539
So that's one area
00:46:21,539 -- 00:46:24,342
that we are placing a lot of emphasis on.
00:46:24,342 -- 00:46:26,478
We are recently going to, you know,
00:46:26,478 -- 00:46:29,280
we just finished the design of a questionnaire,
00:46:29,280 -- 00:46:31,483
but we are going to launch this questionnaire
00:46:31,483 -- 00:46:32,984
and all the insurance companies
00:46:32,984 -- 00:46:34,853
here are going to receive it.
00:46:34,853 -- 00:46:37,255
Lynn, don't worry. Consultations are remaining.
00:46:37,255 -- 00:46:39,190
So we haven't disclosed that to you yet.
00:46:40,458 -- 00:46:41,126
But you all.
00:46:41,126 -- 00:46:43,461
Been busy this month. These not this month.
00:46:43,461 -- 00:46:43,828
Okay.
00:46:43,828 -- 00:46:45,630
We work with your schedule,
00:46:45,630 -- 00:46:49,167
But we will be working with a lot of you in this room
00:46:49,167 -- 00:46:50,835
to actually,
00:46:50,835 -- 00:46:52,704
you know, consult on that questionnaire,
00:46:52,704 -- 00:46:55,240
which is actually going to give us intelligence
00:46:55,240 -- 00:46:57,609
about what's happening in the field
00:46:57,609 -- 00:46:58,810
and what will we do
00:46:58,810 -- 00:47:01,479
with all the intelligence that we are gathering?
00:47:01,479 -- 00:47:05,717
That intelligence will help us identify the pockets of risk
00:47:05,717 -- 00:47:07,352
that exist in the marketplace,
00:47:07,352 -- 00:47:09,521
the pockets of risk that we are not aware about.
00:47:09,521 -- 00:47:12,423
There could be additional issues. It could be higher risk MGAs.
00:47:12,423 -- 00:47:13,258
It could be higher risk
00:47:13,258 -- 00:47:16,361
insurance companies, we just don't know what we don't know.
00:47:16,361 -- 00:47:18,129
So that's the intelligence program
00:47:18,129 -- 00:47:19,364
that we are going to launch.
00:47:19,364 -- 00:47:21,933
And if you have additional questions about it,
00:47:21,933 -- 00:47:23,535
we've got Kevin, Dinesh
00:47:23,535 -- 00:47:25,069
and Glenn in the room who can help
00:47:25,069 -- 00:47:26,170
you answer those questions.
00:47:26,170 -- 00:47:28,072
And I'm free of answering those questions. Then,
00:47:29,207 -- 00:47:30,942
the second piece,
00:47:30,942 -- 00:47:31,776
you know, that,
00:47:31,776 -- 00:47:36,180
Erica mentioned was on the international front,
00:47:36,180 -- 00:47:38,816
you know, I'm not from Canada.
00:47:38,816 -- 00:47:40,685
I've come to Canada a few years ago
00:47:40,685 -- 00:47:42,520
and never thought that I would be intertwined
00:47:42,520 -- 00:47:45,290
in the Canadian regulatory system,
00:47:45,290 -- 00:47:48,092
but when I was working on, you know, these Canadian
00:47:48,092 -- 00:47:51,129
consumer issues on the Market Conduct side,
00:47:51,129 -- 00:47:53,898
I started to realize that what we see in
00:47:53,898 -- 00:47:57,468
Canada is not unique to Canada alone.
00:47:57,468 -- 00:47:58,636
A lot of things,
00:47:58,636 -- 00:48:00,738
a lot of issues, a lot of deficiencies,
00:48:00,738 -- 00:48:03,875
a lot of problems that we are trying to solve in Canada,
00:48:03,875 -- 00:48:06,010
they exist across the globe.
00:48:06,010 -- 00:48:08,846
They exist in so many different countries.
00:48:08,846 -- 00:48:10,848
And we are very lucky that,
00:48:10,848 -- 00:48:11,115
you know,
00:48:11,115 -- 00:48:12,950
our CEO, Mike White, he's
00:48:12,950 -- 00:48:15,853
been selected to be the Chair of the
00:48:15,853 -- 00:48:18,990
Market Conduct Working Group, MCWG,
00:48:18,990 -- 00:48:19,390
at the
00:48:19,390 -- 00:48:21,926
IAIS, which is the International Association
00:48:21,926 -- 00:48:24,429
of Insurance Supervisors.
00:48:24,429 -- 00:48:26,264
So in that space, you know,
00:48:26,264 -- 00:48:28,232
Mark had a very good thought
00:48:28,232 -- 00:48:30,068
leadership to this whole approach
00:48:30,068 -- 00:48:33,971
where he said that when we talk about DEI,
00:48:33,971 -- 00:48:36,574
why are we only talking about DEI
00:48:36,574 -- 00:48:39,010
from an institutional perspective?
00:48:39,010 -- 00:48:41,179
Why are we only talking about gender?
00:48:41,179 -- 00:48:43,514
Why are we only talking about what happens
00:48:43,514 -- 00:48:45,650
from a governance perspective?
00:48:45,650 -- 00:48:49,020
Why can't we tweak our understanding to see
00:48:49,020 -- 00:48:54,025
how can we as an industry treat diverse consumers better?
00:48:55,226 -- 00:48:59,831
How can we treat diverse, vulnerable, minority,
00:48:59,831 -- 00:49:02,500
racialized consumers better?
00:49:02,500 -- 00:49:05,503
So we started a very interesting exercise.
00:49:05,503 -- 00:49:05,770
You know,
00:49:05,770 -- 00:49:08,539
there are 200 regulators on the Market
00:49:08,539 -- 00:49:10,474
Conduct working group internationally,
00:49:10,474 -- 00:49:12,577
and it's the crème de la crème of
00:49:12,577 -- 00:49:15,580
you know, all the top notch regulators being there.
00:49:15,580 -- 00:49:18,482
We asked each one of them to give us examples
00:49:18,482 -- 00:49:20,618
of how vulnerable consumers
00:49:20,618 -- 00:49:23,120
have been harmed in their country.
00:49:23,120 -- 00:49:25,690
So we got a huge repository of examples.
00:49:25,690 -- 00:49:26,924
And thank you to Deepa,
00:49:26,924 -- 00:49:29,827
Nathan, who led that exercise from my team.
00:49:29,827 -- 00:49:32,964
And when we gathered all those examples, we saw
00:49:32,964 -- 00:49:35,099
there are so many distinct,
00:49:35,099 -- 00:49:37,501
you know, parallels that we could draw
00:49:37,501 -- 00:49:39,337
in terms of what was happening
00:49:39,337 -- 00:49:42,273
across the different countries, but commonalities.
00:49:42,273 -- 00:49:45,643
And so now we've embarked on an exercise
00:49:45,643 -- 00:49:47,845
where we are understanding what are the common trends
00:49:47,845 -- 00:49:49,480
that are happening globally,
00:49:49,480 -- 00:49:52,450
how consumers are intentionally being targeted,
00:49:52,450 -- 00:49:54,118
or, you know, things are not comprehensive
00:49:54,118 -- 00:49:56,320
enough for vulnerable consumers.
00:49:56,320 -- 00:49:58,990
And we are developing an application paper,
00:49:58,990 -- 00:50:00,224
an application paper
00:50:00,224 -- 00:50:02,093
that's going to give all of you
00:50:02,093 -- 00:50:04,595
insurance companies and intermediaries
00:50:04,595 -- 00:50:06,997
some very practical recommendations
00:50:06,997 -- 00:50:09,166
on how diverse and vulnerable
00:50:09,166 -- 00:50:11,302
consumers can be better treated.
00:50:11,302 -- 00:50:12,436
So again,
00:50:12,436 -- 00:50:15,005
we look forward to having a lot of consultations
00:50:15,005 -- 00:50:15,740
with many of you
00:50:15,740 -- 00:50:16,540
in the room
00:50:16,540 -- 00:50:19,243
on both the exercise, on the Ontario
00:50:19,243 -- 00:50:21,278
related intelligence program,
00:50:21,278 -- 00:50:23,614
as well as the international application paper,
00:50:23,614 -- 00:50:25,983
which is going to be a great toolkit
00:50:25,983 -- 00:50:27,118
for all of us in the room.
00:50:28,419 -- 00:50:29,153
Thanks, Swati.
00:50:29,153 -- 00:50:31,388
So can I just comment on that? Yes, of course.
00:50:31,388 -- 00:50:36,393
So since my role moved to be global, late last year,
00:50:37,428 -- 00:50:38,796
it was very intriguing,
00:50:38,796 -- 00:50:40,698
and you're speaking exactly to what
00:50:40,698 -- 00:50:43,033
I have been learning over the last number of months.
00:50:43,033 -- 00:50:45,669
Everybody thinks that it's always very different
00:50:45,669 -- 00:50:47,838
in their country.
00:50:47,838 -- 00:50:51,008
and very quickly I came to the same understanding
00:50:51,008 -- 00:50:54,111
that it's all really quite the same
00:50:54,111 -- 00:50:56,347
with just some general nuances.
00:50:56,347 -- 00:50:58,048
So I'm going to be very intrigued
00:50:58,048 -- 00:51:01,418
to see where this application paper comes in.
00:51:01,418 -- 00:51:03,320
See, I said I had superpowers,
00:51:03,320 -- 00:51:06,123
I could intuitively understand what Kim was,
00:51:06,123 -- 00:51:09,460
you know, working on despite of not knowing it.
00:51:09,460 -- 00:51:12,730
Perfect. Is interesting how it all ties together. Right?
00:51:12,730 -- 00:51:17,735
So we've got international trends and consumer issues,
00:51:18,068 -- 00:51:21,138
and seeing them perhaps played out,
00:51:21,138 -- 00:51:22,206
perhaps differently,
00:51:22,206 -- 00:51:24,608
perhaps not, depending on the country
00:51:24,608 -- 00:51:27,444
and the market and the product.
00:51:27,444 -- 00:51:32,016
And we continue to see that role of gathering data
00:51:32,016 -- 00:51:36,020
in order to inform our supervisory priorities.
00:51:36,020 -- 00:51:39,823
And, then you've got to bring it back down to that
00:51:39,823 -- 00:51:40,924
agent on the ground.
00:51:40,924 -- 00:51:41,792
At the end of the day,
00:51:41,792 -- 00:51:43,694
if you're thinking about Individual Life
00:51:43,694 -- 00:51:46,864
and Health Insurance, it's typically an agent,
00:51:46,864 -- 00:51:48,966
that a consumer's interfacing with.
00:51:48,966 -- 00:51:50,634
And, Robert, your team's done
00:51:50,634 -- 00:51:52,136
a lot of work to really drive
00:51:52,136 -- 00:51:54,938
kind of intelligence informed agent supervision.
00:51:54,938 -- 00:51:56,774
Do you want to spend a couple of minutes
00:51:56,774 -- 00:51:58,409
talking about that? Sure.
00:51:58,409 -- 00:52:01,145
So the, we discussed the LAMR.
00:52:01,145 -- 00:52:01,945
So that would be, you know,
00:52:01,945 -- 00:52:04,214
industry's obligation to report on suitable
00:52:04,214 -- 00:52:07,418
agents to the regulator and the data that, you know, helps
00:52:07,418 -- 00:52:11,221
what we're driving there from a data analytics perspective.
00:52:11,221 -- 00:52:12,489
Our bread and butter,
00:52:12,489 -- 00:52:14,124
if you will, is agent examinations
00:52:14,124 -- 00:52:15,826
or audits or whatever title you want to
00:52:15,826 -- 00:52:16,560
you want to give it.
00:52:18,328 -- 00:52:21,698
So we had developed a examination program.
00:52:21,698 -- 00:52:23,200
I always get the numbers wrong.
00:52:23,200 -- 00:52:25,436
There are
00:52:25,436 -- 00:52:29,673
710 point examination with 2,282
00:52:29,673 -- 00:52:30,741
data points,
00:52:30,741 -- 00:52:34,711
including a 48 point questionnaire with attestation.
00:52:34,711 -- 00:52:37,347
And, that's all electronic,
00:52:37,347 -- 00:52:41,685
because if I saw another Excel spreadsheet, I was going to
00:52:41,685 -- 00:52:44,988
die.
00:52:44,988 -- 00:52:47,291
So we've moved that to electronic,
00:52:47,291 -- 00:52:48,959
and that's what's been launched now.
00:52:48,959 -- 00:52:50,627
So I mean, there's the typical side of it,
00:52:50,627 -- 00:52:50,928
which is,
00:52:50,928 -- 00:52:53,197
you know, reduces burden, increases accuracy,
00:52:53,197 -- 00:52:55,132
make sure you're asking the same questions
00:52:55,132 -- 00:52:58,101
that at any person who's, who's operating that particular.
00:52:58,101 -- 00:53:01,505
It's on something called OSP on Online Service Portal.
00:53:01,505 -- 00:53:03,273
So you know, if anybody is operating
00:53:03,273 -- 00:53:04,775
that OSP platform is going to be done
00:53:04,775 -- 00:53:06,443
the same ways. We could good clean data
00:53:06,443 -- 00:53:09,680
that we can report back to the industry, publish on.
00:53:09,680 -- 00:53:12,082
And then we have those collaborations compare data.
00:53:12,082 -- 00:53:14,518
Because my colleagues here are doing the same thing,
00:53:14,518 -- 00:53:17,487
just from a different side, different lens.
00:53:17,487 -- 00:53:19,990
And let's see if we're all noticing the same things.
00:53:19,990 -- 00:53:21,491
But I think
00:53:21,491 -- 00:53:23,293
and this is all good, it's good information to have,
00:53:23,293 -- 00:53:25,762
and it's something we can collate and collaborate on.
00:53:25,762 -- 00:53:28,832
But we started to do is also look at
00:53:28,832 -- 00:53:30,467
from an FTC side of things.
00:53:30,467 -- 00:53:32,703
It's not just about your strict compliance
00:53:32,703 -- 00:53:35,739
with the act and the regs and even the guidance.
00:53:35,739 -- 00:53:37,107
What we're looking for is
00:53:38,508 -- 00:53:40,477
like,
00:53:40,477 -- 00:53:43,013
are you a suitable agent and are you making suitable sales?
00:53:43,013 -- 00:53:44,881
Are you doing what's in the best interest of the consumer?
00:53:44,881 -- 00:53:47,050
And one of the easiest ways to demonstrate,
00:53:47,050 -- 00:53:48,352
or at least help demonstrate you're doing
00:53:48,352 -- 00:53:51,488
that is to follow best practices, like it's very simple.
00:53:51,488 -- 00:53:53,523
Here's your baseline of expectation.
00:53:53,523 -- 00:53:55,192
Are you taking notes?
00:53:55,192 -- 00:53:56,660
Are you doing needs analysis?
00:53:56,660 -- 00:53:58,662
Are you doing financial analysis.
00:53:58,662 -- 00:54:01,098
You know, are we following the best practice.
00:54:01,098 -- 00:54:02,332
And if we follow the best practices,
00:54:02,332 -- 00:54:04,167
then you are in a better position to demonstrate
00:54:04,167 -- 00:54:05,469
that the sale was suitable,
00:54:05,469 -- 00:54:08,105
that you had a comprehensive conversation with the client
00:54:08,105 -- 00:54:09,806
and that the client understood what you were,
00:54:09,806 -- 00:54:12,075
what you were selling them. Like,
00:54:12,075 -- 00:54:14,945
that's the driving factor of it.
00:54:14,945 -- 00:54:16,646
So that's something we've captured heavily
00:54:16,646 -- 00:54:18,448
within our examination program.
00:54:18,448 -- 00:54:20,217
It's something that we have
00:54:20,217 -- 00:54:23,320
tipped our hat to at least, in the LAMR program as well.
00:54:23,320 -- 00:54:25,355
So these are the types of things you can report even
00:54:25,355 -- 00:54:26,990
if we can't necessarily do something about it.
00:54:26,990 -- 00:54:29,326
Let's keep collecting that data to show
00:54:29,326 -- 00:54:31,261
this is where we're seeing a gap in the industry.
00:54:31,261 -- 00:54:35,232
You know, this is where we’re looking at, policy change,
00:54:35,232 -- 00:54:37,367
legislative change, whatever the case may be.
00:54:37,367 -- 00:54:40,070
And so it allows us to support that. And,
00:54:41,738 -- 00:54:42,639
yeah, I think that that
00:54:42,639 -- 00:54:44,574
testing the best practices is something that, again,
00:54:44,574 -- 00:54:45,942
the industry is very on board with
00:54:45,942 -- 00:54:47,944
because I see the importance of it.
00:54:47,944 -- 00:54:49,546
So the next sort of stage of
00:54:49,546 -- 00:54:51,147
that is not...there's our examinations,
00:54:51,147 -- 00:54:53,350
which tend to be reactive,
00:54:53,350 -- 00:54:55,118
something that we'll do if we receive a LAMR
00:54:55,118 -- 00:54:56,486
or we'll go to an examination.
00:54:56,486 -- 00:54:57,420
There's proactive,
00:54:57,420 -- 00:54:59,289
which is where we're doing something thematic
00:54:59,289 -- 00:55:01,725
like the MGA reviews is very specific.
00:55:01,725 -- 00:55:02,525
There are,
00:55:02,525 -- 00:55:04,427
intelligence focused examinations,
00:55:04,427 -- 00:55:07,664
which is another form of, you know, risk identification and
00:55:07,664 -- 00:55:09,466
and thematic review.
00:55:09,466 -- 00:55:10,800
But we're also,
00:55:10,800 -- 00:55:13,570
soon going to be sending out something called,
00:55:13,570 -- 00:55:14,771
because you need another acronym.
00:55:14,771 -- 00:55:18,074
This one's, BPAC, and it’s a...
00:55:18,074 -- 00:55:21,678
We're wrapping like. Gee, I told you.
00:55:21,678 -- 00:55:24,547
Such a set up, I had to wrap. And Erica said, no.
00:55:25,849 -- 00:55:28,852
Anyway, so the BPAC is the Business Practice
00:55:28,852 -- 00:55:29,886
and Compliance questionnaire,
00:55:29,886 -- 00:55:32,956
and this is going to be distributed as a,
00:55:32,956 -- 00:55:34,257
so I think it's not risk identified.
00:55:34,257 -- 00:55:37,027
This is something a little truly more randomized
00:55:37,027 -- 00:55:38,361
because I think it's important to,
00:55:38,361 -- 00:55:41,097
you know, to demonstrate to the industry as well as,
00:55:41,097 -- 00:55:43,733
we're not out just to catch bad acts.
00:55:43,733 -- 00:55:45,769
Like, we also want to catch people doing the right thing.
00:55:45,769 -- 00:55:46,469
That's important.
00:55:46,469 -- 00:55:48,304
With 66,000 agents in the space,
00:55:48,304 -- 00:55:49,773
I am highly confident
00:55:49,773 -- 00:55:52,175
there are some really good agents out there
00:55:52,175 -- 00:55:54,177
and they need to be highlighted as well.
00:55:54,177 -- 00:55:59,182
So sending us something that's a bit more of a,
00:55:59,783 -- 00:56:02,152
a randomize,
00:56:02,152 -- 00:56:04,254
not risk based approach...things create,
00:56:04,254 -- 00:56:07,690
sort of creates that, what's the word I'm looking for here?
00:56:08,858 -- 00:56:09,392
Baseline.
00:56:09,392 -- 00:56:10,360
Baseline. Thank you.
00:56:10,360 -- 00:56:11,661
That's the word that would not go into
00:56:11,661 -- 00:56:13,897
Robert’s head. A baseline survey.
00:56:13,897 -- 00:56:14,531
You know,
00:56:14,531 -- 00:56:15,932
and part of that baseline
00:56:15,932 -- 00:56:18,501
we're going to be asking is about business practices
00:56:18,501 -- 00:56:20,570
and how the BPAC is going to be signed
00:56:20,570 -- 00:56:21,471
by attestations.
00:56:21,471 -- 00:56:23,706
So I'm hoping everyone tells the truth on it.
00:56:23,706 -- 00:56:26,509
We have actually had such circumstances where agents had
00:56:26,509 -- 00:56:29,679
we have given them a,
00:56:29,679 -- 00:56:31,347
an administrative monetary penalty,
00:56:31,347 -- 00:56:33,249
and they've actually thanked us, say,
00:56:33,249 -- 00:56:34,984
I didn't know that I had to do that,
00:56:34,984 -- 00:56:37,053
and I'm going to change my practice as a result of that.
00:56:37,053 -- 00:56:39,656
So the idea is, that it is an educational component.
00:56:39,656 -- 00:56:41,691
It's not about catching bad guys all the time.
00:56:41,691 -- 00:56:43,960
It's not about pointing out what people have done wrong.
00:56:43,960 -- 00:56:45,595
It's pointing to what people done right.
00:56:45,595 -- 00:56:47,797
You know, using it as a learning opportunity
00:56:47,797 -- 00:56:50,567
to, to, to improve, overall business practices.
00:56:50,567 -- 00:56:51,834
And that runs end to end.
00:56:51,834 -- 00:56:54,270
And then we support each other in that, in that quest.
00:56:55,738 -- 00:56:56,372
Thanks, Robert.
00:56:56,372 -- 00:56:56,739
I have to
00:56:56,739 -- 00:56:57,340
say, first
00:56:57,340 -- 00:56:58,441
he said he wanted to wrap
00:56:58,441 -- 00:57:00,310
and then I thought I misheard him
00:57:00,310 -- 00:57:02,378
when he said bad act,
00:57:02,378 -- 00:57:06,282
and I was getting a little bit nervous as a moderator.
00:57:06,282 -- 00:57:10,320
Or you might tip up the mic like this. That’s when you have to worry.
00:57:10,320 -- 00:57:12,422
Let's, let's keep going here.
00:57:12,422 -- 00:57:15,391
We sort of looked at the past. We've looked at the present.
00:57:15,391 -- 00:57:17,560
We're going to get into the crystal ball,
00:57:17,560 -- 00:57:20,096
part of the session here.
00:57:20,096 -- 00:57:23,933
FSRA is going to turn five this spring.
00:57:23,933 -- 00:57:27,036
And as Swati said earlier in Life and Health Insurance,
00:57:27,036 -- 00:57:31,140
we are really continuing on our multi year sector strategy
00:57:31,140 -- 00:57:34,010
to really establish and operationalize
00:57:34,010 -- 00:57:34,877
FSRA's approach
00:57:34,877 -- 00:57:37,613
to supervising the end to end distribution of Life
00:57:37,613 -- 00:57:39,749
and Health Insurance products
00:57:39,749 -- 00:57:41,050
and the outcomes
00:57:41,050 -- 00:57:42,919
we're driving for here,
00:57:42,919 -- 00:57:44,020
the consumer outcomes
00:57:44,020 -- 00:57:47,023
we're trying to achieve in all of this work.
00:57:47,023 -- 00:57:50,493
First of, of course, is suitability, of
00:57:50,493 -- 00:57:52,462
the market participants in the sector.
00:57:52,462 -- 00:57:54,297
And we've talked a lot about that already,
00:57:54,297 -- 00:57:56,933
I think on on the panel today,
00:57:56,933 -- 00:58:00,203
and then more so in the last question,
00:58:00,203 -- 00:58:02,738
we were talking about business practices. Right.
00:58:02,738 -- 00:58:04,407
So the outcome you're looking for here
00:58:04,407 -- 00:58:05,975
is business practices
00:58:05,975 -- 00:58:08,811
that support fair outcomes for consumers.
00:58:08,811 -- 00:58:13,683
And of course, we do have to mitigate specific risks
00:58:13,683 -- 00:58:14,784
where we find them.
00:58:14,784 -- 00:58:16,786
If there are specific risks
00:58:16,786 -- 00:58:19,689
due to business practices or products out there
00:58:19,689 -- 00:58:21,791
when it comes to consumer protection,
00:58:21,791 -- 00:58:24,594
of course we need to seek to mitigate those risks.
00:58:24,594 -- 00:58:27,396
And so if we look ahead to the next five years,
00:58:28,364 -- 00:58:31,801
once, you know, when we're all here together,
00:58:31,801 -- 00:58:36,806
when FSRA turns ten, what does the future look like?
00:58:37,073 -- 00:58:38,941
How will it affect consumers
00:58:38,941 -- 00:58:40,843
and how are you preparing for it?
00:58:40,843 -- 00:58:43,713
Eric, I think you were going to lead us on this answer.
00:58:43,713 -- 00:58:44,747
Sure.
00:58:44,747 -- 00:58:49,885
I mean, we heard this morning during the AI discussion,
00:58:49,919 -- 00:58:50,319
you know,
00:58:50,319 -- 00:58:52,989
this great technological marvel
00:58:52,989 -- 00:58:55,825
and, you know, in this technological miracle of an age
00:58:55,825 -- 00:59:00,830
we're living in, it's interesting on the first point that,
00:59:01,430 -- 00:59:04,900
our experience is that consumers are relying on their agent
00:59:04,900 -- 00:59:06,369
more than ever before.
00:59:06,369 -- 00:59:10,206
Yes, they have electronic means to research and
00:59:10,206 -- 00:59:12,008
and get information.
00:59:12,008 -- 00:59:14,243
But this technological marvel
00:59:14,243 -- 00:59:17,046
is also leading to a certain degree of laziness.
00:59:17,046 -- 00:59:17,413
Right.
00:59:17,413 -- 00:59:18,781
And one thing I always say is
00:59:18,781 -- 00:59:20,750
people don't open their mail anymore.
00:59:20,750 -- 00:59:24,053
How many people have their credit card on auto pay?
00:59:24,053 -- 00:59:26,022
Do they really look at their statement every month?
00:59:27,189 -- 00:59:30,092
And, you know, a simple complaint like someone getting in,
00:59:30,092 -- 00:59:32,561
a ten year renewal, never opened it.
00:59:32,561 -- 00:59:34,563
Three months later, they look at their bank account
00:59:34,563 -- 00:59:36,732
and see they're being charged quadruple the premium.
00:59:36,732 -- 00:59:39,101
So, to a certain extent,
00:59:39,101 -- 00:59:40,569
you know, we take it seriously
00:59:40,569 -- 00:59:42,138
and we impress upon advisors
00:59:42,138 -- 00:59:42,638
that, you know,
00:59:42,638 -- 00:59:46,342
when a client says you're my guy or you're my girl,
00:59:46,342 -- 00:59:47,910
they really mean it.
00:59:47,910 -- 00:59:51,614
And, you know, to Robert's point, they're, just about,
00:59:51,614 -- 00:59:53,916
you know, something as simple as the approach
00:59:53,916 -- 00:59:56,452
following the approach as a best practice
00:59:56,452 -- 00:59:59,221
and having those seven key
00:59:59,221 -- 01:00:01,590
compliance aspects in your client file,
01:00:01,590 -- 01:00:04,193
it's amazing how hard it is to get in trouble
01:00:04,193 -- 01:00:06,729
if you're following the approach.
01:00:06,729 -- 01:00:08,631
Even from a self-inquiry standpoint,
01:00:08,631 -- 01:00:10,466
if the advisor's doing an engagement
01:00:10,466 -- 01:00:12,434
letter with the client,
01:00:12,434 -- 01:00:14,236
if the advisor's doing good reason
01:00:14,236 -- 01:00:17,206
why letters, it requires some self-reflection,
01:00:17,206 -- 01:00:20,209
and the advisor can often self, correct themselves.
01:00:20,209 -- 01:00:23,379
So, you know what? I have to relook at this case here.
01:00:23,379 -- 01:00:25,414
But going back to the question,
01:00:25,414 -- 01:00:27,283
so how do I expected to evolve
01:00:27,283 -- 01:00:30,152
in terms of suitability of market participants?
01:00:30,152 -- 01:00:30,819
Well, you know,
01:00:30,819 -- 01:00:32,788
we're already seeing that FSRA’s
01:00:32,788 -- 01:00:36,158
licensing team is looking more closely at renewals,
01:00:36,158 -- 01:00:38,661
at license renewals than ever before.
01:00:38,661 -- 01:00:40,562
And we have to explain to advisors, yes,
01:00:40,562 -- 01:00:43,332
you need to upload your CE credit certificates.
01:00:43,332 -- 01:00:45,668
It's not just an attestation anymore.
01:00:45,668 -- 01:00:46,568
So, you know,
01:00:46,568 -- 01:00:48,270
I think we can expect this
01:00:48,270 -- 01:00:50,940
to increase and more and more scrutiny
01:00:50,940 -- 01:00:53,876
given on this valuable thing called a Life License.
01:00:54,843 -- 01:00:55,477
And, you
01:00:55,477 -- 01:00:57,413
know, are we going to see
01:00:57,413 -- 01:01:00,516
more advisors who perhaps exit the industry?
01:01:00,516 -- 01:01:01,984
Because, you know,
01:01:01,984 -- 01:01:04,620
we have to say that some MGAs we're seeing
01:01:04,620 -- 01:01:07,389
are looking at their advisor population saying, well,
01:01:07,389 -- 01:01:08,991
this bottom third isn't doing anything.
01:01:08,991 -- 01:01:12,127
They're just hanging around. And before that was okay.
01:01:12,127 -- 01:01:14,096
But now with all the industry scrutiny,
01:01:14,096 -- 01:01:15,831
that's becoming a risk to us.
01:01:15,831 -- 01:01:19,268
So I think there's going to be some attrition there.
01:01:19,268 -- 01:01:21,070
In terms of business practices
01:01:21,070 -- 01:01:24,173
that support fair outcomes for consumers.
01:01:24,173 -- 01:01:27,076
You know, Kim talked about it, Swati talked about it,
01:01:27,076 -- 01:01:28,544
Robert talked about it.
01:01:28,544 -- 01:01:29,378
Just, you know,
01:01:29,378 -- 01:01:31,613
knocking on the advisor's door
01:01:31,613 -- 01:01:34,650
asking them, you know, what are you doing in your practice?
01:01:34,650 -- 01:01:39,655
And we've seen some insurers do some little creative,
01:01:39,822 -- 01:01:41,657
maneuvers like one insurer
01:01:41,657 -- 01:01:44,993
now instead of a standard advisor practice review,
01:01:44,993 -- 01:01:46,628
they're doing desk audits.
01:01:46,628 -- 01:01:48,063
Oh, you just submitted a case for us.
01:01:48,063 -- 01:01:50,999
Can you please provide us with the best practice
01:01:50,999 -- 01:01:52,434
documentation behind this case?
01:01:52,434 -- 01:01:56,505
Kind of a...a snappier, real time audit.
01:01:56,505 -- 01:01:59,441
Which is catching some advisors off guard,
01:01:59,441 -- 01:02:01,977
which is a good thing, right? It's ruffling some feathers.
01:02:01,977 -- 01:02:04,913
Wow. Yeah. This is real. This is, this is coming home now,
01:02:06,281 -- 01:02:07,716
And even things like,
01:02:07,716 -- 01:02:10,619
like audits, you know, that's, that's a great initiative.
01:02:10,619 -- 01:02:13,455
Robert, you spoke about.
01:02:13,455 -- 01:02:14,756
We had a little story.
01:02:14,756 -- 01:02:16,859
We had an advisor who was audited by FSRA,
01:02:16,859 -- 01:02:20,696
a dual license advisor for Mutual Funds and Life Insurance.
01:02:20,696 -- 01:02:23,298
Has great practice, has a great staff.
01:02:23,298 -- 01:02:25,601
He commented...And he passed with flying colors.
01:02:25,601 -- 01:02:26,668
But he commented
01:02:26,668 -- 01:02:29,137
because, he had just gone through an FDA audit,
01:02:29,137 -- 01:02:33,642
and he commented on how impressive the audit process was.
01:02:33,642 -- 01:02:34,509
And he said, you know what?
01:02:34,509 -- 01:02:37,145
This auditor asked me at one point?
01:02:37,145 -- 01:02:37,980
She said,
01:02:37,980 -- 01:02:40,315
how do you decide which insurance company
01:02:40,315 -- 01:02:42,851
you put a client with?
01:02:42,851 -- 01:02:44,786
What a great question!
01:02:44,786 -- 01:02:46,388
And he was impressed
01:02:46,388 -- 01:02:49,324
that the auditor knew enough to even ask that question.
01:02:49,324 -- 01:02:50,726
And he was able to pull out
01:02:50,726 -- 01:02:52,861
several client files and say, well,
01:02:52,861 -- 01:02:54,930
once we decide on a
01:02:54,930 -- 01:02:56,031
a level of insurance
01:02:56,031 -- 01:02:58,734
they need and a product structure they want,
01:02:58,734 -- 01:03:02,004
we do a life guide spread. And here's how it starts.
01:03:02,004 -- 01:03:03,872
And we don't always go to the cheapest company.
01:03:03,872 -- 01:03:05,507
We talk about features and benefits,
01:03:05,507 -- 01:03:07,442
my relationships with underwriters,
01:03:07,442 -- 01:03:08,977
customer service, things like that.
01:03:08,977 -- 01:03:11,246
But he just said, wow, that's a great question.
01:03:11,246 -- 01:03:14,149
So catching advisors doing stuff right
01:03:14,149 -- 01:03:18,019
is, is something that we can expect, more to happen.
01:03:18,019 -- 01:03:19,988
And then number three, in terms of mitigating
01:03:19,988 -- 01:03:23,525
specific consumer risks by targeting practices
01:03:23,525 -- 01:03:25,360
and products being recommended
01:03:26,361 -- 01:03:28,764
that create higher risk for consumer harm.
01:03:28,764 -- 01:03:31,266
I think we're, we're going to see in the next,
01:03:31,266 -- 01:03:33,702
you know, 0 to 5 years
01:03:33,702 -- 01:03:35,403
is collectively,
01:03:35,403 -- 01:03:38,140
we are going to have to look at strategies,
01:03:38,140 -- 01:03:41,109
right, that are being touted out there.
01:03:41,109 -- 01:03:43,078
I'll pick on,
01:03:43,078 -- 01:03:46,414
a simple generic one, leverage...leverage investments,
01:03:46,414 -- 01:03:49,050
which for whatever reason, anecdotally from my lens,
01:03:49,050 -- 01:03:50,952
were not seen as frenzied
01:03:50,952 -- 01:03:54,723
a rush for consumers or advisors recommending leverage.
01:03:54,723 -- 01:03:58,693
But I can recall, in, in my career
01:03:58,693 -- 01:04:03,698
almost having to do battle with a bank wholesaler
01:04:04,599 -- 01:04:06,568
in terms of why I was disallowing
01:04:06,568 -- 01:04:09,404
this particular leverage investment case
01:04:09,404 -- 01:04:11,106
with the bank
01:04:11,106 -- 01:04:12,140
wholesaler saying, look,
01:04:12,140 -- 01:04:14,976
the client qualifies for this million dollars
01:04:14,976 -- 01:04:16,011
and trying to explain.
01:04:16,011 -- 01:04:18,914
Yes, but that doesn't mean it's reasonable for the client,
01:04:18,914 -- 01:04:21,917
given their parameters, their age,
01:04:21,917 -- 01:04:23,051
their risk tolerance,
01:04:23,051 -- 01:04:26,988
their overall income, their wealth...profile.
01:04:26,988 -- 01:04:29,557
That doesn't mean it's a reasonable case for them.
01:04:29,557 -- 01:04:31,326
So at a certain point,
01:04:31,326 -- 01:04:33,428
you know, we have to recognize like, like here
01:04:33,428 -- 01:04:36,298
I am the MGA trying to control that
01:04:36,298 -- 01:04:38,700
the, the banker, just like our,
01:04:38,700 -- 01:04:41,936
our climate expert there on the stage said,
01:04:41,936 -- 01:04:44,673
wow, you can't insure a house in a floodplain,
01:04:44,673 -- 01:04:45,907
but you can get a loan to buy one.
01:04:47,008 -- 01:04:48,009
That's not consistent.
01:04:48,009 -- 01:04:50,178
Right. That's an inconsistent message.
01:04:50,178 -- 01:04:55,250
So here, if I'm trying to mitigate a leverage case,
01:04:55,250 -- 01:04:56,851
that may be egregious.
01:04:56,851 -- 01:05:00,155
Well, the bank wholesaler wants to sell debt.
01:05:00,155 -- 01:05:01,756
He wants to get the maximum debt out there.
01:05:01,756 -- 01:05:04,826
The insurance company wants to sell units of SEG funds,
01:05:04,826 -- 01:05:06,094
that's out there.
01:05:06,094 -- 01:05:07,729
So I think it will help.
01:05:07,729 -- 01:05:08,897
You know, it's a fantasy
01:05:08,897 -- 01:05:10,498
to think that I, as the MGA
01:05:10,498 -- 01:05:14,269
compliance officer, can stop that by myself.
01:05:14,269 -- 01:05:17,138
If the industry itself, at the carrier level,
01:05:17,138 -- 01:05:19,407
at the regulator level,
01:05:19,407 -- 01:05:22,744
doesn't kind of at least put forth an opinion to say,
01:05:22,744 -- 01:05:24,813
you know what, these are the nine dots.
01:05:24,813 -- 01:05:25,346
You know,
01:05:25,346 -- 01:05:26,614
you can look at the MFDA,
01:05:26,614 -- 01:05:27,916
which has a
01:05:27,916 -- 01:05:31,119
pretty reasonable way to calculate
01:05:31,119 -- 01:05:33,488
what a reasonable amount of leverage would be
01:05:33,488 -- 01:05:36,124
and what might be over, off side.
01:05:36,124 -- 01:05:37,525
So looking at the client's
01:05:37,525 -- 01:05:40,428
risk, their debt service ratio, things like that.
01:05:40,428 -- 01:05:42,630
But it can't just be one entity
01:05:42,630 -- 01:05:45,700
in the distribution chain that's trying to control that.
01:05:45,700 -- 01:05:48,403
Everybody needs to kind of put that line in the sand.
01:05:49,971 -- 01:05:51,906
So yeah.
01:05:51,906 -- 01:05:54,042
We got some SEG funds Guidance coming.
01:05:54,042 -- 01:05:57,245
You're going to get excited about Eric, when it comes to leveraging.
01:05:57,245 -- 01:05:57,946
Robert,
01:05:57,946 -- 01:05:59,080
do you want to jump in
01:05:59,080 -- 01:06:02,717
and talk about the future of agent supervision?
01:06:02,717 -- 01:06:03,017
Sure.
01:06:03,017 -- 01:06:05,119
So I already touched on some of it in terms of,
01:06:05,119 -- 01:06:05,453
you know, the
01:06:05,453 -- 01:06:10,959
we have shifted, our entire supervision process to OSP.
01:06:10,959 -- 01:06:12,794
So we're we're all we're 100% digital
01:06:12,794 -- 01:06:15,897
now for LAMR receptions, examinations.
01:06:15,897 -- 01:06:17,899
The BPAC going out.
01:06:17,899 -- 01:06:19,300
Where that's expanding out
01:06:19,300 -- 01:06:20,501
is something we mentioned earlier,
01:06:20,501 -- 01:06:22,470
is there 66,000 agents in the space.
01:06:22,470 -- 01:06:25,006
And I have a small but mighty team.
01:06:25,006 -- 01:06:30,011
We need to leverage technology heavily.
01:06:31,145 -- 01:06:32,280
By leveraging technology,
01:06:32,280 -- 01:06:33,715
not only are we looking at process
01:06:33,715 -- 01:06:35,516
efficiencies and burden reduction,
01:06:35,516 -- 01:06:36,384
and that's on both sides.
01:06:36,384 -- 01:06:38,152
It's not just the Senior Compliance Officers
01:06:38,152 -- 01:06:40,121
who are processing these.
01:06:40,121 -- 01:06:42,156
You know, these reviews and investigations,
01:06:42,156 -- 01:06:43,758
but also on the industry side,
01:06:43,758 -- 01:06:45,293
encouraging the industry to report
01:06:45,293 -- 01:06:46,627
because we make it easy for them.
01:06:46,627 -- 01:06:49,330
That's the idea, right? To reduce that burden.
01:06:49,330 -- 01:06:50,498
But at the end of the day,
01:06:50,498 -- 01:06:52,166
that all needs to be boiled down to something.
01:06:52,166 -- 01:06:54,736
So 66,000 agents, limited resources.
01:06:54,736 -- 01:06:57,171
How is it we determine what we do next?
01:06:57,171 -- 01:06:59,140
So by taking
01:06:59,140 -- 01:07:02,677
maximizing data, big data analytics and being able to,
01:07:02,677 -- 01:07:02,977
you know,
01:07:02,977 -- 01:07:05,813
distill that down and identify risk
01:07:05,813 -- 01:07:08,349
and direct resources where that risk is greatest.
01:07:08,349 -- 01:07:10,718
That is the future, and the future is now.
01:07:10,718 -- 01:07:12,487
We're doing that now,
01:07:12,487 -- 01:07:13,221
what it is
01:07:13,221 -- 01:07:14,355
now is growing
01:07:14,355 -- 01:07:15,990
the capacity to,
01:07:15,990 -- 01:07:17,191
you know, maximize
01:07:17,191 -- 01:07:19,694
those as well and also to share that data back out again.
01:07:21,028 -- 01:07:23,431
So
01:07:23,431 -- 01:07:25,266
in the meantime, we have to be realistic
01:07:25,266 -- 01:07:27,735
that we're not going to hit 66,000 agents every year.
01:07:27,735 -- 01:07:28,903
It's not going to happen.
01:07:28,903 -- 01:07:30,271
So we have to take sort of a trust
01:07:30,271 -- 01:07:32,607
and confirm approach to things as well.
01:07:32,607 -- 01:07:34,809
So yes, we have self-reported data
01:07:34,809 -- 01:07:36,878
that self-reported data through questionnaires
01:07:36,878 -- 01:07:37,812
such as the BPAC.
01:07:37,812 -- 01:07:39,313
There's a questionnaire that also goes along
01:07:39,313 -- 01:07:40,781
with the examination program.
01:07:40,781 -- 01:07:42,416
There's an attestation at the end of that.
01:07:42,416 -- 01:07:44,385
You're swearing to its content.
01:07:44,385 -- 01:07:46,320
So you may be part of an exam
01:07:46,320 -- 01:07:48,489
where we are going to confirm the content.
01:07:48,489 -- 01:07:49,757
You might be part of a BPAC,
01:07:49,757 -- 01:07:51,893
which is a broad reaching questionnaire
01:07:51,893 -- 01:07:54,128
and may or may not have a follow up examination.
01:07:54,128 -- 01:07:56,230
But that attestation means something.
01:07:56,230 -- 01:07:57,565
So it will be a test and confirm
01:07:57,565 -- 01:07:59,333
approach to it, or a trust and confirm
01:07:59,333 -- 01:08:01,002
approach to it as well,
01:08:01,002 -- 01:08:02,770
that we have to broadly believe that
01:08:02,770 -- 01:08:05,172
there are good agents who are going to report accurately,
01:08:05,172 -- 01:08:07,008
and then we'll be, will be, you know,
01:08:07,008 -- 01:08:10,611
confirming those who aren't then reporting that back again.
01:08:10,611 -- 01:08:12,146
And that's a surrealistic approach
01:08:12,146 -- 01:08:14,315
when we're looking at a large number.
01:08:14,315 -- 01:08:16,384
But in terms of the future, I mean, we're looking
01:08:16,384 -- 01:08:19,720
we've already implemented AI into, to our programs,
01:08:21,689 -- 01:08:23,824
mostly for burden reduction purposes.
01:08:23,824 -- 01:08:26,927
We're seeing the industry has shifted heavily to,
01:08:26,927 -- 01:08:29,196
electronic applications.
01:08:29,196 -- 01:08:30,431
We're looking with agents
01:08:30,431 -- 01:08:32,366
when we're doing examinations of their files,
01:08:32,366 -- 01:08:34,568
are stored electronically.
01:08:34,568 -- 01:08:36,070
That's now ballooned into,
01:08:36,070 -- 01:08:39,040
so what cloud are your, are your files served on?
01:08:39,040 -- 01:08:41,409
Are they within Canadian borders or not?
01:08:41,409 -- 01:08:42,843
Is that a concern to the industry?
01:08:42,843 -- 01:08:44,712
Is that a concern to the regulator, these sort of things?
01:08:44,712 -- 01:08:46,080
These are the conversations that are happening
01:08:46,080 -- 01:08:48,549
that expands out onto CISRO. CCIR levels
01:08:48,549 -- 01:08:51,452
having those conversations as well.
01:08:51,452 -- 01:08:53,988
So it's growing rapidly.
01:08:53,988 -- 01:08:56,490
Where I see it as a very positive,
01:08:56,490 -- 01:08:59,126
is that data is knowledge,
01:08:59,126 -- 01:09:00,761
and that knowledge gives you the ability
01:09:00,761 -- 01:09:02,296
to make good decisions.
01:09:02,296 -- 01:09:03,898
And if, if everyone's now
01:09:03,898 -- 01:09:05,833
moved from what you said earlier, like
01:09:05,833 -- 01:09:07,201
everything was paper driven, right?
01:09:07,201 -- 01:09:07,868
And everything's now
01:09:07,868 -- 01:09:10,237
shifted, that it's now easier to process
01:09:10,237 -- 01:09:11,539
and analyze that data
01:09:11,539 -- 01:09:16,544
to identify harm or identify agents doing great work.
01:09:16,877 -- 01:09:19,647
Then, then that's something that we can leverage and have,
01:09:20,948 -- 01:09:23,150
you know, to, to, to...raise the industry up entirely.
01:09:23,150 -- 01:09:27,788
So I think, an adage I like to use a lot is like,
01:09:27,788 -- 01:09:30,257
how do you eat an elephant?
01:09:30,257 -- 01:09:31,458
One bite at a time.
01:09:31,458 -- 01:09:34,361
Exactly.
01:09:34,361 -- 01:09:36,230
When I jump in with the company perspective.
01:09:36,230 -- 01:09:40,701
Not from the elephant perspective, no.
01:09:40,701 -- 01:09:41,936
I've touched on a lot of it.
01:09:41,936 -- 01:09:44,438
You've, you've spoken to a lot of it as well, Robert,
01:09:44,438 -- 01:09:47,441
about how we are changing the way that we are monitoring
01:09:47,441 -- 01:09:49,643
how we're using data.
01:09:49,643 -- 01:09:51,979
Just a couple of, kind of, follow up
01:09:51,979 -- 01:09:55,149
points to some of the things that have already said,
01:09:55,149 -- 01:09:59,386
while we may be using this data for our advisors,
01:09:59,386 -- 01:10:00,187
please understand
01:10:00,187 -- 01:10:01,455
we're also going to be rolling it up
01:10:01,455 -- 01:10:05,526
to see what firm are they with, what MGA are they with, what AGA
01:10:05,526 -- 01:10:06,126
are they with.
01:10:06,126 -- 01:10:08,228
Because that might then influence
01:10:08,228 -- 01:10:10,731
the conversations that we're going to be having.
01:10:10,731 -- 01:10:12,967
Or you know, the interactions
01:10:12,967 -- 01:10:14,902
that we might want to have with those firms.
01:10:16,337 -- 01:10:20,708
I think our advisors practices have shifted,
01:10:20,708 -- 01:10:25,779
but will shift monumentally with the use of technology.
01:10:26,213 -- 01:10:29,883
You talked about notes and things along those lines.
01:10:29,883 -- 01:10:30,784
I don't understand
01:10:30,784 -- 01:10:33,187
why advisors aren't taping some of their phone
01:10:33,187 -- 01:10:34,488
or their meetings
01:10:34,488 -- 01:10:36,790
and using those as their sources of,
01:10:36,790 -- 01:10:40,127
of meeting notes and things along those lines.
01:10:40,127 -- 01:10:42,796
But then how do we make sure that it's secure?
01:10:42,796 -- 01:10:45,833
How do we make sure the advisor understands? Yes.
01:10:45,833 -- 01:10:47,768
Where is that data cloud?
01:10:47,768 -- 01:10:52,106
Do you know how to have access or restrict access?
01:10:52,106 -- 01:10:54,975
Does your assistant that you just fired yesterday
01:10:54,975 -- 01:10:57,778
still have access to all of your systems?
01:10:57,778 -- 01:11:01,648
Have you made sure to take care of all of those things?
01:11:01,648 -- 01:11:04,751
Cybersecurity is probably one of, well,
01:11:04,751 -- 01:11:06,420
it is, the number one,
01:11:06,420 -- 01:11:08,122
behind licensing
01:11:08,122 -- 01:11:11,658
issue that my, my compliance team is dealing with.
01:11:11,658 -- 01:11:13,527
So advisors who have had
01:11:13,527 -- 01:11:15,629
their emails compromised
01:11:15,629 -- 01:11:18,632
or their clients have had their emails compromised,
01:11:18,632 -- 01:11:20,734
this is only going to continue.
01:11:20,734 -- 01:11:22,469
So there's a whole education
01:11:22,469 -- 01:11:24,404
that I believe needs to occur
01:11:24,404 -- 01:11:25,639
for advisors
01:11:25,639 -- 01:11:28,375
and for clients about data and protection
01:11:28,375 -- 01:11:31,245
and the use of these technologies
01:11:31,245 -- 01:11:35,148
that are very quickly becoming commonplace for all of us.
01:11:36,683 -- 01:11:40,087
I was a part of a very large,
01:11:40,087 -- 01:11:43,790
ATO, account takeover situation
01:11:43,790 -- 01:11:45,826
going back about two years now.
01:11:45,826 -- 01:11:46,960
And we were talking with the,
01:11:46,960 -- 01:11:48,528
you know, carrier in the,
01:11:48,528 -- 01:11:48,895
you know,
01:11:48,895 -- 01:11:52,599
carrier had just completed a survey of their advisors
01:11:52,599 -- 01:11:55,068
who purchased their insurance product.
01:11:55,068 -- 01:11:59,439
And the number one password was still password 1234.
01:11:59,439 -- 01:12:02,442
No, really. Right.
01:12:02,442 -- 01:12:03,443
Not password?
01:12:03,443 -- 01:12:04,778
That was number two, I believe.
01:12:04,778 -- 01:12:06,647
But, you know, it,
01:12:06,647 -- 01:12:07,014
you know,
01:12:07,014 -- 01:12:07,681
how do we
01:12:07,681 -- 01:12:09,549
how do we advance all of these things
01:12:09,549 -- 01:12:12,853
that are to the betterment of all of us, from the MGA
01:12:12,853 -- 01:12:15,055
to the insurer to the regulator?
01:12:15,055 -- 01:12:19,593
But then also keep the customers fair and protected?
01:12:19,593 -- 01:12:22,229
So those would be my closing.
01:12:22,229 -- 01:12:23,597
Thanks, Kim.
01:12:23,597 -- 01:12:24,798
I, in the interest of time,
01:12:24,798 -- 01:12:26,666
I think we're just going to jump ahead,
01:12:26,666 -- 01:12:28,769
and, do our last questions.
01:12:28,769 -- 01:12:30,937
We've got a bit of time for Q&A.
01:12:30,937 -- 01:12:32,005
If you've got a question
01:12:32,005 -- 01:12:33,907
and you haven't submitted it, I'd encourage you
01:12:33,907 -- 01:12:36,743
to figure out the site and submit it now
01:12:36,743 -- 01:12:39,379
so we can take it in a couple of minutes.
01:12:39,379 -- 01:12:41,248
I'm hearing a lot on the need
01:12:41,248 -- 01:12:44,451
for education, on the need for security,
01:12:44,451 -- 01:12:46,887
on the need for data protection.
01:12:46,887 -- 01:12:47,888
Another theme that I think
01:12:47,888 -- 01:12:49,156
is coming out of every single
01:12:49,156 -- 01:12:51,258
one of the questions we've discussed
01:12:51,258 -- 01:12:53,226
today is collaboration.
01:12:53,226 -- 01:12:55,762
And that collaboration is key, that we're stronger,
01:12:56,830 -- 01:12:59,366
we're stronger together when it comes to achieving fair
01:12:59,366 -- 01:13:01,201
outcomes for consumers.
01:13:01,201 -- 01:13:03,870
And it's really important then to learn from each other.
01:13:03,870 -- 01:13:04,738
It's important
01:13:04,738 -- 01:13:07,641
for regulators to learn from industry and vice versa,
01:13:07,641 -- 01:13:10,210
and to really appreciate each other's perspective.
01:13:10,210 -- 01:13:15,215
So a challenge to my panel is, for our insurer and MGA
01:13:16,883 -- 01:13:18,051
reps,
01:13:18,051 -- 01:13:19,586
if you could put yourself
01:13:19,586 -- 01:13:22,322
into the Market Conduct regulator shoes,
01:13:22,322 -- 01:13:23,890
what learnings would you share?
01:13:23,890 -- 01:13:25,959
And then for my FSRA colleagues
01:13:25,959 -- 01:13:28,028
try on Kim and Eric shoes for size.
01:13:28,028 -- 01:13:29,396
And what learnings would you share.
01:13:29,396 -- 01:13:32,666
And we'll hear more some doozies today.
01:13:32,666 -- 01:13:33,800
And I'm also going to give you
01:13:33,800 -- 01:13:37,537
an additional challenge of trying to do, your response
01:13:37,537 -- 01:13:38,672
and maybe one minute each.
01:13:38,672 -- 01:13:40,740
So we still have time for Q&A.
01:13:40,740 -- 01:13:42,075
Kim, do you want to kick it off?
01:13:42,075 -- 01:13:43,009
Okay.
01:13:43,009 -- 01:13:45,979
In one minute or less, I was actually going to say,
01:13:45,979 -- 01:13:47,681
and Swati kind of stole this, through
01:13:47,681 -- 01:13:50,150
her comments about an industry level
01:13:50,150 -- 01:13:53,019
is learning from the examples
01:13:53,019 -- 01:13:55,255
and the experiences that are occurring
01:13:55,255 -- 01:13:55,855
all around
01:13:55,855 -- 01:13:59,192
us, and using that to inform the shape
01:13:59,192 -- 01:14:01,328
and the way that our industry moves forward.
01:14:03,163 -- 01:14:05,665
Robert.
01:14:05,665 -- 01:14:07,767
For those of you who don't know, I come from industry,
01:14:07,767 -- 01:14:12,272
so I've seen sort of both sides of it. And I think,
01:14:12,272 -- 01:14:14,841
I think it's important to recognize that,
01:14:14,841 -- 01:14:16,810
people in the compliance world are genuine.
01:14:16,810 -- 01:14:19,079
They genuinely care about consumer protection,
01:14:19,079 -- 01:14:20,080
about doing the right thing.
01:14:20,080 -- 01:14:22,849
And I think it's easy to get lost in this idea
01:14:22,849 -- 01:14:24,951
that, you know,
01:14:24,951 -- 01:14:26,786
the insurers are just out to make money.
01:14:26,786 -- 01:14:27,787
It's just commission driven.
01:14:27,787 -- 01:14:30,790
And sales driven, is like, well, yes, it's a business.
01:14:30,790 -- 01:14:32,959
But the compliance side of it can still be genuine.
01:14:32,959 -- 01:14:37,497
And on the regulator's side of it, it's not the big bad
01:14:37,497 -- 01:14:40,467
regulator coming in and, you know, not connecting as well.
01:14:40,467 -- 01:14:42,335
Like this is all about collaboration.
01:14:42,335 -- 01:14:44,637
Like this has to be done together.
01:14:44,637 -- 01:14:45,872
We have to see that, you know,
01:14:45,872 -- 01:14:47,040
there's, there's a reality
01:14:47,040 -- 01:14:51,044
that tens of thousands of transactions occur every day,
01:14:51,044 -- 01:14:51,911
within an insurer.
01:14:51,911 -- 01:14:53,513
So the regulator can't look back and say, well,
01:14:53,513 -- 01:14:54,848
how did you miss that?
01:14:54,848 -- 01:14:56,816
The regulator should say, how did you miss that?
01:14:56,816 -- 01:14:57,417
You know, like, let's, let's,
01:14:57,417 -- 01:14:59,919
let's learn about this together. What can we do to help?
01:14:59,919 -- 01:15:03,690
And so I think it's really understanding each other.
01:15:03,690 -- 01:15:05,325
Well, point of your question, like,
01:15:05,325 -- 01:15:06,793
you are seeing it from both sides of it.
01:15:06,793 -- 01:15:08,094
And I think,
01:15:08,094 -- 01:15:10,063
sharing that information, sharing the mistakes
01:15:10,063 -- 01:15:12,732
as well as the victories, is very important
01:15:12,732 -- 01:15:14,567
because I've said this at other
01:15:14,567 -- 01:15:16,336
stakeholder engagement,
01:15:16,336 -- 01:15:18,104
events, you know, a rising
01:15:18,104 -- 01:15:20,106
tide of compliance raises all ships.
01:15:24,944 -- 01:15:27,947
From the MGA perspective,
01:15:27,947 -- 01:15:30,149
you know, what we would like you to know
01:15:30,149 -- 01:15:33,119
is, is how important we think the work is
01:15:33,119 -- 01:15:34,954
that you're doing with LAMRs
01:15:34,954 -- 01:15:37,624
and, and hopefully that you can triage those
01:15:37,624 -- 01:15:40,593
because at the ground level, as an MGA,
01:15:40,593 -- 01:15:43,630
if we see, a real bad actor
01:15:43,630 -- 01:15:45,164
and we have to quickly reassign
01:15:45,164 -- 01:15:47,700
those clients to new advisor,
01:15:47,700 -- 01:15:50,236
and meanwhile that advisor is still running around
01:15:50,236 -- 01:15:51,371
speaking of those clients,
01:15:51,371 -- 01:15:53,139
because nothing's yet done,
01:15:53,139 -- 01:15:54,907
it places us in a hard position,
01:15:54,907 -- 01:15:57,310
but obviously we recognize you have to cover yourselves.
01:15:57,310 -- 01:15:59,278
There's certain legal things you have to do,
01:15:59,278 -- 01:16:01,748
but we just respect that work and,
01:16:01,748 -- 01:16:03,383
want to give you that insight.
01:16:03,383 -- 01:16:05,051
And then the second thing is,
01:16:05,051 -- 01:16:08,855
maybe this is more for CLHIA, but the industry in general
01:16:08,855 -- 01:16:10,990
is the electronic applications.
01:16:10,990 -- 01:16:15,328
There's so much potential to add FTC into them.
01:16:15,328 -- 01:16:17,230
Something as simple as, there's
01:16:17,230 -- 01:16:19,532
a small insurance company out there,
01:16:19,532 -- 01:16:20,833
I won't name its name, but they
01:16:20,833 -- 01:16:24,070
they have a, a dedicated sales force.
01:16:24,070 -- 01:16:24,837
And it was interesting.
01:16:24,837 -- 01:16:26,472
I know someone who's in that company.
01:16:26,472 -- 01:16:28,074
And the application,
01:16:28,074 -- 01:16:30,009
if the advisor tries to submit a case
01:16:30,009 -- 01:16:32,512
where the premium is more than 12% of the client's
01:16:32,512 -- 01:16:36,249
gross income, it freezes it. There's a red flag on it.
01:16:36,249 -- 01:16:38,184
Not to mean that there might not be a reason for that,
01:16:38,184 -- 01:16:40,953
but it has to be approved at a higher level.
01:16:40,953 -- 01:16:43,222
So things like electronic applications
01:16:43,222 -- 01:16:44,824
that can stop something.
01:16:44,824 -- 01:16:46,325
If an advisor is writing a case
01:16:46,325 -- 01:16:48,661
on a client who lives in Alberta,
01:16:48,661 -- 01:16:50,296
and the client goes to sign it
01:16:50,296 -- 01:16:51,497
and says signed where
01:16:51,497 -- 01:16:54,300
Alberta and the advisors license is Ontario,
01:16:54,300 -- 01:16:56,869
that application should freeze that case.
01:16:56,869 -- 01:16:58,538
It shouldn't allow it to go through.
01:16:58,538 -- 01:16:59,672
And now the insurance carrier
01:16:59,672 -- 01:17:00,940
has to report to the regulator
01:17:00,940 -- 01:17:03,509
that this was an extra jurisdictional case.
01:17:03,509 -- 01:17:05,478
So, a couple of, a couple of points there.
01:17:08,147 -- 01:17:08,881
You know, our
01:17:08,881 -- 01:17:09,882
last FSRA
01:17:09,882 -- 01:17:12,518
change, the last question was
01:17:12,518 -- 01:17:15,221
what makes you successful as a regulator?
01:17:15,221 -- 01:17:18,758
And I had mentioned about five C’s that I think,
01:17:18,758 -- 01:17:21,127
you know, make us successful as a regulator.
01:17:21,127 -- 01:17:23,396
If I were to put myself in Kim
01:17:23,396 -- 01:17:27,566
and Eric's shoes, big shoes to fill and fancy ones to,
01:17:27,566 -- 01:17:29,535
but if I were to put myself in their shoes
01:17:29,535 -- 01:17:31,270
and I would apply the same
01:17:31,270 -- 01:17:33,239
five C’s to them
01:17:33,239 -- 01:17:37,109
and then see what learning can we have for the industry.
01:17:37,109 -- 01:17:39,412
So the first C is Courage.
01:17:39,412 -- 01:17:43,082
I think both Kim and Eric, representing insurance companies
01:17:43,082 -- 01:17:45,651
and the MGAs have had a lot of courage
01:17:45,651 -- 01:17:48,788
to accept the problems that we've identified.
01:17:48,788 -- 01:17:50,289
They always say to solve a problem,
01:17:50,289 -- 01:17:52,224
you first need to identify and accept
01:17:52,224 -- 01:17:53,492
that there is a problem.
01:17:53,492 -- 01:17:54,827
All automatic studies,
01:17:54,827 -- 01:17:56,996
all our reviews, all the problems and deficiencies
01:17:56,996 -- 01:17:58,664
that we've identified, them
01:17:58,664 -- 01:18:00,733
being installed, wha’ts in the industry for many,
01:18:00,733 -- 01:18:04,403
many years, still had the courage to accept it.
01:18:04,403 -- 01:18:07,073
The second thing, Competency,
01:18:07,073 -- 01:18:08,541
both on the insurer side
01:18:08,541 -- 01:18:10,910
and on the MGA side. I see Kim
01:18:10,910 -- 01:18:11,477
and Eric
01:18:11,477 -- 01:18:13,079
continuously striving
01:18:13,079 -- 01:18:14,980
to improve the competency
01:18:14,980 -- 01:18:17,383
of the people that they are working with,
01:18:17,383 -- 01:18:20,453
to ensure that we are meeting the regulatory requirements,
01:18:20,453 -- 01:18:21,320
just not, you know,
01:18:21,320 -- 01:18:22,922
the hard coded rules,
01:18:22,922 -- 01:18:24,323
but also the guidance,
01:18:24,323 -- 01:18:26,692
the spirit of law to serve the consumer better.
01:18:26,692 -- 01:18:29,161
And I'm sure, just like Eric and Kim,
01:18:29,161 -- 01:18:31,864
all of you are doing that in the room as well.
01:18:31,864 -- 01:18:34,867
The third thing, the third C, Communication.
01:18:34,867 -- 01:18:36,368
We are constantly talking.
01:18:36,368 -- 01:18:38,604
You can even see through the banter that we have here.
01:18:38,604 -- 01:18:40,105
We are interacting
01:18:40,105 -- 01:18:41,373
and insurance
01:18:41,373 -- 01:18:44,210
companies and MGAs are just not interacting with regulators,
01:18:44,210 -- 01:18:46,812
but they are also talking amongst themselves
01:18:46,812 -- 01:18:49,682
to understand how best to serve the consumer.
01:18:49,682 -- 01:18:52,117
The fourth thing, Consistent approach.
01:18:52,117 -- 01:18:54,620
I know that insurance companies and MGAs
01:18:54,620 -- 01:18:55,888
and both Kim and Eric,
01:18:55,888 -- 01:18:57,423
they are on our stakeholder advisory
01:18:57,423 -- 01:18:59,191
committee, technical advisory committee,
01:18:59,191 -- 01:19:01,126
so many members in this room,
01:19:01,126 -- 01:19:03,229
you are constantly striving to understand
01:19:03,229 -- 01:19:04,964
how best we divvy up the roles
01:19:04,964 -- 01:19:06,465
and responsibilities
01:19:06,465 -- 01:19:08,467
to make sure that the right effect
01:19:08,467 -- 01:19:10,469
gets passed on to the consumer.
01:19:10,469 -- 01:19:12,705
And the last thing is the moral Compass.
01:19:12,705 -- 01:19:13,539
The North Star
01:19:13,539 -- 01:19:15,674
that Mark mentioned as well this morning.
01:19:15,674 -- 01:19:16,475
All of this,
01:19:16,475 -- 01:19:19,144
I mean, we understand that we are in the industry.
01:19:19,144 -- 01:19:20,512
Bottom lines are important.
01:19:20,512 -- 01:19:23,215
Profitability is important. Growth is important.
01:19:23,215 -- 01:19:26,151
But doing it the right way is also very important.
01:19:26,151 -- 01:19:29,521
And if I were to place myself in Kim and Eric's shoes,
01:19:29,521 -- 01:19:29,755
you know,
01:19:29,755 -- 01:19:31,757
ever since I've started in Canada
01:19:31,757 -- 01:19:33,759
in the Life and Health Insurance industry,
01:19:33,759 -- 01:19:36,729
I've seen them both follow through that North Star.
01:19:36,729 -- 01:19:39,698
So I would just summarize that the combination of,
01:19:39,698 -- 01:19:42,668
you know, having that Courage, Competency,
01:19:42,668 -- 01:19:45,070
Communication, Consistency
01:19:45,070 -- 01:19:49,541
and Compass is what we can learn from Kim and Eric.
01:19:49,541 -- 01:19:51,243
And if we all in the industry
01:19:51,243 -- 01:19:54,913
implement that, we definitely will be a super
01:19:54,913 -- 01:19:56,615
powerful industry together.
01:19:57,583 -- 01:19:58,984
Thanks, Swati.
01:19:58,984 -- 01:20:01,987
I'm just going to do a check with, at the back of the room.
01:20:01,987 -- 01:20:05,791
I think we have about five minutes for Q&A.
01:20:05,791 -- 01:20:09,661
Okay. And, and we've got one up here.
01:20:09,661 -- 01:20:10,662
I'll read it out,
01:20:10,662 -- 01:20:12,898
and then I'll, let the panel decide
01:20:12,898 -- 01:20:15,067
who wants to jump in on it first.
01:20:15,067 -- 01:20:16,502
What is the role of life
01:20:16,502 -- 01:20:18,771
insurers to ensure that their products
01:20:18,771 -- 01:20:22,241
are designed appropriately for their target market,
01:20:22,241 -- 01:20:24,309
with increasingly complex products
01:20:24,309 -- 01:20:26,945
being sold to mass market households,
01:20:26,945 -- 01:20:28,747
who is really responsible
01:20:28,747 -- 01:20:31,250
for the suitability of the products?
01:20:31,250 -- 01:20:32,050
Or we could say,
01:20:32,050 -- 01:20:35,187
perhaps a suitability of the advice?
01:20:35,187 -- 01:20:38,157
Who wants to jump in on that?
01:20:38,157 -- 01:20:40,058
Well, I can start.
01:20:40,058 -- 01:20:45,030
So as I mentioned, in some of my earlier remarks,
01:20:45,030 -- 01:20:46,632
at Manulife,
01:20:46,632 -- 01:20:48,734
our product design does
01:20:48,734 -- 01:20:51,336
include the fair treatment of customers as a
01:20:52,838 -- 01:20:54,239
creation component.
01:20:54,239 -- 01:20:59,278
So we are, you know, doing market studies to determine who
01:20:59,278 -- 01:21:04,283
these clients should be or in some cases, shouldn't be.
01:21:04,750 -- 01:21:09,755
The complexity of the products being sold.
01:21:09,855 -- 01:21:13,358
To me, very honestly, it's a joint responsibility.
01:21:13,358 -- 01:21:16,428
The advisor has the responsibility to complete,
01:21:16,428 -- 01:21:20,299
a needs based sale that is right for their client.
01:21:20,299 -- 01:21:24,569
They need to understand the product that they are selling.
01:21:24,569 -- 01:21:26,805
They need to be able to explain it,
01:21:26,805 -- 01:21:30,175
in a variety of ways to their client.
01:21:30,175 -- 01:21:32,277
And then they need to complete,
01:21:32,277 -- 01:21:35,814
in my opinion, a really great reason
01:21:35,814 -- 01:21:39,785
why letter so that the client can remember years later
01:21:39,785 -- 01:21:43,255
why it was that they purchased what they purchased.
01:21:43,255 -- 01:21:45,490
That's the adviser's responsibility.
01:21:45,490 -- 01:21:49,094
I see the MGA having a responsibility for ensuring that,
01:21:49,094 -- 01:21:52,998
you know, it's not everything the advisor is selling.
01:21:52,998 -- 01:21:54,966
Because, again, as an insurance company,
01:21:54,966 -- 01:21:57,035
I can only see Manulife product.
01:21:57,035 -- 01:22:00,705
I can't see Sun Equitable or any of my other colleagues.
01:22:00,705 -- 01:22:02,908
I can't see what's happening there.
01:22:02,908 -- 01:22:03,975
And then from the insurance
01:22:03,975 -- 01:22:07,045
company, again, using our tools,
01:22:07,045 -- 01:22:10,315
we should be going to those advisors to say,
01:22:10,315 -- 01:22:11,950
why are you selling this?
01:22:11,950 -- 01:22:12,951
This doesn't appear
01:22:12,951 -- 01:22:17,956
to fit inside the, the client base that we were expecting.
01:22:18,190 -- 01:22:22,060
What is your rationalization for that? Help us understand.
01:22:22,060 -- 01:22:25,497
And folks, in some cases their answer is appropriate.
01:22:25,497 -- 01:22:30,168
In other cases, the answer is, that's probably not great.
01:22:30,168 -- 01:22:31,636
How can we remediate this?
01:22:31,636 -- 01:22:33,638
What should we be doing for the clients
01:22:33,638 -- 01:22:34,806
that have already got the product?
01:22:34,806 -- 01:22:37,676
And what should we be doing with you? Go forward.
01:22:37,676 -- 01:22:39,978
So I just want to quickly add to that,
01:22:39,978 -- 01:22:41,580
that a product is a thing.
01:22:41,580 -- 01:22:42,347
Right?
01:22:42,347 -- 01:22:46,518
It's, it's like a car with no governor.
01:22:48,520 -- 01:22:49,988
For those who aren't from car
01:22:49,988 -- 01:22:52,123
culture, like a governor will dictate,
01:22:52,123 -- 01:22:53,858
it can only go up to a certain speed.
01:22:53,858 -- 01:22:57,596
So I think, as I mentioned before, collectively
01:22:57,596 -- 01:22:59,864
we have to look at these products like, say, whole life.
01:22:59,864 -- 01:23:01,099
It's, it's a thing.
01:23:01,099 -- 01:23:02,767
It's designed for a marketplace,
01:23:02,767 -- 01:23:04,869
but it can be used in so many different ways.
01:23:04,869 -- 01:23:06,571
And so collectively
01:23:06,571 -- 01:23:07,906
we have to decide, like
01:23:07,906 -- 01:23:11,910
if someone's putting 40% of their income into one product,
01:23:11,910 -- 01:23:12,944
we as an industry
01:23:12,944 -- 01:23:14,279
have to start to look at that
01:23:14,279 -- 01:23:15,714
and say, okay, is that strategy?
01:23:15,714 -- 01:23:18,383
Is that going to lead to good long term success?
01:23:18,383 -- 01:23:20,986
It could or could not.
01:23:20,986 -- 01:23:23,088
But we, you know, I personally believe
01:23:23,088 -- 01:23:25,090
we can't just leave it to MGAs
01:23:25,090 -- 01:23:27,659
to put that governor on those products
01:23:27,659 -- 01:23:29,294
because it can be very dangerous
01:23:29,294 -- 01:23:30,995
if they're used the wrong way.
01:23:30,995 -- 01:23:34,032
So in this game of Whac-A-Mole, where one MGA will say,
01:23:34,032 -- 01:23:35,633
well, I'm not comfortable with that
01:23:35,633 -- 01:23:37,535
advisor moves to another MGA.
01:23:37,535 -- 01:23:39,371
That game of whac-a-mole has to stop.
01:23:39,371 -- 01:23:40,839
So I think as an industry,
01:23:40,839 -- 01:23:43,208
if we can look at the strategies
01:23:43,208 -- 01:23:46,010
and come up with certain parameters for that,
01:23:46,010 -- 01:23:47,545
that would be helpful.
01:23:47,545 -- 01:23:50,849
And I think one thing to remember that, you know,
01:23:50,849 -- 01:23:51,483
one of our,
01:23:52,517 -- 01:23:53,485
principles, which
01:23:53,485 -- 01:23:55,120
has been a very important principle
01:23:55,120 -- 01:23:56,521
and you know, our Bible,
01:23:56,521 -- 01:23:58,556
when doing market conduct regulation,
01:23:58,556 -- 01:24:01,860
are the ICPs, Insurance Core Principles,
01:24:01,860 -- 01:24:03,128
which have been established
01:24:03,128 -- 01:24:05,897
at the IAIS and Insurance Core
01:24:05,897 -- 01:24:09,334
Principle 19 is the Bible for Market Conduct.
01:24:09,334 -- 01:24:13,404
And 19.5 specifically talks about,
01:24:13,404 -- 01:24:15,840
you know, how insurance companies,
01:24:15,840 -- 01:24:17,442
when they design a product,
01:24:17,442 -- 01:24:18,643
they need to think about
01:24:18,643 -- 01:24:21,279
who their target market is for their product
01:24:21,279 -- 01:24:23,681
appropriate as well as inappropriate.
01:24:23,681 -- 01:24:25,517
Kim mentioned that there is some kind of,
01:24:25,517 -- 01:24:27,318
you know, baseline target market.
01:24:27,318 -- 01:24:30,455
Not all insurance companies that we've seen it have it.
01:24:30,455 -- 01:24:33,157
So it's important to establish it, to set it.
01:24:33,157 -- 01:24:35,293
That can be exceptions to the norm.
01:24:35,293 -- 01:24:38,463
But you know, the exception can not become the norm.
01:24:38,463 -- 01:24:41,499
And then ICP 19.5...read through it.
01:24:41,499 -- 01:24:42,500
It also delves
01:24:42,500 -- 01:24:44,569
deeper into how insurance companies
01:24:44,569 -- 01:24:48,006
should communicate that target market to the MGAs,
01:24:48,006 -- 01:24:50,441
and how the MGAs, based on their work
01:24:50,441 -- 01:24:51,843
with the advisors, are required
01:24:51,843 -- 01:24:54,479
to report it back to the insurance companies,
01:24:54,479 -- 01:24:57,415
such that you have the right checks and balances in place.
01:24:57,415 -- 01:25:01,686
So we have a lot of good guidance and principles around it.
01:25:01,686 -- 01:25:04,989
It's time now that we operationalize it.
01:25:04,989 -- 01:25:05,990
Thanks, Swati.
01:25:05,990 -- 01:25:07,225
We're almost out of time,
01:25:07,225 -- 01:25:09,661
but we've got a great, question on the Board
01:25:09,661 -- 01:25:12,797
here, about compliance from the advisors perspective.
01:25:12,797 -- 01:25:14,565
So I'll read it out and then,
01:25:14,565 -- 01:25:15,733
Robert, we'll start with you
01:25:15,733 -- 01:25:18,970
and just send it down 30 seconds each, maybe.
01:25:18,970 -- 01:25:20,338
So from the advisors
01:25:20,338 -- 01:25:23,074
perspective, are the compliance functions
01:25:23,074 -- 01:25:25,877
seen as an impediment to doing business?
01:25:25,877 -- 01:25:27,578
How can MGAs or
01:25:27,578 -- 01:25:29,047
and insurers
01:25:29,047 -- 01:25:33,551
ensure that advisors are incented to do the right thing?
01:25:33,551 -- 01:25:34,018
Robert.
01:25:35,853 -- 01:25:37,088
I have heard the comment that
01:25:37,088 -- 01:25:39,891
I don't make any money doing compliance.
01:25:39,891 -- 01:25:42,427
You know, from when I was in the private sector as well as,
01:25:42,427 -- 01:25:44,595
in the public sector now.
01:25:44,595 -- 01:25:46,030
You know, I was like, I'm here for sales.
01:25:46,030 -- 01:25:47,765
I don't make money when I'm filling out reason
01:25:47,765 -- 01:25:49,600
why letters and all this sort of stuff.
01:25:49,600 -- 01:25:51,736
And, I'm sorry, you're a licensed professional.
01:25:51,736 -- 01:25:53,771
You have obligations, and,
01:25:53,771 -- 01:25:54,939
you, you need to,
01:25:54,939 -- 01:25:58,042
you know, complete your, your best practice steps.
01:25:58,042 -- 01:25:59,977
But what I always put back to people
01:25:59,977 -- 01:26:04,315
now is if you're going to sell your book a business
01:26:04,315 -- 01:26:06,818
and get good money, top dollar for it, don't
01:26:06,818 -- 01:26:07,718
you want to make sure
01:26:07,718 -- 01:26:10,388
that it is completely compliant, that you have followed...
01:26:10,388 -- 01:26:13,057
You can demonstrate with every single sale
01:26:13,057 -- 01:26:14,659
that it was a suitable sale because you followed
01:26:14,659 -- 01:26:16,194
best practices within it?
01:26:16,194 -- 01:26:17,662
That's how you maintain book value.
01:26:17,662 -- 01:26:19,897
That ought to be one of many incentives,
01:26:19,897 -- 01:26:21,299
but that is definitely one of your incentives.
01:26:21,299 -- 01:26:22,800
Like that's your retirement plan there.
01:26:22,800 -- 01:26:23,668
When you sell that book.
01:26:27,772 -- 01:26:31,676
No.
01:26:31,676 -- 01:26:32,910
Sorry.
01:26:32,910 -- 01:26:33,978
Yeah. Elaborate.
01:26:33,978 -- 01:26:38,983
How can how can we, well, we can ensure by making...
01:26:39,083 -- 01:26:40,651
I think that we can help advisors
01:26:40,651 -- 01:26:42,520
by making sure that they understand
01:26:42,520 -- 01:26:42,954
what the best
01:26:42,954 -- 01:26:44,288
practices are
01:26:44,288 -- 01:26:46,257
that we are expecting them to adhere
01:26:46,257 -- 01:26:49,260
to, helping them very quickly, perhaps
01:26:49,260 -- 01:26:51,629
very early on in their careers.
01:26:51,629 -- 01:26:52,863
Course correct.
01:26:52,863 -- 01:26:56,634
Make, make adjustments where required.
01:26:56,634 -- 01:27:00,338
So that, they are insulated.
01:27:00,338 -- 01:27:01,605
I always say to advisors, it's
01:27:01,605 -- 01:27:04,508
not if you get a complaint, it's when.
01:27:04,508 -- 01:27:07,178
And I have seen complaints go away
01:27:07,178 -- 01:27:10,881
because they have amazing notes and reason why letters.
01:27:10,881 -- 01:27:14,018
So if we can help them understand that,
01:27:14,018 -- 01:27:17,355
and I think we've done a good job.
01:27:17,355 -- 01:27:20,191
I think in the short run, maybe.
01:27:20,191 -- 01:27:22,927
But we are not here for the short run, right?
01:27:22,927 -- 01:27:24,361
I mean, a life insurance
01:27:24,361 -- 01:27:27,098
policy is a very long term policy that we are buying.
01:27:27,098 -- 01:27:29,200
And if you serve your consumers right,
01:27:29,200 -- 01:27:30,501
I think it's only going to prosper
01:27:30,501 -- 01:27:32,203
your business in the long run.
01:27:32,203 -- 01:27:35,739
So I would keep that, again, you know, as my North Star.
01:27:36,841 -- 01:27:37,208
Yeah.
01:27:37,208 -- 01:27:39,610
And at the MGA level,
01:27:39,610 -- 01:27:41,278
for advisors,
01:27:41,278 -- 01:27:42,413
doing business
01:27:42,413 -- 01:27:43,481
who want to do the right thing,
01:27:43,481 -- 01:27:44,648
they've reported to us
01:27:44,648 -- 01:27:47,118
that these actually help them do more business.
01:27:47,118 -- 01:27:49,086
So following the approach
01:27:49,086 -- 01:27:52,089
wins them cases and it gets them more referrals.
01:27:52,089 -- 01:27:54,291
So what we try to do is enhance
01:27:54,291 -- 01:27:55,426
those success stories
01:27:55,426 -- 01:27:57,094
and spread the magic
01:27:57,094 -- 01:27:58,762
and let advisors know that this
01:27:58,762 -- 01:28:00,965
this isn't some cryptic form.
01:28:00,965 -- 01:28:02,666
You have to apologize to a client
01:28:02,666 -- 01:28:05,436
that you're shoving it in front of them to sign.
01:28:05,436 -- 01:28:05,736
You know,
01:28:05,736 -- 01:28:08,405
this is something that can enhance their understanding
01:28:08,405 -- 01:28:11,275
and make sure that, God forbid, if they're in a coma,
01:28:11,275 -- 01:28:13,844
their family will understand what you've done here today.
01:28:13,844 -- 01:28:17,548
So it's all it should be a positive thing.
01:28:17,548 -- 01:28:20,751
So, we are out of time, and,
01:28:20,751 -- 01:28:22,820
we've actually gone a couple of minutes over time,
01:28:22,820 -- 01:28:24,788
and you're clearly a compliance crowd
01:28:24,788 -- 01:28:26,023
because you're all stuck around.
01:28:26,023 -- 01:28:28,559
So thank you so much for being here.
01:28:28,559 -- 01:28:30,394
We hope you found value,
01:28:30,394 -- 01:28:33,063
in the session today, both being here in person.
01:28:33,063 -- 01:28:35,499
And for those of you who are attending virtually,
01:28:36,500 -- 01:28:37,568
We would ask,
01:28:37,568 -- 01:28:38,369
from FSRA
01:28:38,369 -- 01:28:39,036
that you please
01:28:39,036 -- 01:28:40,938
take a few minutes to complete the conference
01:28:40,938 -- 01:28:44,575
survey on the conference site under the heading Feedback.
01:28:44,575 -- 01:28:45,909
That's really helpful to us.
01:28:45,909 -- 01:28:47,211
It helps us to plan
01:28:47,211 -- 01:28:48,379
next year's Exchange,
01:28:48,379 -- 01:28:49,680
make it hopefully even better
01:28:49,680 -- 01:28:52,549
and more successful than today.
01:28:52,549 -- 01:28:57,021
Also, please join us in the main area, for,
01:28:57,021 -- 01:28:57,821
short reception.
01:28:57,821 -- 01:28:59,957
That's just where you came down the escalators.
01:28:59,957 -- 01:29:01,425
We'll have a short reception.
01:29:01,425 -- 01:29:04,128
There's a cash bar and light food.
01:29:04,128 -- 01:29:04,995
It's really our chance
01:29:04,995 -- 01:29:06,730
to continue today's discussions
01:29:06,730 -- 01:29:10,267
and do a little more networking before we head home.
01:29:10,267 -- 01:29:12,703
But before you head out of this room,
01:29:12,703 -- 01:29:15,205
please join me in thanking our panel
01:29:15,205 -- 01:29:17,608
for such an informative and engaging discussion.
00:00:04:27 - 00:00:05:17
Good afternoon.
00:00:05:17 - 00:00:08:04
Thank you for joining us. My name is Beata Morris.
00:00:08:04 - 00:00:12:19
I'm the director of Property and Casualty Insurance Conduct at FSRA.
00:00:13:15 - 00:00:17:04
Joining me today is a panel of knowledgeable experts
00:00:17:26 - 00:00:20:28
who have worked with me over the last year, year and a half or so
00:00:20:28 - 00:00:22:17
on some of the work that we're going to talk about.
00:00:22:17 - 00:00:25:17
So I wanted to thank the panel for joining me today.
00:00:26:07 - 00:00:29:10
I wanted to acknowledge the audience that is joining us virtually.
00:00:30:10 - 00:00:32:29
I will say when we were preparing for the session,
00:00:32:29 - 00:00:33:26
I had asked my team
00:00:33:26 - 00:00:38:02
to look up a couple of insurance jokes or regulator jokes to make it a bit funny.
00:00:38:20 - 00:00:41:29
They’re way back over there you have Nick, Corey and John.
00:00:42:07 - 00:00:44:07
Spoiler alert, they didn't write any jokes.
00:00:44:07 - 00:00:47:07
They told me regulators aren't funny and insurance is not funny,
00:00:47:21 - 00:00:50:21
which in itself, probably is the joke so there will be no jokes
00:00:51:14 - 00:00:53:00
but we'll go through the session.
00:00:53:00 - 00:00:57:18
I do want to flag that this session is being simultaneously translated in French.
00:00:58:15 - 00:01:01:02
So if you would like to listen French, you want to put your hand up,
00:01:01:02 - 00:01:04:25
somebody from our staff will come over and give you a microphone or,
00:01:04:25 - 00:01:07:24
I don't know, a little thing that goes in your ear, I guess.
00:01:07:24 - 00:01:11:03
And for those of you online, there's a button there as well
00:01:11:03 - 00:01:13:16
where you can click on the French translation.
00:01:13:28 - 00:01:16:27
I do not speak a word of French, so this will all be in English
00:01:16:27 - 00:01:19:12
unless you have one of those devices or one of those methods.
00:01:20:02 - 00:01:23:26
I will remind everyone we will take questions at the end of the session.
00:01:24:18 - 00:01:27:15
If you log into your app, it works the same way as it did this morning.
00:01:27:15 - 00:01:30:14
You log in to the app with your username and password
00:01:30:14 - 00:01:32:09
and the questions will go to the back of the room.
00:01:32:09 - 00:01:35:26
And once we're ready, John and team will send them to me to the front.
00:01:38:07 - 00:01:38:29
One more thing.
00:01:38:29 - 00:01:43:06
The session is being taped and will be posted on our website
00:01:43:29 - 00:01:46:02
in the coming weeks, so give it a couple of weeks before
00:01:46:02 - 00:01:50:00
it is posted, but it will be available for viewing on our website afterwards.
00:01:50:28 - 00:01:53:27
Maybe with that, I will turn it over to my panel
00:01:53:27 - 00:01:56:04
and ask them to introduce themselves.
00:01:56:04 - 00:01:57:08
Liam, since you are on my right?
00:01:57:08 - 00:01:58:12
Yeah, of course.
00:01:58:12 - 00:01:59:21
Hi everyone, my name is Liam McGuinty.
00:01:59:21 - 00:02:02:23
I'm the VP, Strategy at the Insurance Bureau of Canada.
00:02:03:17 - 00:02:05:08
Beata, do you want me to say a little bit about IBC?
00:02:05:08 - 00:02:05:28
Sure!
00:02:05:28 - 00:02:09:14
So, we're the P&C industry association
00:02:09:22 - 00:02:13:26
we represent insurers that write home, car and business insurance.
00:02:14:24 - 00:02:18:00
We represent approximately 90% of the P&C industry.
00:02:18:00 - 00:02:18:28
It’s good to be here.
00:02:20:04 - 00:02:21:05
My name is Huston Loke.
00:02:21:05 - 00:02:24:05
I'm Executive Vice President of Market Conduct at FSRA
00:02:24:13 - 00:02:28:18
and we oversee conduct for all sectors that FSRA regulates.
00:02:30:11 - 00:02:33:15
And I'm Ryan Stein with Definity Insurance,
00:02:33:15 - 00:02:38:14
and I'm the AVP responsible for Regulatory and Industry Affairs.
00:02:38:28 - 00:02:42:26
A little bit about Definity, Ontario-based insurance company
00:02:42:26 - 00:02:44:21
and some of the brands you might have heard of
00:02:45:13 - 00:02:47:10
are Economical,
00:02:47:10 - 00:02:49:25
Sonnet and Pet Line.
00:02:49:25 - 00:02:54:08
And you know, combined, it's a good mix of auto, home,
00:02:54:22 - 00:02:57:22
commercial and pet insurance.
00:02:58:00 - 00:03:00:10
So the one thing I would add before we get started
00:03:00:10 - 00:03:03:20
is this is the non-auto P&C supervision session.
00:03:03:20 - 00:03:06:28
If you're looking for the auto jokes, they are next door, head's up.
00:03:07:29 - 00:03:11:22
So my panel members have also agreed to put some trust in me
00:03:12:13 - 00:03:14:01
and in the interests of getting to know them,
00:03:14:01 - 00:03:16:23
I'm going to ask them some rapid fire questions.
00:03:16:23 - 00:03:20:15
They may regret this later because they did not get these questions ahead of time.
00:03:20:27 - 00:03:23:27
So I have no particular order as to who I'm going to ask what.
00:03:23:27 - 00:03:26:27
So I'm just going to kind of look at you and hope you find the answer
00:03:27:02 - 00:03:28:09
and we'll see what we end up with.
00:03:29:08 - 00:03:32:08
Liam, what's your favourite food?
00:03:34:13 - 00:03:35:04
I could go on.
00:03:35:04 - 00:03:36:04
I don't know.
00:03:36:04 - 00:03:39:04
Right now it is
00:03:39:09 - 00:03:40:02
Thai food.
00:03:40:02 - 00:03:42:18
No, I'm going to change my answer.
00:03:42:18 - 00:03:45:15
Dan Dan Mian noodles, which is a Chinese dish,
00:03:45:15 - 00:03:48:11
which I've come to know recently. I love it.
00:03:48:11 - 00:03:49:07
New find.
00:03:49:07 - 00:03:51:04
I like that.
00:03:51:04 - 00:03:54:04
Huston, what was your favourite subject in school?
00:03:54:21 - 00:03:55:14
That one’s easy.
00:03:55:14 - 00:03:58:14
I love math. So math
00:03:58:23 - 00:04:00:29
Almost everything can be condensed into a math problem.
00:04:00:29 - 00:04:01:27
So I love that.
00:04:01:27 - 00:04:03:26
I think with most folks on the stage,
00:04:03:26 - 00:04:07:02
no, I'm mathematically challenged, so I'll send my kid over to you for tutoring.
00:04:07:23 - 00:04:10:23
Ryan, what's your favourite movie genre?
00:04:13:18 - 00:04:14:06
I like.
00:04:14:06 - 00:04:16:29
You can tell I did not share the questions with them.
00:04:16:29 - 00:04:19:23
I like.
00:04:19:23 - 00:04:20:18
Yeah, I guess. I don't know.
00:04:20:18 - 00:04:22:19
It depends on my mood.
00:04:22:19 - 00:04:25:19
I think after this I'll see a good comedy, but in general it'll be.
00:04:26:07 - 00:04:27:16
It'll be a drama.
00:04:27:16 - 00:04:28:26
Drama? Okay.
00:04:29:15 - 00:04:33:22
Liam, What is your favourite thing to do in the summertime?
00:04:36:28 - 00:04:37:19
I don't know.
00:04:37:19 - 00:04:39:28
This is not the tricky part of this.
00:04:39:28 - 00:04:41:14
It's not on the briefing note.
00:04:42:24 - 00:04:45:03
I love going to cottages.
00:04:45:03 - 00:04:48:03
I love exploring Ontario.
00:04:48:03 - 00:04:49:28
Huston, and I think I know this one.
00:04:49:28 - 00:04:51:24
What is your hidden talent?
00:04:51:24 - 00:04:53:11
I'm not sure of it’s hidden talent.
00:04:53:11 - 00:04:55:04
I do like athletic endeavors.
00:04:55:04 - 00:04:59:09
So last year I did an Iron Man and just ran a marathon in February.
00:04:59:13 - 00:05:01:19
So the lessons out of that is
00:05:01:19 - 00:05:04:09
sometimes pain is good and sometimes pain is necessary,
00:05:04:09 - 00:05:07:09
and I don't give up too easily.
00:05:07:26 - 00:05:11:24
Ryan, on a scale of 1 to 10, how good of a driver are you?
00:05:11:28 - 00:05:14:05
Oh, wait, I do have an auto question. Never mind.
00:05:16:22 - 00:05:19:03
According to a telematics app that I had once,
00:05:19:03 - 00:05:22:00
probably between a 7 and a 10.
00:05:22:00 - 00:05:23:11
A 7 and an 8, sorry, out of 10.
00:05:23:11 - 00:05:26:11
So did you say you had the app and then you got rid of it?
00:05:26:25 - 00:05:29:24
Well, there was a switch involved.
00:05:30:14 - 00:05:32:05
I think I understand why.
00:05:32:05 - 00:05:33:04
Okay.
00:05:33:04 - 00:05:37:22
What is your favourite rainy day activity, Liam?
00:05:41:23 - 00:05:42:21
Maybe a guilty pleasure,
00:05:42:21 - 00:05:44:09
we have a Nintendo Switch.
00:05:44:09 - 00:05:45:23
You know, the most recent system.
00:05:45:23 - 00:05:49:16
I really like playing video games, even though I'm almost 40.
00:05:51:00 - 00:05:52:20
Okay.
00:05:52:20 - 00:05:56:27
What superpower would you want if you could have one, Huston?
00:05:56:27 - 00:05:58:06
Probably flying
00:05:58:06 - 00:06:00:23
and that might in fact affect insurance rates.
00:06:00:23 - 00:06:02:29
But being in the air, flying.
00:06:02:29 - 00:06:05:28
Alright, and then I have one question, one last question for all three of you.
00:06:05:28 - 00:06:07:09
Name one of the seven dwarfs.
00:06:08:12 - 00:06:10:17
Dopey.
00:06:10:17 - 00:06:13:17
Dopey.
00:06:15:07 - 00:06:18:07
I think he's describing the rest of us.
00:06:19:21 - 00:06:20:17
Sneezy.
00:06:20:17 - 00:06:22:20
Sneezy.
00:06:22:20 - 00:06:24:01
Sleepy!
00:06:24:01 - 00:06:25:12
There! Sleepy.
00:06:25:12 - 00:06:28:12
I was going to say Lousy, but Sleepy.
00:06:29:15 - 00:06:32:15
Well, let's hope the questions get easier for the rest of the session.
00:06:32:15 - 00:06:34:26
I think I might have scared the panelists here.
00:06:34:26 - 00:06:37:15
Okay. Huston, the first one is for you.
00:06:37:15 - 00:06:41:03
Why is FSRA looking into non-auto P&C insurance sector now?
00:06:42:10 - 00:06:44:29
You know, insurance is a promise.
00:06:44:29 - 00:06:48:06
Someone makes better decisions because that person has
00:06:48:14 - 00:06:50:07
the coverage that they need
00:06:50:07 - 00:06:55:02
and when there's a problem, then there is an ability to to pay for the cost.
00:06:55:28 - 00:06:58:26
So traditionally, the regulator
00:06:58:26 - 00:07:02:15
has usually focused on auto because auto is such a big piece of the market.
00:07:02:15 - 00:07:05:16
But when we look at the experience of clients and what clients need,
00:07:06:09 - 00:07:09:22
what they need is for, you know, other critical aspects of their life,
00:07:09:22 - 00:07:14:01
such as, you know, homeowner's policies to to be there when they need them.
00:07:14:09 - 00:07:17:09
And for the most part, they are.
00:07:17:14 - 00:07:20:22
But we've started to look into areas such as claims handling
00:07:21:04 - 00:07:24:04
and complaint handling, because we think that's part of the insurance promise
00:07:24:23 - 00:07:27:22
and the preliminary results that we've seen indicate that
00:07:28:04 - 00:07:31:01
there are certainly, you know, lots of instances
00:07:31:01 - 00:07:34:27
where things are handled well, where things are handled capably,
00:07:35:06 - 00:07:38:21
the customer benefits from the promise being kept.
00:07:39:16 - 00:07:41:23
And there are other cases where I think, you know,
00:07:41:23 - 00:07:44:23
we can all learn from some of the experiences.
00:07:44:23 - 00:07:48:11
Sometimes it's just the case that,
00:07:48:13 - 00:07:52:28
someone is not happy with the decision from the insurer.
00:07:53:08 - 00:07:55:14
Sometimes it's something to do with supply chain.
00:07:55:14 - 00:07:57:27
Sometimes it's something to do with an adjuster.
00:07:57:27 - 00:08:01:09
Sometimes it's got something to do with the customer not understanding
00:08:01:26 - 00:08:04:05
what was included or not included.
00:08:04:05 - 00:08:08:09
Those are all important takeaways for us to have as well as for industry
00:08:08:09 - 00:08:09:17
and for customers.
00:08:09:17 - 00:08:12:15
And so we want to actually address
00:08:12:15 - 00:08:15:15
each of those contributors
00:08:15:27 - 00:08:19:17
to make sure that that promise is available and is kept.
00:08:19:17 - 00:08:21:28
And where that's not the case,
00:08:21:28 - 00:08:25:24
then the regulator, you know, can be part of shining some light on to that.
00:08:27:06 - 00:08:28:27
Okay, I'm going to move on to,
00:08:28:27 - 00:08:31:18
and I'm going to try and not use acronyms like this morning.
00:08:31:18 - 00:08:33:03
I don't know how well that's going to go,
00:08:33:03 - 00:08:36:03
but I'm going to talk about the fair treatment of consumers,
00:08:36:10 - 00:08:41:03
which sets out the regulatory expectations for conduct of insurance businesses,
00:08:41:19 - 00:08:44:06
insurance companies when treating consumers.
00:08:44:06 - 00:08:45:04
And Fair-
00:08:45:04 - 00:08:46:01
I was going to say FTC.
00:08:46:01 - 00:08:48:20
Fair Treatment of Consumers Guidance
00:08:48:20 - 00:08:51:08
is a key tool that FSRA and regulators use
00:08:51:08 - 00:08:54:10
when it comes to assessing market conduct and compliance.
00:08:55:13 - 00:08:57:21
That is, you would have seen that in the work that we've done
00:08:57:21 - 00:08:59:01
in our home insurance review.
00:08:59:01 - 00:09:02:16
You will see that in the supervision plan that we've recently published
00:09:02:16 - 00:09:07:21
with respect to the overview of outsourcing of insurer functions to P&C MGA’s.
00:09:08:13 - 00:09:11:25
That tends to be the core of our work and what we focus on.
00:09:12:07 - 00:09:14:15
So I'm going to turn over, I guess I'll start with Ryan.
00:09:15:14 - 00:09:18:16
FTC has been around since quite a while.
00:09:18:17 - 00:09:21:08
Insurers have been slowly implementing it.
00:09:21:08 - 00:09:24:26
How is the industry implementing FTC Guidance since its release
00:09:24:26 - 00:09:27:26
and what initiatives can insurers take to promote
00:09:27:29 - 00:09:30:29
fair treatment of consumers in their organizations?
00:09:31:08 - 00:09:34:08
Well, you know, I'll start out by saying
00:09:34:08 - 00:09:37:20
insurance companies want to promote fair outcomes for their customers.
00:09:37:20 - 00:09:41:22
So I think, you know the expectations that regulators have
00:09:41:22 - 00:09:45:02
kind of aligns with the expectations that companies have for themselves.
00:09:45:02 - 00:09:48:02
In fact, companies might hold themselves to a higher standard.
00:09:48:06 - 00:09:51:07
So, yeah, I'm going to throw out an acronym here again. But,
00:09:52:10 - 00:09:56:00
you know, I'll spell it out so I don't have to give a $5.
00:09:57:10 - 00:10:01:19
FSRA adopted the Canadian Council of Insurance Regulators’ (CCIR)
00:10:01:19 - 00:10:03:13
Fair Treatment of Consumers Guidance
00:10:03:13 - 00:10:05:29
and we think that's important.
00:10:05:29 - 00:10:10:24
You know, customers across the country, they rightfully expect to be treated well
00:10:10:24 - 00:10:13:07
by their product and their service providers.
00:10:13:11 - 00:10:16:27
And so having a kind of a national standard that, you know,
00:10:17:00 - 00:10:21:12
most companies are in the space, national, have operations
00:10:21:12 - 00:10:24:15
across the country, you know, can implement
00:10:24:15 - 00:10:27:26
throughout their organizations and deploy down to their customer experiences
00:10:27:26 - 00:10:31:10
and it's just really having that national standard is really
00:10:31:10 - 00:10:35:02
a more efficient kind of approach to regulation.
00:10:35:13 - 00:10:40:26
And the way that the CCIR Guidance is drafted is in a principle-based way,
00:10:40:26 - 00:10:43:09
setting expectations for companies.
00:10:44:02 - 00:10:47:05
So now to, you know, kind of bring it down to the Definity level
00:10:47:14 - 00:10:52:06
and how we have implemented it, I'll talk from two perspectives.
00:10:52:06 - 00:10:53:08
One is going to be more
00:10:53:08 - 00:10:55:03
like the higher level, the organization level,
00:10:55:03 - 00:10:59:12
and then we'll drill down to the ground level about, you know, how this translates
00:11:00:03 - 00:11:03:11
into interactions and experiences for customers.
00:11:03:11 - 00:11:07:09
So at the sort of organizational level, we have a
00:11:07:11 - 00:11:11:16
and I'm sure you know, we're no different than many other companies, have a
00:11:12:05 - 00:11:16:06
you know, a company-wide policy, a policy framework for fair treatment of customers.
00:11:16:06 - 00:11:19:01
And this is really designed to have a kind of,
00:11:19:01 - 00:11:22:04
to sort of build a customer-centric culture
00:11:22:15 - 00:11:26:29
within the the organization and let that kind of permeate,
00:11:27:12 - 00:11:30:21
you know, through all the employees and all the different functions
00:11:30:21 - 00:11:34:25
so that ultimately we can deliver a superior service when we engage
00:11:34:25 - 00:11:37:27
with customers during multiple different touchpoints, everything from,
00:11:38:07 - 00:11:41:20
you know, giving advice to to ultimately
00:11:41:20 - 00:11:45:16
selling the policy to interacting if there is a claim and then also handling
00:11:46:19 - 00:11:51:06
any complaints and to support that companywide policy, we have,
00:11:51:06 - 00:11:54:11
you know, companywide training and then also team-specific training
00:11:54:28 - 00:11:57:22
for the various unique functions
00:11:57:22 - 00:12:02:17
and the folks that engage with the customers on the front line
00:12:03:06 - 00:12:07:01
and then also track performance metrics so that if there is a problem
00:12:07:01 - 00:12:10:12
that we identify, we're in a position to to rectify it quickly.
00:12:11:29 - 00:12:13:24
Now going down more to the ground level.
00:12:13:24 - 00:12:14:13
And again, if you know,
00:12:14:13 - 00:12:18:08
if you look at the CCIR Guidance, I think it covers about a dozen different
00:12:19:03 - 00:12:22:08
you know, kind of categories of expectations, everything from,
00:12:22:20 - 00:12:26:09
you know, governance to culture to product promotion.
00:12:26:18 - 00:12:29:15
I'm not going to go through them all, but there's
00:12:29:15 - 00:12:33:17
there's a lot and I'm just going to touch on kind of one specific instance
00:12:33:17 - 00:12:37:25
or a couple, which is really when it comes to giving advice.
00:12:37:25 - 00:12:42:00
And then, you know, ultimately selling insurance policies
00:12:42:28 - 00:12:44:22
and I'll use Sonnet as an example.
00:12:44:22 - 00:12:48:03
So for those that don't know, Sonnet is a direct digital
00:12:49:12 - 00:12:52:12
insurer, and its primary platform for
00:12:53:10 - 00:12:55:26
selling insurance is online.
00:12:55:26 - 00:12:59:29
And and the reason I want to mention, use it as the example is because it has
00:13:00:03 - 00:13:04:01
many unique risks and and, or I should say challenges
00:13:04:01 - 00:13:06:09
and opportunities associated
00:13:06:20 - 00:13:09:11
with it when engaging customers
00:13:09:11 - 00:13:13:05
and the kind of the approach that we take when we're giving advice and, you know,
00:13:13:05 - 00:13:17:23
selling insurance, it would be home and auto in this case
00:13:18:12 - 00:13:21:22
to customers, is we want to empower customers.
00:13:21:22 - 00:13:23:23
We want them to feel empowered when they're using the site.
00:13:25:00 - 00:13:27:05
So now, I'll break that down a little bit
00:13:27:26 - 00:13:29:28
before you can be kind of an empowered customer.
00:13:29:28 - 00:13:32:19
You know, we kind of think you have to be an informed customer
00:13:32:19 - 00:13:38:06
and an informed customer is someone who has the information that they need
00:13:38:08 - 00:13:41:06
to be confident in the decision that they're about to make.
00:13:41:06 - 00:13:44:11
And then an empowered customer is a customer who's informed,
00:13:44:11 - 00:13:48:06
but then is also able to act on that decision.
00:13:48:09 - 00:13:51:26
So to inform customers, you know, through the site
00:13:52:22 - 00:13:55:22
we'll use plain language text that was talked about
00:13:55:27 - 00:13:57:21
earlier today, the importance of that.
00:13:57:21 - 00:14:00:13
And then we'll also use accompanying illustrations
00:14:00:13 - 00:14:03:14
so that the customer will know what options are,
00:14:04:06 - 00:14:07:08
what are the various options that are available to them and sort of the,
00:14:08:13 - 00:14:11:12
you know, the various implications of each one.
00:14:11:12 - 00:14:13:14
And then, you know, they'll also have access
00:14:13:14 - 00:14:18:16
to other information, whether it's FAQ’s or blog posts and stuff like that
00:14:18:16 - 00:14:21:15
to just make sure that they're more informed.
00:14:22:12 - 00:14:25:12
To empower the customer,
00:14:25:16 - 00:14:29:14
we want to make sure that the application process is as simple as possible.
00:14:29:14 - 00:14:31:24
Ask only really the questions that are needed
00:14:31:24 - 00:14:34:01
that the customer knows the answers for,
00:14:34:01 - 00:14:37:25
and that the company can use for rating and underwriting.
00:14:37:25 - 00:14:39:20
And if you go through just the site,
00:14:39:20 - 00:14:42:00
you can go through that process, you know, in a few minutes
00:14:42:00 - 00:14:44:28
but we also recognize that that's not for every customer.
00:14:44:28 - 00:14:47:12
It's also not for every customer who goes to the site
00:14:47:12 - 00:14:50:04
thinking that this is the process that they want to go through.
00:14:50:04 - 00:14:53:12
They might need more advice, they might want to go a more traditional route.
00:14:53:22 - 00:14:57:01
They might have questions, and we want to provide that to them
00:14:57:01 - 00:14:58:25
so that at the end they feel
00:14:58:25 - 00:15:01:05
that they're making the right decision and they can act on it.
00:15:01:05 - 00:15:04:05
So there's other communication channels that we'll have available.
00:15:05:04 - 00:15:07:13
You know, you can send an email, you can go through the chat bot
00:15:07:13 - 00:15:10:13
or you can call and speak to a live agent and ask questions.
00:15:10:13 - 00:15:15:26
So that's just sort of, again, one form of interaction, one example,
00:15:15:26 - 00:15:19:18
but how we try to, you know, take the expectations for how customers
00:15:19:18 - 00:15:22:20
should be treated and try to create optimal outcomes for them
00:15:22:20 - 00:15:25:07
through the Sonnet platform.
00:15:25:07 - 00:15:26:24
And with the focus on the consumer.
00:15:26:28 - 00:15:30:09
Liam, maybe I'll turn it over to you for a quick industry perspective.
00:15:31:04 - 00:15:32:11
Emphasis on quick.
00:15:32:11 - 00:15:33:01
Was that subtle?
00:15:33:01 - 00:15:34:04
No problem.
00:15:34:11 - 00:15:37:11
You know, Ryan gave a really good on the ground perspective,
00:15:37:15 - 00:15:40:15
maybe from a 10,000 foot view.
00:15:41:13 - 00:15:44:23
I think the ways that insurers are implementing FTC.
00:15:44:23 - 00:15:46:19
I'm sorry, I'm going to use acronyms.
00:15:46:19 - 00:15:49:23
Let’s all agree to use FTC and CCIR.
00:15:49:29 - 00:15:50:28
We're all good.
00:15:50:28 - 00:15:52:17
You'll find that there's a difference
00:15:52:17 - 00:15:54:02
in terms of how insurers are applying them
00:15:54:02 - 00:15:55:07
but in terms of adherence
00:15:55:07 - 00:15:59:13
to the principles of FTC, that's commonplace within the industry.
00:15:59:17 - 00:16:01:13
But a few points to make, just briefly
00:16:02:20 - 00:16:03:26
on FTC
00:16:03:26 - 00:16:06:26
that I think make it and FSRA's approach
00:16:07:00 - 00:16:11:08
to implementing FTC resonate with our members.
00:16:12:01 - 00:16:15:14
The first is it's grounded in the IAS’s core insurance principles,
00:16:16:09 - 00:16:17:14
and the second, as Ryan mentioned,
00:16:17:14 - 00:16:20:18
it's a national approach by CCIR and CISRO.
00:16:21:00 - 00:16:24:19
So that means it is grounded in international best practice.
00:16:25:24 - 00:16:28:24
It's a pan-Canadian approach that focuses on harmonization.
00:16:29:03 - 00:16:34:18
And ideally, it should avoid the kinds of regulatory duplication or worse,
00:16:34:22 - 00:16:38:14
you know, divergence of regulatory obligations across the country.
00:16:38:28 - 00:16:41:21
And then the second part of FTC that I think resonates with our members
00:16:41:21 - 00:16:45:02
is it is non-prescriptive in it’s approach
00:16:45:02 - 00:16:48:02
and certainly the way that the non-auto unit has approached FTC
00:16:48:16 - 00:16:53:00
is not prescriptive, you know, specific to non-auto supervision by FSRA.
00:16:53:11 - 00:16:56:01
I think from what I've seen so far, I've been involved in it
00:16:56:01 - 00:16:57:26
for about a year now.
00:16:57:26 - 00:17:01:24
There's a much stronger emphasis on consumer outcomes
00:17:02:06 - 00:17:05:15
than insurer outputs, which I think is encouraging.
00:17:06:06 - 00:17:09:25
And I think from an FTC perspective, it really lends itself to
00:17:09:25 - 00:17:12:27
a principle-based approach than outcomes that are focused on consumers.
00:17:14:04 - 00:17:16:19
Speaking of ongoing initiatives, I'm going to quote,
00:17:16:19 - 00:17:19:24
I guess, your boss in her executive outlook
00:17:19:24 - 00:17:22:00
that was published by Canadian Underwriter,
00:17:22:00 - 00:17:23:01
Celyeste Power said
00:17:23:10 - 00:17:28:22
“Over the last decade, insured losses from natural disasters average $2.2 billion a year,
00:17:28:22 - 00:17:32:21
far exceeding the average in the previous decade of $632 million
00:17:33:00 - 00:17:36:03
and in the last two years, this year included, we've surpassed
00:17:36:03 - 00:17:39:12
$3 billion in insured losses of natural catastrophes.”
00:17:39:24 - 00:17:42:12
So I’ll start with you, Liam, what are insurers doing
00:17:42:12 - 00:17:45:12
and what is the industry doing to address the new normal?
00:17:47:04 - 00:17:49:24
Maybe some additional context as well.
00:17:49:24 - 00:17:55:00
So, the last four years are all within the worst
00:17:55:00 - 00:17:58:12
ten years in terms of insured losses from natural catastrophes.
00:17:58:12 - 00:18:01:12
In fact, they're all in the top seven.
00:18:01:25 - 00:18:05:08
And given what we've seen this winter in terms of conditions, I would expect
00:18:05:28 - 00:18:08:28
a difficult CAT season upcoming.
00:18:09:08 - 00:18:12:08
And when I think of how
00:18:12:11 - 00:18:15:16
our insurers, our members have adjusted to
00:18:15:25 - 00:18:20:15
what we call the new normal, I think of claims, Huston touched on that,
00:18:20:15 - 00:18:22:13
I think of coverage, but I also think of increasing
00:18:23:15 - 00:18:25:18
public policy thought leadership.
00:18:25:18 - 00:18:31:11
So maybe starting with claims briefly, that $3 billion figure is representative
00:18:31:11 - 00:18:36:06
of a surge in the number of individual claims stemming from CATs
00:18:36:25 - 00:18:41:13
and between 2021 and 2022, you saw a doubling of
00:18:41:13 - 00:18:45:16
CAT-related claims in Canada and a tripling in Ontario.
00:18:45:16 - 00:18:49:28
In 2023 that number has somewhat subsided from 2022, but it's still in Ontario,
00:18:49:28 - 00:18:53:00
nearly double the number of claims from 2021.
00:18:53:11 - 00:18:56:22
You've got that surge in claims matched with and you've heard us
00:18:56:22 - 00:18:58:09
say this many, many times
00:18:58:09 - 00:19:01:20
with a number of external factors, including supply chain shortages,
00:19:02:05 - 00:19:05:05
skill, trade shortages and our own challenges with with talent.
00:19:05:22 - 00:19:09:03
And you've got a perfect storm of sorts that creates pressure
00:19:09:03 - 00:19:11:19
and tests insurer claims capacity.
00:19:12:11 - 00:19:15:04
And I think that's why you've seen
00:19:15:04 - 00:19:17:24
such a renewed focus
00:19:17:24 - 00:19:21:11
by insurers on claims processes and building claims capacity.
00:19:21:11 - 00:19:24:05
And maybe just to cite a few examples of what we've heard
00:19:24:05 - 00:19:26:03
our insurer members are doing to adjust.
00:19:27:16 - 00:19:30:16
One, increasing the level of communication
00:19:30:21 - 00:19:33:13
between themselves and the claimant so the claimant is better
00:19:33:13 - 00:19:36:13
aware of where they're at in every stage of the claims process.
00:19:37:07 - 00:19:39:10
Two,
00:19:39:10 - 00:19:43:20
significant recruitment and retention efforts for relevant staff,
00:19:43:20 - 00:19:46:20
whether that's in-house adjusting capacity or claims staff.
00:19:47:06 - 00:19:52:06
And then three, the creation of specialized field teams to help manage
00:19:52:06 - 00:19:55:07
complex losses, especially those resulting from natural catastrophes.
00:19:55:18 - 00:19:58:03
And I think we'll see how this plays out on claims.
00:19:58:03 - 00:20:01:27
And you know, we can have a discussion about it, but I am encouraged by the fact
00:20:01:27 - 00:20:05:29
that the most recent numbers produced by the General Insurance OmbudService
00:20:06:23 - 00:20:09:04
point to a decline in the number
00:20:09:04 - 00:20:12:11
of claims-related inquiries made in the most recent year.
00:20:12:11 - 00:20:14:02
I think that's encouraging.
00:20:15:09 - 00:20:18:12
Maybe just briefly on coverage, we're still conducting internal research
00:20:18:12 - 00:20:23:01
on how the personal property product has evolved over the last couple of decades.
00:20:23:08 - 00:20:26:29
You know, I think the biggest development,
00:20:26:29 - 00:20:29:29
of course, is the emergence of overland flood protection
00:20:30:11 - 00:20:32:29
but you're also seeing incentives
00:20:32:29 - 00:20:35:29
increasingly be put in place by insurers
00:20:36:11 - 00:20:40:29
to incentivize risk mitigating behaviors, installation of some pumps,
00:20:41:21 - 00:20:46:22
weather-resistant hail and wind-resistant shingles and roofing and the like.
00:20:46:22 - 00:20:50:17
And I suspect you're going to see more of those kinds of incentives going forward.
00:20:50:17 - 00:20:54:13
And then maybe briefly and finally and Brian may want to touch on this as well.
00:20:54:13 - 00:20:57:13
He's been a big part of it.
00:20:57:15 - 00:20:58:25
I think the industry
00:20:58:25 - 00:21:01:25
has really put its money where its mouth is in terms of
00:21:02:25 - 00:21:05:08
thought leadership on public policy development,
00:21:05:08 - 00:21:07:23
specific to adaptation, resilience.
00:21:08:00 - 00:21:11:09
I can't think of another industry that has funded or supported
00:21:11:22 - 00:21:15:15
more third parties that are either primarily or solely dedicated
00:21:16:05 - 00:21:19:24
to advancing public policy recommendations
00:21:19:24 - 00:21:20:23
focused on resilience.
00:21:20:23 - 00:21:24:07
There’s the ICLR, Intact Center for Climate Adaptation,
00:21:25:07 - 00:21:26:04
Climate Proof Canada.
00:21:26:04 - 00:21:29:11
Then, of course, there's IBC and a number of other P&C associations
00:21:29:11 - 00:21:33:13
and and broker associations for which resilience is a primary focus.
00:21:34:24 - 00:21:38:03
So I think in that sense that the industry has been pushing
00:21:38:03 - 00:21:41:13
for what we call a whole of society approach that recognizes our role
00:21:42:10 - 00:21:43:14
in adapting to this new normal,
00:21:43:14 - 00:21:46:14
but also the role of policymakers in adapting to the new normal.
00:21:47:18 - 00:21:50:18
Ryan, I’ll handed over to you for the Definity perspective.
00:21:50:27 - 00:21:52:20
Yeah, it's a Definity perspective,
00:21:52:20 - 00:21:54:08
it's also an industry perspective.
00:21:54:08 - 00:21:56:20
I mean, there's
00:21:56:20 - 00:21:59:21
As Liam kind of, sort of insinuated where,
00:22:01:05 - 00:22:05:07
insurers are all kind of pushing in the same direction in many ways here.
00:22:05:07 - 00:22:09:17
So, you know,
00:22:10:06 - 00:22:13:14
we heard that the new normal is, there is no new normal.
00:22:13:14 - 00:22:14:09
We heard that this morning.
00:22:14:09 - 00:22:19:15
It's constantly changing and insurers are constantly adapting and,
00:22:19:26 - 00:22:21:12
you know, trying to put their customers
00:22:21:12 - 00:22:25:12
in the best position as possible to manage the risks out there.
00:22:25:12 - 00:22:28:09
They're reaching out to insurers to help them,
00:22:28:09 - 00:22:29:09
to help them manage.
00:22:29:09 - 00:22:31:17
And what I like about
00:22:31:17 - 00:22:34:16
what insurers are doing here is so much of the talk about insurance
00:22:34:16 - 00:22:36:19
is always about price what's happening with price
00:22:36:19 - 00:22:39:15
and you know why isn't it cheaper and it should be lower.
00:22:39:15 - 00:22:43:20
But here, you know, those stats you showed showed the
00:22:43:20 - 00:22:47:23
or, that you mentioned show that the scope and the scale that
00:22:49:00 - 00:22:51:07
that climate risk is increasing
00:22:51:07 - 00:22:54:23
and more severe natural catastrophes happening more frequently.
00:22:55:24 - 00:22:58:24
And insurers are responding by
00:22:59:09 - 00:23:02:22
increasing the value that they're offering.
00:23:02:22 - 00:23:05:22
And I think, you know, there's a lot of good,
00:23:05:29 - 00:23:08:29
good initiatives that are helping to make
00:23:09:07 - 00:23:12:00
home insurance, property insurance in this case
00:23:12:00 - 00:23:16:02
more valuable to customers.
00:23:16:02 - 00:23:20:17
So I've identified five ways, some of them Liam has touched on.
00:23:20:23 - 00:23:25:11
So the first one is P&C insurers are responding with more coverage.
00:23:25:26 - 00:23:28:07
So Liam talked about
00:23:28:07 - 00:23:29:20
residential flood insurance.
00:23:29:20 - 00:23:31:24
You know, 12 years ago, I believe it didn't exist
00:23:31:24 - 00:23:35:21
and at that point it was, this is uninsurable, it can't exist.
00:23:36:02 - 00:23:38:29
And then slowly, one company at a time.
00:23:38:29 - 00:23:42:18
Now, you know, pretty much 90% of the market,
00:23:42:18 - 00:23:47:07
those in the low in the medium risk zones, are able to obtain coverage
00:23:47:07 - 00:23:52:06
and I think it's one of the industry's greatest achievements in recent memory.
00:23:53:18 - 00:23:55:26
Insurers are also responding with ways to help customers.
00:23:55:26 - 00:23:57:04
There's a greater emphasis
00:23:57:04 - 00:23:59:27
on helping their customers mitigate the threat of loss.
00:23:59:27 - 00:24:03:01
So whether it could be offering discounts for
00:24:03:18 - 00:24:06:11
people who install backwater valves or some pumps on their property
00:24:06:11 - 00:24:09:28
or other resiliency measures to reduce the likelihood of
00:24:10:11 - 00:24:13:15
damage from the sewer backing up or
00:24:13:15 - 00:24:16:23
it could be other perils as well.
00:24:18:06 - 00:24:22:04
You know, in the case of a Definity, we have one of those types of discounts.
00:24:22:04 - 00:24:26:02
We also, you know, for commercial property insurance
00:24:26:02 - 00:24:30:26
for businesses that reach certain environmental criteria, we’ll offer
00:24:30:29 - 00:24:35:02
they'll be able to purchase higher coverage limits for their property.
00:24:35:27 - 00:24:38:03
And then we also have what we call a green endorsement
00:24:38:03 - 00:24:41:19
and different companies have different forms of this where after a loss,
00:24:43:00 - 00:24:45:21
you know, the insurance company will cover
00:24:45:21 - 00:24:50:22
higher than the, more than the limits to install eco-friendly
00:24:50:22 - 00:24:55:05
and resiliency enhancing solutions within the rebuilt process.
00:24:55:26 - 00:24:58:18
The third one and this is the one I think, the one that I'm
00:24:58:18 - 00:24:59:19
at least the most proud of
00:24:59:19 - 00:25:02:24
and what I think is such great value is
00:25:03:04 - 00:25:06:08
insurers are responding by helping people rebuild and recover.
00:25:06:08 - 00:25:10:12
And many companies have, you know, natural catastrophe response teams.
00:25:10:12 - 00:25:12:27
We call ours a national catastrophe response team.
00:25:12:27 - 00:25:14:21
We have
00:25:14:21 - 00:25:17:19
dedicated
00:25:17:19 - 00:25:21:05
and highly skilled and experienced adjusters
00:25:21:05 - 00:25:24:10
and appraisers located, in our case, on the East and the West Coast.
00:25:24:10 - 00:25:25:24
And really what their job is
00:25:25:24 - 00:25:28:28
when there is a catastrophe that hits somewhere around the country,
00:25:28:28 - 00:25:31:17
they drop what they're doing, they go to the location
00:25:31:17 - 00:25:34:14
and then they're on the ground meeting face to face with the customer
00:25:34:14 - 00:25:37:02
and starting the claims process and helping them
00:25:37:02 - 00:25:40:11
rebuild and recover from really what is a you know, was discussed earlier,
00:25:40:11 - 00:25:41:13
kind of like a life-altering,
00:25:43:03 - 00:25:45:15
life altering event.
00:25:46:29 - 00:25:48:23
We also-
00:25:48:23 - 00:25:51:02
Another way that we're responding is we need to make sure
00:25:51:02 - 00:25:54:06
that the businesses continue to be viable in adapting to these risks.
00:25:54:06 - 00:25:57:18
So making sure that you know, we're managing our concentration
00:25:57:18 - 00:25:59:07
and risk exposure,
00:25:59:07 - 00:26:00:24
you know, that's probably more of a boring topic,
00:26:00:24 - 00:26:02:24
but it's really important because it's important
00:26:02:24 - 00:26:07:07
that we're able to, you know, meet the obligations in the insurance policies
00:26:07:07 - 00:26:09:08
and help our customers when there's a claim.
00:26:09:08 - 00:26:12:23
And then the last one just sort of building, Liam, on what you mentioned
00:26:12:23 - 00:26:16:11
is the fifth one, which is engaging policymakers and really,
00:26:16:23 - 00:26:19:25
you know, pushing forward and being a supportive voice and helping
00:26:19:25 - 00:26:23:12
bring positive public policy change because ultimately it's,
00:26:23:12 - 00:26:26:13
you know, one company and one industry can't do it on its own.
00:26:26:13 - 00:26:29:05
It's got to be a public-private partnership in a lot of ways
00:26:29:05 - 00:26:33:04
and it's great to see the P&C insurance industry leading the way there.
00:26:35:01 - 00:26:38:13
So FSRA, as you- I think most of you know, completed
00:26:38:24 - 00:26:41:24
or started a review of home insurance claims last year.
00:26:41:25 - 00:26:44:10
So, Huston, I'm going to throw it over to you.
00:26:44:10 - 00:26:46:26
Why was home insurance an area of focus?
00:26:46:26 - 00:26:48:04
What did FSRA find?
00:26:48:04 - 00:26:51:26
And can you share a little bit of a sneak peek of what our publication will say?
00:26:52:12 - 00:26:52:22
Sure.
00:26:52:22 - 00:26:56:15
Well, this goes back to earlier comments that I made about this is the promise, right?
00:26:56:15 - 00:26:59:12
When there is a claim, when there is a complaint,
00:26:59:12 - 00:27:02:12
that's part of the deal from a consumer perspective.
00:27:02:14 - 00:27:03:09
I want to build on
00:27:03:09 - 00:27:06:22
what my colleagues up here have talked about in terms of frequency
00:27:07:23 - 00:27:11:11
as well as, you know, a preoccupation on the cost side.
00:27:11:21 - 00:27:15:11
Those are all very important consideration because this is
00:27:15:11 - 00:27:17:11
not a market or a situation
00:27:18:12 - 00:27:21:07
that is just static and doesn't change.
00:27:21:07 - 00:27:25:01
In fact, quite the opposite because of climate change issues,
00:27:25:01 - 00:27:29:11
because of density, because of different expectations and costs,
00:27:29:23 - 00:27:32:28
I think it's fair to say that many consumers don't know exactly
00:27:33:14 - 00:27:36:14
you know, what's going on in terms of their policy and coverage and so on,
00:27:36:20 - 00:27:39:15
and what is the best way to glean insight into that?
00:27:39:15 - 00:27:42:22
Well, we decided that we would do work with insurers to determine
00:27:43:00 - 00:27:46:27
what the complaint handling processes and the claims handling processes yielded.
00:27:47:10 - 00:27:51:06
And we know that from time to time there are issues in terms of, you know,
00:27:51:07 - 00:27:52:19
getting adjusters on site
00:27:52:19 - 00:27:56:08
because that's part of what happens when there's a, you know, Nat CAT event.
00:27:56:26 - 00:28:01:16
We know that there are situations where customers aren't happy at the end,
00:28:01:25 - 00:28:04:21
and that's where the complaint handling piece comes in.
00:28:04:21 - 00:28:07:21
What's more challenging is to figure out, okay,
00:28:07:28 - 00:28:10:14
what can be done to help with this?
00:28:10:14 - 00:28:12:28
And so we think the additional transparency
00:28:12:28 - 00:28:16:05
that we will be able to provide when we publish our report
00:28:16:05 - 00:28:19:11
will help in terms of identifying contributing factors.
00:28:19:27 - 00:28:21:15
We think it is important
00:28:21:15 - 00:28:25:07
to state that the timeliness with which a claim is handled
00:28:25:07 - 00:28:29:23
and the ability to have feedback and information to a customer,
00:28:29:28 - 00:28:31:15
you know, those are important factors.
00:28:31:15 - 00:28:34:07
That is part of fair treatment.
00:28:34:28 - 00:28:37:28
And we also think that
00:28:38:04 - 00:28:41:23
there's a role also for us and there's some things that we can take away as well.
00:28:42:14 - 00:28:46:23
Things like, you know, adjuster capacity when the system is stressed.
00:28:47:11 - 00:28:50:01
At FSRA, we have come up with a few mechanisms
00:28:50:01 - 00:28:53:12
that will assist in adjuster capacity and we're working with our partners
00:28:53:12 - 00:28:56:08
across the country and learning more about how they do the same.
00:28:56:08 - 00:29:01:03
So that is one area and I think that as time goes on,
00:29:01:11 - 00:29:06:06
this is an area where the average homeowner has to also adapt,
00:29:06:15 - 00:29:10:25
which will mean we need to work with industry,
00:29:10:25 - 00:29:15:06
we need to work with homeowners themselves to bring them up to speed in terms of
00:29:15:14 - 00:29:18:26
here is the disclosure that you might need in order to make the best decision
00:29:18:26 - 00:29:21:26
for your family, for your house, for your partner.
00:29:22:13 - 00:29:25:00
And all of that work is being done
00:29:25:00 - 00:29:28:00
and that work is being done as part of a CCIR initiative.
00:29:28:11 - 00:29:29:18
But stay tuned. More to come.
00:29:30:21 - 00:29:32:02
On the CCIR initiative.
00:29:32:02 - 00:29:33:12
And I think I see a theme
00:29:33:12 - 00:29:37:27
from all three of you in terms of consumer education and consumers understanding
00:29:37:27 - 00:29:40:27
what it is that they're purchasing and what needs they have,
00:29:40:27 - 00:29:44:03
which goes along with the work that CCIR is doing.
00:29:44:03 - 00:29:47:06
And I know, Liam, you're now part of the Working Group committee
00:29:47:26 - 00:29:50:01
with respect to the Consumer Education piece.
00:29:50:01 - 00:29:52:11
As a result of the paper that was published.
00:29:52:11 - 00:29:55:29
I'm just curious, for those of you in the room, all insurance professionals,
00:29:55:29 - 00:29:59:05
how many of you have earthquake insurance on your policies
00:29:59:05 - 00:30:02:05
right now?
00:30:02:09 - 00:30:05:09
How many of you don't know?
00:30:06:10 - 00:30:08:01
I think we've got our work cut out for us.
00:30:08:01 - 00:30:09:28
These are the insurance people in the room.
00:30:09:28 - 00:30:13:15
And I think that's very symptomatic of what is in society
00:30:13:15 - 00:30:16:06
where simply people don't know what the coverages are.
00:30:16:06 - 00:30:18:07
There's so many pages and so many endorsements
00:30:18:07 - 00:30:19:17
and there's a lack of understanding.
00:30:19:17 - 00:30:22:23
So I think the work that CCIR is doing together with industry
00:30:23:14 - 00:30:25:05
is very helpful in terms of that.
00:30:25:05 - 00:30:27:10
And I know, Liam, I'll give you a shameless plug.
00:30:27:10 - 00:30:31:10
IBC has done some work on home insurance and helping consumers.
00:30:31:10 - 00:30:32:15
We do.
00:30:33:18 - 00:30:35:10
We have resources on our website.
00:30:35:10 - 00:30:40:07
We also have a consumer information center that maybe isn't as widely known
00:30:40:07 - 00:30:43:28
as we wish, but that's a service offered through IBC by the industry.
00:30:43:28 - 00:30:46:28
We have mostly retired insurance professionals
00:30:47:13 - 00:30:51:09
taking phone calls and offering an impartial perspective.
00:30:51:20 - 00:30:54:20
We get thousands of emails and phone calls
00:30:54:25 - 00:30:57:14
every year through our consumer information officers.
00:30:57:14 - 00:31:01:29
We also have, you know, as you mentioned, home insurance resources on our website.
00:31:01:29 - 00:31:05:06
How to file a home insurance claim, risk mitigation tips, etc.
00:31:05:12 - 00:31:08:07
My favorite is we have a glossary of terms
00:31:08:07 - 00:31:10:28
which I think is very much needed
00:31:10:28 - 00:31:12:09
and it explains abbreviations.
00:31:12:09 - 00:31:15:14
Well, I should say since I started in the industry eight years ago,
00:31:15:15 - 00:31:18:28
I've noticed a real shift to more plain language
00:31:19:26 - 00:31:24:01
by the industry in terms of how it communicates with insureds.
00:31:24:13 - 00:31:27:13
So putting the lawyers out of business, are we?
00:31:27:29 - 00:31:28:08
Okay.
00:31:28:08 - 00:31:30:01
I'm going to keep picking on Liam.
00:31:30:01 - 00:31:35:05
Liam, last year at the National Insurance Conference, you hosted a panel called
00:31:35:13 - 00:31:41:04
‘How the industry can get out of the government's crosshairs for good.’
00:31:41:04 - 00:31:42:26
And here you are on stage with me.
00:31:42:26 - 00:31:44:20
Maybe that didn't work out so well.
00:31:44:20 - 00:31:48:04
Some of the advice from the panel was to give regulators data early
00:31:48:04 - 00:31:51:12
and address potential concerns before they are in the headlines.
00:31:51:21 - 00:31:53:08
And I think I've had you on speed dial.
00:31:53:08 - 00:31:56:25
So I think I get that from both of you on stage and many other in the room.
00:31:57:23 - 00:32:02:03
In your opinion, what has FSRA done well and what can we do better to work
00:32:02:03 - 00:32:05:14
together with industry towards common cause of better protecting consumers?
00:32:08:04 - 00:32:10:18
When my wife wants to
00:32:10:18 - 00:32:13:18
change my behavior, she delivers a compliment sandwich.
00:32:14:28 - 00:32:17:28
So I'm going to employ that technique.
00:32:18:26 - 00:32:21:26
Well, I think the first thing is through the,
00:32:22:09 - 00:32:25:08
you know, sticking to non-auto, through the Technical Advisory Committee
00:32:25:08 - 00:32:28:19
you've set up, that to me, from my observations,
00:32:28:19 - 00:32:31:18
and I think our members would say the same is a meaningful
00:32:31:27 - 00:32:34:26
and thoughtful approach to early consultation.
00:32:34:26 - 00:32:37:28
There are lots of examples I can point to from the home insurance
00:32:37:28 - 00:32:42:09
review that you did where you took insurer feedback into account,
00:32:44:03 - 00:32:46:18
worked with us in terms of,
00:32:46:18 - 00:32:49:08
you know, the scope of the questionnaire in particular,
00:32:49:08 - 00:32:51:23
and demonstrated some flexibility
00:32:51:23 - 00:32:54:14
in recognition of some of the concerns that I think insurers had raised.
00:32:54:14 - 00:32:57:07
So I think your approach to engagement is
00:32:58:18 - 00:33:00:12
is helpful in some sense, and in some cases
00:33:00:12 - 00:33:03:12
it could be a model for other regulators.
00:33:03:12 - 00:33:04:25
Now comes the bad news.
00:33:04:25 - 00:33:07:25
The meaty part of the compliment sandwich is,
00:33:08:06 - 00:33:11:06
and it's not even so much about FSRA.
00:33:12:06 - 00:33:15:24
Huston, you mentioned earlier adjuster licensing.
00:33:16:09 - 00:33:19:09
I cannot
00:33:19:25 - 00:33:20:29
subscribe
00:33:20:29 - 00:33:26:07
to the rationale that we need ten plus different accreditation regimes
00:33:26:24 - 00:33:29:24
for adjusters in Canada.
00:33:30:07 - 00:33:32:13
And if we're focused
00:33:32:13 - 00:33:35:13
on consumer outcomes in the event of a CAT,
00:33:35:22 - 00:33:40:28
we need to eliminate artificial barriers that exist between provinces.
00:33:41:06 - 00:33:44:16
I don't believe that the claims landscape
00:33:44:16 - 00:33:48:07
and the adjuster landscape is sufficiently different in New Brunswick,
00:33:48:16 - 00:33:53:11
in Ontario and Alberta that warrants this kind of bureaucracy that we have.
00:33:53:28 - 00:33:58:17
And so, you know, our request, not necessarily of FSRA, because I think
00:33:58:17 - 00:34:03:22
the undertaking that FSRA has, you know, adopted post Derecho and 2021 is a model.
00:34:04:04 - 00:34:08:22
But as we move towards ideally reciprocity of adjuster licensing in the country,
00:34:09:07 - 00:34:11:25
it would be helpful if FSRA played a leadership role
00:34:11:25 - 00:34:16:06
nationally with CISRO and the CCIR in getting us to that end state because
00:34:16:06 - 00:34:20:16
I do think these are artificial barriers that prevent optimal consumer outcomes.
00:34:22:20 - 00:34:26:03
One more part of the meat and then back to the sandwich.
00:34:26:26 - 00:34:29:07
I think just a general comment again,
00:34:29:07 - 00:34:32:15
you know, our request of FSRA would be to take into account
00:34:32:29 - 00:34:36:26
the cumulative regulatory burden on Canadian insurers.
00:34:37:09 - 00:34:39:07
We have
00:34:39:07 - 00:34:42:00
sophisticated
00:34:42:00 - 00:34:46:08
regulators in Canada with ambitious scope and pace of work
00:34:46:24 - 00:34:51:04
and our request would be that you adopt a complementarity approach
00:34:51:15 - 00:34:54:07
in your approach to regulation.
00:34:54:07 - 00:34:54:23
You know,
00:34:54:23 - 00:34:55:11
for example,
00:34:55:11 - 00:34:57:03
I'll raise it as a question, not a comment,
00:34:57:03 - 00:34:59:10
and maybe Huston will want to talk about it
00:34:59:10 - 00:35:03:15
but, in terms of the insurer MGA outsourcing arrangement review,
00:35:03:28 - 00:35:06:28
whatever comes out of that process, we would want to make sure
00:35:07:24 - 00:35:10:01
intersects neatly with
00:35:10:01 - 00:35:13:08
B10, the OSFI third-party arrangements guideline
00:35:13:08 - 00:35:15:20
and I'm sure there'll be something to say but that'll be a question
00:35:15:20 - 00:35:18:15
I'm sure that you get, Beata, through this process.
00:35:20:08 - 00:35:23:08
Can I close with one when we're positive?
00:35:23:17 - 00:35:26:15
I think,
00:35:26:15 - 00:35:27:16
I'm looking through my notes.
00:35:27:16 - 00:35:30:16
I definitely have more positives to say.
00:35:31:02 - 00:35:33:16
So maybe it might make sense for me to talk about
00:35:33:16 - 00:35:36:19
the B10 and the overlap issue because it's a real,
00:35:37:26 - 00:35:40:26
it’s an item that I think it's fair for us to try to address.
00:35:41:12 - 00:35:44:12
Of course, OSFI from a prudential perspective
00:35:44:12 - 00:35:47:17
is going to make sure that things like custody
00:35:47:17 - 00:35:51:03
of funds and securities and so on for financial institutions
00:35:51:22 - 00:35:55:15
is taken care of by whomever a financial institution outsources to
00:35:55:27 - 00:35:56:17
and similarly
00:35:56:17 - 00:35:59:25
for insurers, they'll want to know that certain outsourcing arrangements,
00:36:00:16 - 00:36:04:10
you know, I'm thinking the easier ones or, you know, Treasury functions
00:36:04:10 - 00:36:05:28
and of course they've got asset management
00:36:06:28 - 00:36:09:10
subsidiaries and so on.
00:36:09:10 - 00:36:13:16
From our perspective, first of all, why are we looking at that?
00:36:13:16 - 00:36:17:17
It's because when in our consulting and in our discussions with,
00:36:18:02 - 00:36:21:17
you know, certain commercial brokers, with those representing customers,
00:36:22:28 - 00:36:27:14
they've indicated to us that there are some aspects of functions
00:36:27:14 - 00:36:31:01
that, you know, traditionally might have been the domain of the insurer
00:36:31:11 - 00:36:34:01
and appear to be performed by others
00:36:34:01 - 00:36:36:16
and so we need to learn more about that.
00:36:36:16 - 00:36:39:24
And we will have, you know, whatever measures
00:36:40:20 - 00:36:45:22
come out of that or whatever observations we make will be guided by that evidence.
00:36:46:01 - 00:36:47:08
It really is
00:36:47:08 - 00:36:50:10
a bit of an ‘apples and oranges’ because we're not looking at it
00:36:50:10 - 00:36:52:13
from a prudential safety and soundness perspective.
00:36:52:13 - 00:36:54:27
That is the role for the prudential regulator.
00:36:54:27 - 00:36:56:29
But we know that when there is
00:36:58:17 - 00:37:01:07
let's say that there is not disclosure in terms of,
00:37:01:07 - 00:37:04:07
you know, for example, who's providing the coverage,
00:37:04:07 - 00:37:07:07
then that is something where the consumer can actually
00:37:07:19 - 00:37:09:10
it's reasonable for consumer to want to know that.
00:37:09:10 - 00:37:13:03
So I think that our intention is to work with you and your members to make sure
00:37:13:10 - 00:37:16:03
that we identify and observe issues
00:37:16:03 - 00:37:19:10
that, you know, are understood and socialized with you.
00:37:20:05 - 00:37:23:05
And of course, when we
00:37:23:09 - 00:37:25:29
when we actually publish the findings from that,
00:37:25:29 - 00:37:27:29
we will want to hear more in terms of, you know,
00:37:27:29 - 00:37:30:00
are there other ways to address the issues?
00:37:30:00 - 00:37:30:27
Because ultimately,
00:37:30:27 - 00:37:33:27
it's about the consumer, it's about being fair for the consumer
00:37:34:05 - 00:37:37:18
and not everything requires, you know, a new rule.
00:37:37:18 - 00:37:41:11
Sometimes it could be a practice that's established or a solution
00:37:41:11 - 00:37:42:08
that's derived elsewhere.
00:37:44:10 - 00:37:47:12
So maybe I'll turn this one over to you, Ryan.
00:37:47:12 - 00:37:51:16
How has industry and IBC collaborated with FSRA recently,
00:37:51:16 - 00:37:55:01
and what are some of the initiatives that both IBC and industry
00:37:55:01 - 00:37:58:09
and I'll leave the IBC part to you, Liam.
00:37:58:18 - 00:38:01:07
What plans do you have to engage with regulators in the future
00:38:01:07 - 00:38:04:16
outside of the Technical Advisory Committee that Liam mentioned?
00:38:05:24 - 00:38:06:02
Yeah.
00:38:06:02 - 00:38:10:01
So, I'll sort of just mention and this picks up a little bit
00:38:10:01 - 00:38:13:26
on what Liam said that, you know, FSRA’s approach to transparency
00:38:13:26 - 00:38:18:25
and stakeholder dialogue is quite unique.
00:38:19:23 - 00:38:23:19
You know, everything from the
00:38:23:27 - 00:38:26:11
webinars to launch regulatory initiatives,
00:38:27:00 - 00:38:29:13
willingness to have bilateral meetings with stakeholders
00:38:29:13 - 00:38:32:22
and then obviously the stakeholder and Technical Advisory committees.
00:38:32:22 - 00:38:38:10
These are all great forums for collaboration and, you know,
00:38:38:10 - 00:38:42:18
discussing issues and hopefully arriving at the optimal solution.
00:38:44:00 - 00:38:45:05
You know,
00:38:45:05 - 00:38:48:22
it's hard to separate, you know, and I go deeper into this one,
00:38:49:01 - 00:38:52:01
the auto from the non-auto because at the end
00:38:52:13 - 00:38:55:13
we’re P&C insurance companies, there's people here that are
00:38:56:01 - 00:38:57:06
you know, here because they want to learn
00:38:57:06 - 00:38:58:22
about what's happening in the non-auto space
00:38:58:22 - 00:39:03:04
but they’re pretty much all employed by companies who also work in the auto space.
00:39:03:04 - 00:39:06:28
So it's hard to separate, you know,
00:39:07:09 - 00:39:11:03
the the overall assessment of the interaction with FSRA
00:39:11:07 - 00:39:14:23
and then, you know, what are going to be the next
00:39:15:06 - 00:39:17:09
engagements.
00:39:17:20 - 00:39:20:19
I would say that,
00:39:20:24 - 00:39:24:13
you know, we see generally a move to,
00:39:24:17 - 00:39:28:08
you know, a greater focus on principles-based regulation
00:39:28:08 - 00:39:31:07
and we see it kind of upon ourselves.
00:39:31:07 - 00:39:35:15
We want to be at all the tables that we can because, you know, you're opening your doors,
00:39:35:15 - 00:39:40:16
you want to hear from us and, you know, you meet with us early.
00:39:40:16 - 00:39:44:09
Like sometimes it's not like, you know, we're about to launch this in a week,
00:39:44:09 - 00:39:48:14
let's talk. It's here's a draft survey, we're not sure if you know,
00:39:48:17 - 00:39:51:15
it makes sense to be able to share the information in this format.
00:39:51:15 - 00:39:53:18
Let's talk what this survey's going to look like.
00:39:55:05 - 00:39:58:10
So we want to be at all the tables to sort of
00:39:58:16 - 00:40:02:12
come to a common understanding about what the issue is and then be a position
00:40:02:12 - 00:40:06:05
to work with you on the eventual
00:40:07:17 - 00:40:08:29
solution.
00:40:08:29 - 00:40:11:09
I'll bring up an auto example
00:40:11:09 - 00:40:14:23
of where kind of we see a lot of really great work happening
00:40:14:23 - 00:40:17:23
and that's in the the space of,
00:40:18:21 - 00:40:23:10
you know, the reform strategy for auto rate and underwriting regulation
00:40:23:10 - 00:40:25:25
where FSRA’s been working on this
00:40:25:25 - 00:40:30:21
for a couple of years, it has a, you know, a goal by the end of 2025
00:40:30:21 - 00:40:33:23
to have replaced the traditionally rules-based approach with a more
00:40:34:17 - 00:40:35:26
principles-based one.
00:40:35:26 - 00:40:38:19
And, you know, there's still a lot to be written in this story.
00:40:38:19 - 00:40:42:06
There's probably, you know, a few more consultations to go
00:40:42:29 - 00:40:45:19
but there's a lot of great momentum.
00:40:45:19 - 00:40:50:20
And I think if, you know, FSRA and the industry has to be there
00:40:50:20 - 00:40:56:03
to be ready to engage and collaborate, sort of the momentum we're seeing
00:40:56:03 - 00:40:59:08
in that auto space, I could see translating over into the non-auto space.
00:41:00:14 - 00:41:01:28
Liam, anything to add?
00:41:01:28 - 00:41:04:28
Maybe just briefly, because you had mentioned the
00:41:05:09 - 00:41:08:04
the CCIR and CISRO
00:41:08:04 - 00:41:10:21
project looking at climate risk
00:41:10:21 - 00:41:12:29
and consumer awareness gaps and there's a
00:41:12:29 - 00:41:16:29
fairly significant project being undertaken.
00:41:16:29 - 00:41:20:25
I'm looking at Colin Simpson, who's a large part in it, and
00:41:21:26 - 00:41:25:19
I think that that will be a priority for IBC
00:41:26:21 - 00:41:29:12
over the coming year plus
00:41:29:12 - 00:41:32:12
and, you know, one of the initial observations that
00:41:32:16 - 00:41:35:24
I've made since joining the project, since we're focused on
00:41:36:07 - 00:41:39:14
individual property risks of the homeowner,
00:41:40:23 - 00:41:43:04
is the importance of ensuring
00:41:43:04 - 00:41:46:04
publicly accessible risk mapping.
00:41:46:23 - 00:41:50:15
There was a commitment to that from from the federal government as well
00:41:50:15 - 00:41:54:11
as a commitment to a national flood insurance program in the 2023 budget.
00:41:54:25 - 00:41:57:22
And so while it's not specific to FSRA
00:41:58:19 - 00:42:00:00
over the coming weeks and months
00:42:00:00 - 00:42:01:24
in the lead up to the federal budget, I suspect
00:42:01:24 - 00:42:04:24
you'll hear much from IBC as we try to secure funding
00:42:04:24 - 00:42:08:10
for a national flood insurance program and then continue to work collaboratively
00:42:09:11 - 00:42:12:16
with the federal government on designing the parameters of that program.
00:42:13:15 - 00:42:17:29
I'm going to move subjects and completely move topics to something
00:42:17:29 - 00:42:19:25
I suspect some of you might be interested in
00:42:19:25 - 00:42:23:00
and kind of the review and the supervision plan that we recently published
00:42:23:20 - 00:42:26:06
with respect to P&C MGA’s.
00:42:26:06 - 00:42:29:06
So I'm going to go with another quote because I seem to like these today.
00:42:29:22 - 00:42:32:22
Greg Williams, the Director at AM Best recently said
00:42:32:23 - 00:42:35:21
“With an estimated 80 plus MGA’s in Canada,
00:42:35:21 - 00:42:39:06
they are now the fastest growing segment of Canadian insurance market.
00:42:39:15 - 00:42:42:10
From a commercial lines perspective, estimates are anywhere between
00:42:42:10 - 00:42:45:27
three and a half to 4 billion in premium flowing through MGA’s,
00:42:45:27 - 00:42:49:06
which accounts for approximately 10% of gross written premium.”
00:42:49:22 - 00:42:50:18
So for those of you
00:42:50:18 - 00:42:54:08
that have read our report, we have done some preliminary market intelligence work.
00:42:54:08 - 00:42:57:08
We have done some discussions with industry stakeholders,
00:42:57:26 - 00:43:01:23
spoken to many of you in the room at a peripheral level
00:43:01:23 - 00:43:03:10
and a high level.
00:43:03:10 - 00:43:06:16
We've identified some potential areas of consumer harm
00:43:06:26 - 00:43:09:26
as a result of those outsourcing relationships,
00:43:09:27 - 00:43:13:01
a potential for non-disclosure of conflict of interests
00:43:13:01 - 00:43:17:03
in terms of ownership and who the MGA is owned by.
00:43:17:24 - 00:43:22:02
We had some concerns with respect to non-disclosure of the insurer underwriting the risk.
00:43:22:19 - 00:43:27:05
That is predominantly in subscription policies where the front-end consumer
00:43:27:05 - 00:43:29:23
may not actually know who the insurer on that policy is.
00:43:30:18 - 00:43:34:21
Some potential delays and poor claims management and a lack of understanding
00:43:34:21 - 00:43:37:22
from consumers as to who they complain to
00:43:37:22 - 00:43:40:22
and who do they deal with with respect to a claims if it comes up.
00:43:41:14 - 00:43:43:21
Potential mismanagement of policy funds.
00:43:43:21 - 00:43:47:17
So intermingling of funds, I'm going to say improper management
00:43:47:17 - 00:43:50:23
of a trust account, potentially inefficient
00:43:50:23 - 00:43:53:27
or inadequate E&O insurance or fidelity insurance.
00:43:54:21 - 00:43:58:02
And another one that we heard is insufficient or late
00:43:58:03 - 00:44:01:14
notice of cancellation on a policy, or non-renewal on a policy.
00:44:02:11 - 00:44:04:18
So with respect those preliminary findings,
00:44:06:09 - 00:44:07:14
we're continuing our work.
00:44:07:14 - 00:44:10:22
And I know, Liam, you've mentioned that we're proceeding with our survey,
00:44:11:04 - 00:44:14:03
that we actually have the consultation meetings booked for this week
00:44:14:13 - 00:44:18:02
where our Technical Advisory Committee has been asked to provide us feedback
00:44:18:02 - 00:44:18:27
on that survey
00:44:18:27 - 00:44:22:17
as we iron out kind of the details and the information we’ll be seeking.
00:44:23:06 - 00:44:26:06
We've also asked the Technical Advisory Committee to bring any members
00:44:26:06 - 00:44:29:06
from their organizations to provide us that feedback.
00:44:29:16 - 00:44:32:26
As Liam had said, the more the merrier and the more information we can have
00:44:32:26 - 00:44:37:01
from stakeholders and generally from folks that understand that market
00:44:37:21 - 00:44:40:25
is beneficial for us to look at it from a consumer perspective.
00:44:41:19 - 00:44:44:01
So Huston, I'm going to ask you, why is this work
00:44:44:01 - 00:44:47:01
a priority for FSRA and what are our next steps?
00:44:47:05 - 00:44:51:00
So what's happened is we are the regulator for insurers
00:44:51:04 - 00:44:55:10
and you know, we have stakeholder meetings on a regular basis.
00:44:55:10 - 00:44:58:11
There is a Stakeholder Advisory Committee
00:44:58:11 - 00:45:02:13
that we convene for the benefit of our board and our CEO attends.
00:45:02:13 - 00:45:04:15
We have Technical Advisory Committee meetings
00:45:04:15 - 00:45:08:05
and we have ad hoc meetings with other stakeholders representing
00:45:08:19 - 00:45:11:10
industry as well as consumers.
00:45:11:10 - 00:45:15:20
And at these meetings we use the input to develop our priorities.
00:45:15:20 - 00:45:18:26
We use the input to identify what are potential issues.
00:45:19:06 - 00:45:21:14
Let's say someone comes in and mentions
00:45:21:14 - 00:45:26:01
that they might have concerns about, you know, knowing who's actually on risk
00:45:26:01 - 00:45:29:17
or they might come in and say, you know what, I'm concerned about the,
00:45:29:29 - 00:45:32:29
about the way the trust account might be being managed
00:45:33:06 - 00:45:37:14
or I've got concerns about who I go to in the event of a claim.
00:45:37:29 - 00:45:40:03
At that point, it is,
00:45:40:03 - 00:45:41:20
okay, it's one piece of input.
00:45:41:20 - 00:45:47:05
And what we need to do next is to identify what is the prevalence of this.
00:45:47:05 - 00:45:49:21
Is this a large issue, small issue?
00:45:49:21 - 00:45:52:21
Are there other measures to manage it?
00:45:53:02 - 00:45:55:21
Is it something where we just need more information
00:45:56:19 - 00:45:59:28
or is it a situation where maybe some insurers handle it
00:45:59:28 - 00:46:03:01
a certain way and other insurers handle it a different way?
00:46:03:21 - 00:46:08:08
So the best way to gather that is to actually ask insurers.
00:46:08:08 - 00:46:11:11
So as the regulator, from a conduct perspective for insurers,
00:46:11:22 - 00:46:14:23
we, you know, we published our supervision plan recently
00:46:15:03 - 00:46:17:29
and we intend to gather that evidence
00:46:17:29 - 00:46:20:29
and then subsequently do the analysis to determine
00:46:21:01 - 00:46:25:12
how do we prioritize the, you know, the observations coming out of that.
00:46:25:26 - 00:46:28:03
Well, in some cases, we're going to come and look at this and say,
00:46:28:03 - 00:46:30:06
you know what, This is quite idiosyncratic.
00:46:30:06 - 00:46:32:28
And in some of the cases, we may say, you know what, this is an area,
00:46:32:28 - 00:46:33:23
you know, for example,
00:46:33:23 - 00:46:36:23
when it comes to claims management, there's been public litigation,
00:46:37:09 - 00:46:40:02
you know, from a customer saying, listen, I didn't know who I was dealing with,
00:46:40:02 - 00:46:42:18
I was dealing with this entity, and then it was this entity
00:46:42:18 - 00:46:44:12
and then just, they filed public litigation.
00:46:44:12 - 00:46:47:14
Well, that's a situation where as a regulator, we observe that
00:46:47:14 - 00:46:50:06
and we say to ourselves, if this is just going to happen,
00:46:50:06 - 00:46:52:06
very rarely, then that's one situation.
00:46:52:06 - 00:46:55:13
If it's a risk to consumers, then is it something
00:46:55:13 - 00:46:58:27
where additional measures need to be contemplated?
00:46:59:07 - 00:47:02:11
And so as we gather that information,
00:47:03:12 - 00:47:04:19
that's the next step
00:47:04:19 - 00:47:07:17
and then we will synthesize some views.
00:47:07:17 - 00:47:09:20
We'll share our observations.
00:47:09:20 - 00:47:13:14
And I think it's safe to say that it's obviously very early days.
00:47:13:14 - 00:47:16:29
We just published the supervision plan, but of course, we would,
00:47:17:13 - 00:47:20:21
you know, continue to engage with you and insurers
00:47:20:21 - 00:47:23:23
and those who are in the industry to make sure
00:47:24:10 - 00:47:27:10
that we're prioritizing and identifying the correct matters.
00:47:28:24 - 00:47:31:21
So kind of along those lines, I know we've mentioned we're consulting
00:47:31:21 - 00:47:35:16
with our Technical Advisory Committee, but I'll ask Ryan and Liam specifically,
00:47:36:11 - 00:47:38:23
what can FSRA do to ensure that we're
00:47:38:23 - 00:47:41:19
clearly understanding this market and focusing on the right things?
00:47:41:19 - 00:47:45:18
What advice would you give us when we undertake this process?
00:47:49:18 - 00:47:49:26
Okay.
00:47:49:26 - 00:47:51:06
I'll start off.
00:47:51:06 - 00:47:53:26
I think it's to look at the whole picture.
00:47:55:03 - 00:47:57:26
You know, there were opening remarks about that today
00:47:57:26 - 00:48:00:27
and Huston's talked a little bit about it, too.
00:48:00:27 - 00:48:05:01
So, I mean, you know, who are MGA’s and what's their role in the market?
00:48:05:01 - 00:48:07:10
Well, it's pretty important.
00:48:07:10 - 00:48:11:03
There is often, you know, people or companies that can't
00:48:11:10 - 00:48:14:10
get insurance for just the nature of their risk
00:48:15:00 - 00:48:19:09
from standard insurers and MGA’s are there to fill that gap.
00:48:19:09 - 00:48:22:09
That's important for those customers.
00:48:23:20 - 00:48:24:21
Mainly on the business side,
00:48:24:21 - 00:48:26:18
there are,
00:48:26:21 - 00:48:29:28
business operations that have unique specialty type risks
00:48:29:28 - 00:48:32:15
and, you know, they need coverage
00:48:32:15 - 00:48:36:26
and to provide that coverage, you need an entity that has, you know,
00:48:37:22 - 00:48:39:23
certain like really,
00:48:40:27 - 00:48:41:06
you know,
00:48:41:06 - 00:48:44:06
narrow expertise in underwriting that business
00:48:44:06 - 00:48:47:02
and MGA’s
00:48:47:02 - 00:48:49:15
provide that service.
00:48:49:15 - 00:48:52:15
You know, MGA’s come in various
00:48:52:28 - 00:48:57:11
you know, forms and sizes. They are no different than any other entity
00:48:57:11 - 00:49:01:08
or intermediary that you would see in the P&C insurance space.
00:49:01:08 - 00:49:03:14
Some of them are, you know, pretty big corporations.
00:49:03:14 - 00:49:05:08
They've been around a long time.
00:49:05:08 - 00:49:08:17
They have sophisticated governance frameworks that guide their operations.
00:49:08:17 - 00:49:10:28
There are others that are newer and smaller
00:49:10:28 - 00:49:13:28
and they're not in a position to invest as much,
00:49:14:14 - 00:49:16:09
invest as much there.
00:49:16:09 - 00:49:19:14
From the insurer perspective, you know,
00:49:19:15 - 00:49:23:02
sort of like we've talked about when it comes to other intermediaries.
00:49:24:25 - 00:49:27:01
You know, insurers, we know we're responsible
00:49:27:01 - 00:49:30:25
for the customer experience throughout the product lifecycle
00:49:30:25 - 00:49:34:01
and it's our responsibility to work with,
00:49:35:02 - 00:49:35:19
you know,
00:49:35:19 - 00:49:39:08
whether it's an MGA or whether it's another intermediary or whoever,
00:49:39:09 - 00:49:41:04
to make sure that the outcome
00:49:41:04 - 00:49:46:24
at the end for the customer is optimal and in line with
00:49:47:11 - 00:49:50:11
you know, the regulators expectations.
00:49:51:08 - 00:49:52:06
You know at Definity, and I’m sure
00:49:52:06 - 00:49:56:13
it’s no different at many other companies like when we engage with MGA’s.
00:49:56:13 - 00:49:59:22
You know, MGA is not a huge part of our operations but we do work with them.
00:50:00:22 - 00:50:04:03
We have a due diligence process before we're going to partner with them
00:50:04:03 - 00:50:07:03
and, you know, we conduct audits
00:50:07:03 - 00:50:10:03
to make sure that, you know, the contractual obligations
00:50:10:24 - 00:50:15:15
are achieved. So,
00:50:15:24 - 00:50:19:24
I think, from the regulatory perspective kind of
00:50:20:02 - 00:50:23:29
FSRA will collect the information and see what the,
00:50:24:12 - 00:50:25:26
you know, the nature of any issues.
00:50:25:26 - 00:50:26:25
But, you know
00:50:26:25 - 00:50:30:10
there is multiple you know, you have multiple parties at the table.
00:50:30:12 - 00:50:31:07
Everyone’s...,
00:50:31:16 - 00:50:33:10
MGA’s are serving a very important purpose.
00:50:33:10 - 00:50:37:05
Everyone wants the customer outcome to be a good one
00:50:37:05 - 00:50:40:05
so if there are gaps,
00:50:40:10 - 00:50:41:22
then, you know,
00:50:41:22 - 00:50:45:07
then those will need to be filled in the regulatory space like they're
00:50:45:07 - 00:50:49:09
usually supposed to be filled, which is efficient,
00:50:50:12 - 00:50:54:29
you know, proportionate and risk-based regulation
00:50:54:29 - 00:50:58:01
that all entities can abide by
00:50:58:01 - 00:51:00:05
and sort of move on.
00:51:00:05 - 00:51:01:01
Liam?
00:51:02:21 - 00:51:04:02
Only a few things to add.
00:51:04:02 - 00:51:05:21
I think the first thing I'll say is
00:51:06:07 - 00:51:09:18
we have members that use MGA’s, we have members that don't use MGA’s.
00:51:10:13 - 00:51:12:10
We know, broadly speaking, their prevalence
00:51:12:10 - 00:51:15:09
in the commercial market in Canada is increasing.
00:51:15:22 - 00:51:17:09
Anecdotally, I've heard that their presence
00:51:17:09 - 00:51:20:16
in comparable jurisdictions is even more significant.
00:51:22:06 - 00:51:23:01
I think maybe
00:51:23:01 - 00:51:26:03
just said otherwise, but, Ryan had said it well.
00:51:26:25 - 00:51:29:15
You know, the insurers that I've spoken to,
00:51:29:15 - 00:51:33:14
they understand that they're responsible for their customers regardless of
00:51:33:14 - 00:51:35:03
where the claim is underwritten or
00:51:35:03 - 00:51:38:05
where the claim is handled and the product is underwritten.
00:51:38:27 - 00:51:41:27
I think one of the things you will
00:51:42:29 - 00:51:46:01
uncover from this exploration of
00:51:47:12 - 00:51:50:01
insurer outsourcing relationships with MGA’s
00:51:50:01 - 00:51:54:24
is the incentives in place between insurers and MGA’s.
00:51:54:24 - 00:51:56:13
Put simply,
00:51:56:13 - 00:52:00:01
it's carrier’s money, it's carrier’s capital that is being used by MGA’s.
00:52:00:01 - 00:52:04:27
There's incentives in place to have a rigorous relationship there.
00:52:04:27 - 00:52:07:20
You know, Ryan had mentioned, there's underwriting audits,
00:52:07:20 - 00:52:09:20
there's financial audits
00:52:09:20 - 00:52:12:00
and, you know, from what we've heard from our members,
00:52:12:00 - 00:52:16:09
they establish clear processes that outline their expectations of MGA’s.
00:52:17:08 - 00:52:18:22
And we're looking forward to being part of the
00:52:18:22 - 00:52:21:01
exploratory conversation with FSRA.
00:52:21:03 - 00:52:24:03
Good thing those are some of the questions in the questionnaire.
00:52:25:28 - 00:52:28:15
I know we've talked a lot about kind of some of the future work
00:52:28:15 - 00:52:32:07
that we're looking into and collaboration, but I thought it might be worthwhile
00:52:32:15 - 00:52:35:22
to actually go back and I'll ask you, Ryan, first
00:52:36:04 - 00:52:38:14
some examples of the work that we have done together
00:52:38:14 - 00:52:41:13
or you have done together with FSRA in terms of collaboration
00:52:42:01 - 00:52:45:00
and kind of the focus on consumers.
00:52:45:04 - 00:52:45:17
Yeah.
00:52:45:17 - 00:52:48:23
So in the non-auto space, obviously it's a little bit.
00:52:48:23 - 00:52:49:12
Auto is next door.
00:52:49:13 - 00:52:50:00
Yeah, I know.
00:52:50:00 - 00:52:53:01
It's a little bit, it's a little bit newer,
00:52:53:12 - 00:52:54:23
but we're off to a good start.
00:52:54:23 - 00:52:57:25
You know, there's been a lot of opportunities for information sharing
00:52:57:25 - 00:53:01:16
and, you know, when I look at FSRA’s website, the consumer section of it,
00:53:01:16 - 00:53:03:25
FSRA is an authoritative figure here
00:53:04:12 - 00:53:07:12
so the information that it posts is really important.
00:53:07:19 - 00:53:12:19
There's lots of great information for home and business customers
00:53:13:08 - 00:53:16:06
about, you know, what goes into making up their premium
00:53:16:06 - 00:53:17:14
ways they can lower their premium
00:53:17:14 - 00:53:21:16
and what their rights and responsibilities are as customers.
00:53:21:16 - 00:53:24:29
So just, you know, sharing that information, I think is great.
00:53:25:22 - 00:53:27:19
You know, this isn't an auto example,
00:53:27:19 - 00:53:30:28
but I'll use just a broader FSRA example, you know, the work that
00:53:32:07 - 00:53:33:16
that's underway about,
00:53:33:16 - 00:53:36:17
you know, making sure that vulnerable customers
00:53:37:01 - 00:53:42:10
have good experiences throughout the financial services sector.
00:53:42:10 - 00:53:43:17
This isn't just P&C Insurance,
00:53:43:17 - 00:53:45:22
It's all FSRA, you know, regulated entities
00:53:45:22 - 00:53:49:23
and it's just a great example of, you know, FSRA identified an issue
00:53:50:20 - 00:53:53:01
and is really pulling, you know, all stakeholders
00:53:53:01 - 00:53:55:17
together really early, like not trying to, you know,
00:53:55:17 - 00:53:58:20
figure out the answers on its own, but to really collaborate
00:53:59:10 - 00:54:03:13
with customers in this case and then also with the regulated entities
00:54:04:04 - 00:54:09:19
to talk about it, learn what companies’ internal processes are
00:54:09:19 - 00:54:12:15
to accommodate customers who might need a little bit more help
00:54:12:15 - 00:54:14:29
in their journey, whether it's to purchase insurance
00:54:14:29 - 00:54:17:29
or to go through the claims process.
00:54:18:16 - 00:54:20:22
So to me,
00:54:20:22 - 00:54:25:04
that’s just a really good example of, you know, it still has to play out
00:54:25:04 - 00:54:26:09
and I hear it's multiyear.
00:54:26:09 - 00:54:29:17
So, you know, this this story will end maybe in 2026, 2027,
00:54:30:13 - 00:54:33:18
but it's again, you know, all parties in the industry
00:54:33:18 - 00:54:36:28
who care about the same person, in this case, the customer
00:54:37:09 - 00:54:39:23
working together to see if there's an issue
00:54:39:23 - 00:54:41:10
and if there is work together on a solution.
00:54:42:18 - 00:54:43:19
Liam?
00:54:43:19 - 00:54:45:14
Just briefly on the auto side of things
00:54:45:14 - 00:54:47:11
that just came to mind through Ryan's comments.
00:54:47:25 - 00:54:50:05
But FSRA’s
00:54:50:05 - 00:54:53:10
reaction post-pandemic in terms of providing insurers
00:54:53:10 - 00:54:57:10
with the tools they needed to offer relief, whether through deferral
00:54:57:15 - 00:55:00:28
or reductions to consumers, I think was welcome and
00:55:01:14 - 00:55:06:03
I don't know if it's appreciated how much the P&C industry did not just on auto
00:55:06:03 - 00:55:09:06
but on all lines of insurance during the pandemic.
00:55:09:06 - 00:55:12:05
I think the total figure was $3.6 billion in relief.
00:55:12:05 - 00:55:16:00
I don't know if there's another sector, certainly not in the financial services
00:55:16:12 - 00:55:19:13
that did as much as P&C did, but FSRA was a part of that.
00:55:19:23 - 00:55:21:17
Same with the recent auto theft crisis.
00:55:21:17 - 00:55:25:05
There's surcharging happening in Ontario and elsewhere.
00:55:26:06 - 00:55:28:27
And FSRA has been, by all accounts, very understanding of
00:55:29:27 - 00:55:32:27
the importance of addressing
00:55:33:05 - 00:55:36:05
the surge we've seen in thefts in the GTA in particular,
00:55:36:28 - 00:55:39:25
and the price signals that are that are being sent.
00:55:39:25 - 00:55:42:25
I think maybe just briefly on non-auto, sorry,
00:55:43:24 - 00:55:47:22
We did great work together during the peak of the hard commercial market,
00:55:47:22 - 00:55:51:25
which was exacerbated by the pandemic on business supports
00:55:52:03 - 00:55:53:00
and the core of that.
00:55:53:00 - 00:55:55:28
You know, Ryan will remember because if he doesn't mind me saying this,
00:55:55:28 - 00:56:01:27
he was an IBC staffer at the time, but we launched through the through IBC
00:56:01:27 - 00:56:04:20
but the members drove this was the Business Insurance Action Team,
00:56:04:20 - 00:56:09:11
which is essentially a facility for SMEs in the hospitality sector in Ontario.
00:56:09:11 - 00:56:11:22
It wrote dozens of policies.
00:56:11:22 - 00:56:14:18
You know, it was meant to be a short term, an interim measure
00:56:15:24 - 00:56:17:25
that helped businesses
00:56:17:25 - 00:56:20:28
who were hardest hit by the pandemic get by.
00:56:21:21 - 00:56:24:26
And the latest figures I've seen actually show that 95% of
00:56:24:26 - 00:56:28:03
the businesses that went through the BIAT, as we called it, are still in operation
00:56:28:25 - 00:56:31:10
today and have found coverage in the regular market.
00:56:31:10 - 00:56:35:28
We also offered free risk management services to businesses across Canada.
00:56:35:28 - 00:56:38:01
Hundreds of businesses took us up on that.
00:56:38:01 - 00:56:40:19
And FSRA, I wasn't as close to at the time, but
00:56:40:19 - 00:56:43:19
I know it was with us
00:56:43:23 - 00:56:45:17
every step of the way,
00:56:45:17 - 00:56:48:28
asking the right questions, encouraging the right kinds of responses,
00:56:49:13 - 00:56:53:11
and fostering sort of three way dialogue, government, regulator, industry.
00:56:53:11 - 00:56:56:12
So I think we can share mutual credit for that initiative.
00:56:56:22 - 00:56:57:25
Let me just jump in.
00:56:57:25 - 00:57:01:06
I mean, right now it's March of ‘24, right?
00:57:01:06 - 00:57:04:08
Anyone remember what you're doing four years ago, March of 2020?
00:57:04:19 - 00:57:09:11
I think, especially towards the back half of March of 2020,
00:57:09:11 - 00:57:13:13
everyone was sort of if you were out of town, you were rushing back home.
00:57:13:21 - 00:57:16:21
Offices were figuring out how to work remotely.
00:57:16:23 - 00:57:18:17
And you know what? We were doing.
00:57:18:17 - 00:57:22:29
FSRA was having calls with industry daily.
00:57:23:14 - 00:57:26:14
There was a standing daily call
00:57:26:18 - 00:57:29:11
because we were talking about three things relief,
00:57:31:03 - 00:57:33:02
access
00:57:33:02 - 00:57:35:06
and claims handling.
00:57:35:06 - 00:57:39:05
The relief piece, thankfully, is, you know, the pandemic aspect
00:57:39:05 - 00:57:42:25
and the health aspect that appears to have subsided.
00:57:43:07 - 00:57:46:15
The other two parts access and claims handling.
00:57:47:10 - 00:57:50:29
Those persist in different verticals in different areas.
00:57:51:15 - 00:57:54:15
But it just does speak to the level of communication
00:57:54:15 - 00:57:58:00
that I think is necessary from time to time and that everyone
00:57:58:00 - 00:58:01:06
was very willing to be part of during the depths of the pandemic.
00:58:01:06 - 00:58:04:02
I just want to share that because, you know, I missed those daily calls.
00:58:04:02 - 00:58:07:12
And what I found incredible about that period of time is
00:58:07:12 - 00:58:10:05
something would come across our desk and there would be a concern
00:58:10:05 - 00:58:13:08
and I would call whether it was IBC or call in
00:58:13:08 - 00:58:16:24
or one of the member, or one of the insurers with a question.
00:58:17:00 - 00:58:20:16
And 99% of the time it was, yes, we know about it.
00:58:20:16 - 00:58:21:25
We've already solved the solution
00:58:21:25 - 00:58:24:04
or we're working on a solution or here's what we're going to do
00:58:24:04 - 00:58:27:05
or here's how we can help or here's a link to a solution.
00:58:27:05 - 00:58:31:08
It was an incredible time where industry genuinely came together.
00:58:32:03 - 00:58:35:15
And I think that's what started really that relationship of collaboration
00:58:35:15 - 00:58:38:15
and that ongoing dialogue and that communication.
00:58:38:16 - 00:58:41:22
And I think that we hope to build on that relationship
00:58:41:22 - 00:58:43:23
as we go forward, because I think it started
00:58:43:23 - 00:58:47:08
with that trust and transparency that we can continue forward with.
00:58:47:28 - 00:58:49:16
I'm going to
00:58:49:16 - 00:58:51:19
land on the last question with Huston.
00:58:51:19 - 00:58:56:24
One of our key deliverables in our annual business plan is
00:58:56:24 - 00:59:01:00
the building and the drafting of a non-auto P&C supervision framework.
00:59:01:10 - 00:59:04:18
Can you give us some insights into what that framework will involve?
00:59:04:24 - 00:59:07:23
I'll caveat this with we will consult on the framework,
00:59:07:23 - 00:59:08:28
the TAC will hear about it.
00:59:08:28 - 00:59:10:15
We're open to any feedback,
00:59:10:15 - 00:59:13:26
but just some, I would say, high level preliminary ideas of where we're looking.
00:59:14:13 - 00:59:17:15
I think that it's fair to say we're always going to address areas
00:59:17:15 - 00:59:22:04
that are meaningful and of importance to consumers, what matters most.
00:59:22:04 - 00:59:26:10
So I mentioned things like access, things like, you know, claims handling,
00:59:26:27 - 00:59:29:13
fundamental fairness when it comes to having information
00:59:29:13 - 00:59:32:13
needed for consumer to make their decisions is very important.
00:59:32:26 - 00:59:35:13
We will do we will do our work
00:59:35:13 - 00:59:38:21
based on evidence and observations that we have.
00:59:38:22 - 00:59:40:17
That's why we have the survey out there.
00:59:40:17 - 00:59:42:27
That's why we have stakeholder
00:59:42:27 - 00:59:46:07
events and meetings and stakeholder committees for that very reason.
00:59:46:26 - 00:59:49:11
Where does that lead to supervision
00:59:49:11 - 00:59:53:19
as well as the ability to use a risk-based assessment
00:59:54:25 - 00:59:57:01
to build on some of the comments from this morning's
00:59:57:01 - 01:00:02:12
plenary session, we need data sometimes in order to actively increase
01:00:02:12 - 01:00:06:11
the intensity of supervision for certain aspects or certain areas of a business
01:00:07:02 - 01:00:09:11
and in some cases, you know, dial down
01:00:09:11 - 01:00:13:00
the supervisory intensity for other aspects or other businesses.
01:00:13:07 - 01:00:16:24
But to do that, we need to use tools such as surveys and data.
01:00:17:10 - 01:00:20:26
So being a risk-based regulator, a principal-based regulator,
01:00:20:26 - 01:00:22:17
I think will ultimately help.
01:00:22:17 - 01:00:27:24
There is certainly an awareness about the overall burden of regulation,
01:00:27:24 - 01:00:30:24
and we believe that using a risk based approach will help with that.
01:00:31:19 - 01:00:33:16
And the last thing I would add is transparency.
01:00:33:16 - 01:00:37:26
We're transparent with what our plans are, with what our supervisory plans are.
01:00:38:01 - 01:00:42:14
We will be transparent with our findings, both in terms of the habitation overview
01:00:42:14 - 01:00:44:25
as well as the insurer outsourcing arrangements.
01:00:45:07 - 01:00:48:05
And in addition to that, we will also identify, you know,
01:00:48:05 - 01:00:52:22
here are some of the tools as appropriate, as necessary,
01:00:53:11 - 01:00:56:22
and in a measured way based on what those observations are.
01:00:57:01 - 01:01:00:01
So you've got some of that data gathering,
01:01:00:22 - 01:01:03:22
you've got the commitment to transparency, but it starts
01:01:03:22 - 01:01:06:27
with what is important to consumers, we’ll always be focused on that.
01:01:08:19 - 01:01:10:23
I think we're actually managing to stay on time.
01:01:10:23 - 01:01:12:23
So thank you for the robust conversation.
01:01:12:23 - 01:01:15:23
I guess we now turn it over to the Q&A portion.
01:01:16:06 - 01:01:19:25
Just a reminder, the team in the back is accepting any questions through the app.
01:01:20:17 - 01:01:21:24
If we don't get to any,
01:01:21:24 - 01:01:25:04
to some of the questions they will be posted on our website after the fact,
01:01:25:28 - 01:01:28:28
and then I think you can start sending them through.
01:01:33:13 - 01:01:36:12
I may have to go back to naming dwarfs.
01:01:37:20 - 01:01:41:00
I still have some rapid fire questions if I need to kill time, gentlemen.
01:01:41:00 - 01:01:43:08
No more rapid fire questions.
01:01:45:29 - 01:01:48:20
Sorry, we have someone that can write that down for you.
01:01:53:15 - 01:01:55:15
They’re not showing up.
01:02:00:08 - 01:02:02:08
Here we go.
01:02:02:08 - 01:02:03:04
Okay.
01:02:03:04 - 01:02:07:22
Following the P&C Insurers Managing General Agent Supervision Plan publication,
01:02:07:22 - 01:02:11:12
is FSRA considering licensing P&C MGAs?
01:02:11:12 - 01:02:13:01
Huston, I’m going to turn that one over to you.
01:02:13:01 - 01:02:14:12
Well, I guess that one’s for me.
01:02:14:19 - 01:02:18:27
I think at this point, what we're doing is we've identified some areas
01:02:18:27 - 01:02:23:25
where it's come to our attention that there is an outsourcing by insurers.
01:02:24:08 - 01:02:26:19
We want to see what looks like. We want to see
01:02:27:18 - 01:02:33:22
how, you know, the incidents, how is it real, what is, what are concerns,
01:02:34:02 - 01:02:37:23
you know, to the extent there are concerns, you know, what
01:02:37:23 - 01:02:42:06
are the measures then would be appropriate to address those concerns.
01:02:42:06 - 01:02:45:12
And there are a myriad of ways to address issues,
01:02:46:06 - 01:02:48:14
you know, outside of licensing.
01:02:48:14 - 01:02:52:11
So I think right now the the focus is on identifying,
01:02:52:22 - 01:02:56:17
you know, what stakeholders have brought to us and identified as potential issues,
01:02:56:28 - 01:02:59:26
things that Beata mentioned, you know, who's handling the claim?
01:02:59:26 - 01:03:02:25
Who am I doing business with? Disclosure,
01:03:03:19 - 01:03:07:21
being able to be certain that things like, you know,
01:03:07:22 - 01:03:10:22
trust accounts are handled appropriately, things like that.
01:03:10:24 - 01:03:13:05
And I think that the measures that we take
01:03:13:05 - 01:03:17:26
will depend on what we find and also in additional consultation.
01:03:17:26 - 01:03:21:12
So I think that, you know, this is not something we're looking at right now.
01:03:21:12 - 01:03:23:13
Right now we're looking at just saying
01:03:23:13 - 01:03:26:00
what is the landscape out there, What's going on?
01:03:26:00 - 01:03:28:13
And based on what we find, then we'll take appropriate measures.
01:03:31:11 - 01:03:34:10
Next one.
01:03:38:20 - 01:03:41:20
Soon. We have some technical difficulties.
01:03:45:13 - 01:03:48:13
Here we go.
01:03:50:10 - 01:03:53:19
In regulatory guidance, insurance companies are clearly accountable
01:03:53:19 - 01:03:57:12
for their distribution channel complying with legal and regulatory requirements.
01:03:57:24 - 01:04:00:17
How does FSRA expect that this will be operationalized
01:04:00:17 - 01:04:02:15
in a practical manner in the market?
01:04:02:15 - 01:04:05:14
Have insurance companies pushed back on this accountability?
01:04:05:14 - 01:04:07:09
And where do you see it evolving?
01:04:07:09 - 01:04:09:05
Kind of along the same lines as the previous question.
01:04:09:05 - 01:04:12:05
So I'll send it to Huston.
01:04:12:21 - 01:04:16:09
I think that this is an important matter, right?
01:04:16:11 - 01:04:22:08
I think that this is where data and evidence and the results of our survey
01:04:22:08 - 01:04:27:02
will really help because it is important if there is going to be fairness,
01:04:27:21 - 01:04:31:27
if it is going to be operationalized, people expect and
01:04:31:27 - 01:04:34:14
it's only fair that it actually applies to everyone.
01:04:34:14 - 01:04:36:03
It's a level playing field.
01:04:36:03 - 01:04:38:07
It can't just be okay just here
01:04:38:07 - 01:04:40:29
but over here, something else really bad is happening.
01:04:40:29 - 01:04:43:01
So that is the power of being transparent.
01:04:43:01 - 01:04:45:27
That is the power of actually gathering data from the insurers.
01:04:45:27 - 01:04:49:27
I think it would be a combination of
01:04:50:29 - 01:04:52:23
what the solution
01:04:52:23 - 01:04:55:23
I think will lie based on the incidents
01:04:55:24 - 01:04:59:10
and then, you know, who is best situated to deal with that.
01:04:59:10 - 01:05:03:22
So, for example, we've had situations in the past where we pick up the phone
01:05:03:22 - 01:05:08:05
and we say to insurers, this is the issue we'd like to work with you on this.
01:05:08:21 - 01:05:11:11
Is there clarity we can put on this topic?
01:05:11:11 - 01:05:14:22
And in some cases, FSRA then has subsequently published Guidance
01:05:15:04 - 01:05:18:00
to clarify that this is the interpretation.
01:05:18:00 - 01:05:20:16
And we think that in many cases,
01:05:20:16 - 01:05:23:04
that's actually led to the change that's required.
01:05:23:04 - 01:05:25:12
In other cases, it's a little more complicated.
01:05:25:12 - 01:05:29:08
But in yet and still other cases, sometimes it's consumer education,
01:05:29:15 - 01:05:32:16
sometimes it's just making sure that people understand the landscape.
01:05:33:15 - 01:05:36:13
We will be around afterwards for follow up as well.
01:05:36:13 - 01:05:40:14
But I think that what we want is a level playing field, a fair playing field,
01:05:41:01 - 01:05:43:29
and where we identify something that needs to be corrected,
01:05:43:29 - 01:05:47:12
we obviously, we absolutely will work with industry and with consumers
01:05:47:22 - 01:05:50:22
to make sure that it's executed fairly.
01:05:51:10 - 01:05:53:07
The next one is up.
01:05:53:07 - 01:05:57:08
Given FSRA delegation of broker regulation to RIBO, a self-regulatory
01:05:57:08 - 01:06:01:20
organization, how do they intend to work with RIBO to agree on and work towards
01:06:01:20 - 01:06:05:12
common priorities, approaches and goals when it comes to the P&C industry?
01:06:06:12 - 01:06:09:07
So RIBO, as you all know, is
01:06:09:07 - 01:06:12:07
the regulator of insurance brokers.
01:06:12:09 - 01:06:14:06
You know, they're represented here.
01:06:14:06 - 01:06:18:02
We work with them on a regular basis.
01:06:19:11 - 01:06:22:29
I think that there are issues that are, of course,
01:06:23:09 - 01:06:27:26
broker issues and you know, we always take those to RIBO,
01:06:27:26 - 01:06:30:26
as the regulator for that area.
01:06:31:14 - 01:06:34:14
Where there are insurer issues,
01:06:35:02 - 01:06:39:11
you know, FSRA is the regulator from a conduct perspective of insurers
01:06:39:22 - 01:06:43:12
and we will take concerns we have related to insurers,
01:06:43:19 - 01:06:49:18
whether they be insurer conduct, insurer outsourcing, whatever the case may be.
01:06:49:18 - 01:06:51:26
We'll take those very seriously.
01:06:51:26 - 01:06:54:25
Where there are areas for intercept
01:06:55:04 - 01:06:58:20
when, you know, you may be dealing with a common situation
01:06:58:28 - 01:07:01:25
that is experienced by both brokers
01:07:01:25 - 01:07:05:02
as well as insurers, then of course we will collaborate.
01:07:05:02 - 01:07:08:02
So a good example of that was the Take All Comers review.
01:07:08:09 - 01:07:10:24
We worked very closely with RIBO
01:07:10:24 - 01:07:15:21
because there are, you know, brokers were helpful sources of information
01:07:15:21 - 01:07:18:21
and they were also letting us know about some of their concerns.
01:07:18:26 - 01:07:21:11
And of course, there were insurers on the other side.
01:07:21:11 - 01:07:24:04
So I like to be an optimist about this.
01:07:24:04 - 01:07:27:04
I think this is something that needs to happen and it can happen.
01:07:27:14 - 01:07:29:26
And we should definitely work together.
01:07:29:26 - 01:07:32:06
And I'll just add to that, I think the one thing
01:07:32:06 - 01:07:35:06
one of the things we've learned over the last couple of years is
01:07:35:16 - 01:07:39:16
the important role that brokers play in the lives of consumers
01:07:40:05 - 01:07:42:21
and the information that brokers hold.
01:07:42:21 - 01:07:46:18
Brokers generally are the front line access for consumers.
01:07:46:18 - 01:07:48:10
They have the information.
01:07:48:10 - 01:07:51:06
Often it's the brokers that can identify a potential issue
01:07:51:06 - 01:07:54:24
or a potential trend that's coming up before anybody else is aware of it.
01:07:54:24 - 01:07:57:24
So I think ongoing collaboration with brokers,
01:07:57:25 - 01:08:00:25
we actually have brokers on our Technical Advisory Committee
01:08:01:11 - 01:08:04:01
because we believe they're part of that whole ecosystem.
01:08:04:01 - 01:08:07:07
So in order for us to do supervision, we need to have
01:08:07:07 - 01:08:10:07
that holistic approach and brokers are definitely a part of that.
01:08:11:00 - 01:08:12:01
See, I can't help myself.
01:08:12:01 - 01:08:14:21
I was supposed to moderate, not answer questions.
01:08:14:21 - 01:08:15:17
Okay.
01:08:15:17 - 01:08:16:02
Next one.
01:08:16:02 - 01:08:19:00
On the topic of consumer education related to Nat CAT,
01:08:19:09 - 01:08:22:19
how would you characterize the role of various regulatory bodies,
01:08:22:19 - 01:08:27:10
provincial and federal, including FCAC and marketplace stakeholders should be?
01:08:27:10 - 01:08:28:19
In a perfect world,
01:08:28:19 - 01:08:31:07
what would you recommend to ensure coordination?
01:08:31:07 - 01:08:33:04
I don't know who wants to take this one.
01:08:33:04 - 01:08:34:28
I can start.
01:08:34:28 - 01:08:40:10
I touched on this concept of harmonization when we were talking
01:08:40:10 - 01:08:44:27
about fair treatment of customers and the CCIR guidance.
01:08:45:25 - 01:08:49:07
When I think of, you know, consumer education related to Nat CAT, I think of,
01:08:50:04 - 01:08:54:06
you know, this is a market conduct issue that largely
01:08:55:24 - 01:08:56:27
resides with
01:08:56:27 - 01:09:00:23
the provincial insurance regulators.
01:09:00:23 - 01:09:04:01
So I like the idea of using the Canadian Council of Insurance Regulators
01:09:04:01 - 01:09:06:14
to be the the group that engages
01:09:06:14 - 01:09:09:14
with various industry stakeholders to talk about it.
01:09:10:17 - 01:09:12:02
This is also a multiyear project.
01:09:12:02 - 01:09:16:17
I don't know what the outcome is going to be, but presumably a harmonized,
01:09:17:22 - 01:09:19:21
a harmonized approach, whatever that is.
01:09:19:21 - 01:09:22:22
Some guidance or whatever it comes out to be
01:09:22:23 - 01:09:25:29
is better than a fragmented approach
01:09:25:29 - 01:09:31:06
and CCIR already has various, you know, stakeholder forums for
01:09:32:02 - 01:09:35:02
stakeholders, you know, insurers, brokers to contribute.
01:09:35:04 - 01:09:37:08
I see the FCAC is there.
01:09:37:08 - 01:09:41:15
I'm, you know, I can't really speak specific to the FCAC's role,
01:09:41:15 - 01:09:43:25
but if there is a role for that organization,
01:09:43:25 - 01:09:45:15
I think that that should be coordinated through
01:09:46:17 - 01:09:48:16
the CCIR
01:09:48:16 - 01:09:50:17
to best determine versus having,
01:09:50:17 - 01:09:53:18
you know, one organization kind of go in and try to do its own thing
01:09:53:19 - 01:09:57:11
that doesn't feel part of this other initiative.
01:09:57:11 - 01:10:00:10
It'd be best if all parties are working together
01:10:00:10 - 01:10:02:00
in a perfect world.
01:10:02:00 - 01:10:03:14
I agree with everything Ryan said.
01:10:03:14 - 01:10:04:26
I would only add that I know,
01:10:04:26 - 01:10:09:27
and the reference to FCAC may be because there was a recent consultation
01:10:10:04 - 01:10:13:04
launched by the FCAC that specific to
01:10:14:08 - 01:10:17:27
claims and in keeping with, Ryan said, our view
01:10:17:28 - 01:10:22:16
is that sort of accountability lies with provincial market conduct regulators
01:10:22:16 - 01:10:25:16
and I think our our position as an industry to the FCAC
01:10:25:22 - 01:10:28:21
has been just that.
01:10:28:26 - 01:10:29:22
Huston, anything?
01:10:31:04 - 01:10:33:21
Is that it for questions?
01:10:36:11 - 01:10:37:01
Okay.
01:10:37:01 - 01:10:38:11
Next one.
01:10:38:11 - 01:10:41:14
The insurance industry receives a number of consumer complaints.
01:10:42:18 - 01:10:44:18
Do the panel believe we should be more open
01:10:44:18 - 01:10:48:00
about celebrating our successes while resolving our challenges?
01:10:48:00 - 01:10:49:11
And if so,
01:10:49:11 - 01:10:52:11
what should we do and what should we do differently?
01:10:52:14 - 01:10:54:25
I have a feeling you guys have a lot to say about this.
01:10:54:25 - 01:10:57:09
The answer is yes
01:10:57:09 - 01:10:59:29
and I don't know if anyone knows how to do it.
01:10:59:29 - 01:11:01:21
That's the tough part.
01:11:01:21 - 01:11:04:26
You know, to the discussion we had on natural catastrophes.
01:11:04:26 - 01:11:06:19
I mean, there's, you know, I tried to list off
01:11:06:19 - 01:11:09:19
kind of a lot of good things that insurers
01:11:09:25 - 01:11:13:16
and intermediaries are doing in trying to create more value for the customer.
01:11:13:16 - 01:11:15:28
But yeah, it just doesn't get out and the focus continues
01:11:15:28 - 01:11:20:13
to be on complaints, on price but there's really so much there.
01:11:20:13 - 01:11:23:17
So if there are any marketers, advertisers
01:11:23:17 - 01:11:27:05
in the room, I mean this is a multi, multi-million dollar
01:11:28:04 - 01:11:31:04
initiative to try to solve.
01:11:32:21 - 01:11:34:01
Well said and
01:11:34:01 - 01:11:39:05
it’s a, I think, a perennial issue that we at IBC talk about and struggle with
01:11:39:05 - 01:11:42:28
but it's funny, the you know,
01:11:43:15 - 01:11:47:19
the overwhelming majority of claims go smoothly without incident.
01:11:48:04 - 01:11:51:16
The overwhelming majority of consumer’s interactions
01:11:51:16 - 01:11:55:12
with their broker or agent or direct insurer go very smoothly
01:11:55:12 - 01:11:59:21
but we do tend to hear most about the friction points.
01:12:00:08 - 01:12:01:28
And if there's more we can do
01:12:01:28 - 01:12:05:04
and I think we have something in store at IBC this year in terms of
01:12:05:04 - 01:12:09:10
pointing to the value of the industry and then we should do so.
01:12:09:10 - 01:12:11:22
So stay tuned for more from us.
01:12:12:25 - 01:12:15:01
We're dealing with something that is essential
01:12:15:07 - 01:12:18:13
for most homeowners, right, when it comes to,
01:12:19:01 - 01:12:22:00
you know, their experience, let’s say, on the habitation overview.
01:12:22:00 - 01:12:27:06
I think our publication will also shed some light in terms of what's happening.
01:12:27:06 - 01:12:30:01
And, you know, to your points, it is the case
01:12:30:01 - 01:12:34:17
in the majority of the circumstances, people get the coverage that they need.
01:12:35:16 - 01:12:38:11
And I think what we will do is track through,
01:12:38:11 - 01:12:41:26
you know, some of the timeliness issues that may be there,
01:12:42:01 - 01:12:43:16
but that will also identify that,
01:12:43:16 - 01:12:46:15
you know, in many, many cases, people do get their claim resolved
01:12:46:16 - 01:12:47:25
and they do get what they need.
01:12:47:25 - 01:12:52:15
They get the support that they desperately require just at the right time.
01:12:52:15 - 01:12:55:11
So I think that this is something we can continue to work on together
01:12:55:11 - 01:12:58:26
and we will be able to share data related to that quite soon.
01:12:59:26 - 01:13:02:11
So that brings us to the conclusion of our session.
01:13:02:11 - 01:13:05:18
We hope you received some helpful information and we hope
01:13:05:18 - 01:13:08:23
that you took away the message that we have.
01:13:08:23 - 01:13:12:06
We look forward to continuing to collaborate with you.
01:13:12:11 - 01:13:14:19
Our doors are always open, whether it's through kind of
01:13:14:19 - 01:13:18:02
the formal engagement with our Technical or Stakeholder Advisory Committees
01:13:18:18 - 01:13:21:08
or through one-on-one interactions or through me bugging
01:13:21:08 - 01:13:24:11
some of you in the audience or on the stage here for information.
01:13:25:20 - 01:13:28:21
If you're in the app, there is a feedback section.
01:13:28:21 - 01:13:30:20
It's called the feedback section,
01:13:30:20 - 01:13:33:00
a little loop on our app.
01:13:33:00 - 01:13:36:22
We are looking for feedback to improve conferences for the future
01:13:37:09 - 01:13:40:08
and I invite you all to join us to continue the discussion.
01:13:40:08 - 01:13:41:10
I believe there will be some.
01:13:41:10 - 01:13:45:01
There’s a short reception outside with some refreshments and a cash bar.
01:13:46:02 - 01:13:46:14
Thank you.
00:00:04:28 - 00:00:06:06
I want to introduce myself.
00:00:06:06 - 00:00:07:15
My name is Wendy Horrobin,
00:00:07:15 - 00:00:11:02
I'm the Head of Licensing and Risk Assessment for FSRA.
00:00:11:15 - 00:00:16:07
So in addition to licensing and some market conduct enforcement,
00:00:16:17 - 00:00:20:19
I oversee the unit who has been responsible
00:00:20:19 - 00:00:24:05
for operationalizing the title protection framework.
00:00:24:05 - 00:00:27:19
So for those of you who may be part of a CB,
00:00:27:19 - 00:00:32:16
they're the people that did their recent supervision examination.
00:00:34:07 - 00:00:37:16
We have a few housekeeping items
00:00:37:24 - 00:00:41:20
to remind everybody of, whether you're in person here
00:00:41:20 - 00:00:46:04
or virtually, which welcome as well, those who are on virtually.
00:00:46:20 - 00:00:50:04
I want to remind everyone that this session is being taped
00:00:50:13 - 00:00:54:10
and we have simultaneous French translation available
00:00:54:10 - 00:00:56:16
for those who wish to do so.
00:00:56:16 - 00:00:58:08
If so, you can just raise your hand.
00:00:58:08 - 00:00:59:24
We'll provide you with a headset.
00:01:01:13 - 00:01:05:03
And if you're at home, you can click on the top-right
00:01:05:03 - 00:01:08:25
of the screen and change your language to French.
00:01:09:27 - 00:01:12:08
So we will be taking
00:01:12:08 - 00:01:15:11
some questions at the end of the session.
00:01:15:11 - 00:01:17:14
And as we saw this morning,
00:01:17:14 - 00:01:20:14
all of the questions are being run through the app.
00:01:21:07 - 00:01:24:16
If for whatever reason, you couldn't get on the app, just raise your hand
00:01:24:16 - 00:01:29:00
and one of our team members at the back will come and write down your question
00:01:29:00 - 00:01:32:01
and pose it to us up at the front.
00:01:35:03 - 00:01:39:00
And that brings us to our panel.
00:01:39:22 - 00:01:42:11
So let me introduce you very briefly to the panel.
00:01:42:11 - 00:01:46:25
I won't go through the whole bio because it's available to you on the website.
00:01:46:25 - 00:01:50:11
But in order to my left, we have Marie Muldowney.
00:01:50:23 - 00:01:56:07
She is the Managing Director of the Canadian Securities Institute, CSI
00:01:57:18 - 00:01:58:28
(it's a division of Moody's)
00:01:58:28 - 00:02:01:28
and she has been so since 2010.
00:02:03:11 - 00:02:05:07
For the purposes of title protection.
00:02:05:07 - 00:02:10:03
Just to remind everybody, CSI has two approved designations.
00:02:10:03 - 00:02:14:09
One is for financial planners, which is the Personal Financial Planner PFP
00:02:14:20 - 00:02:20:05
and one for financial advisors, the Designated Financial Services Advisor.
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And to Marie's left is Tashia Batstone.
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She's the president and CEO of FP Canada.
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And FP Canada has the Certified Financial Planner
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and Qualified Associate Financial Planner.
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And finally, Anthony Williams.
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He's the VP of the Canadian Institute of Financial Planning, CIFP,
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and they currently have three approved credentials,
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the Registered Retirement Consultant for FP
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and then two FA credentials,
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Registered Financial and Retirement Advisor
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and Registered Retirement Analyst.
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Welcome
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to our panel
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today.
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Just as an FYI,
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unfortunately we didn't have a representative from Advocis available
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for today's session
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and as well for CIRO.
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Their approval happened post Exchange planning
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so they won't be on the panel either today.
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That said, if you have questions for them,
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you can still submit them and all of the questions that are submitted.
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Obviously, we won't be handling all today.
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They'll be taken back though, and we will eventually answer
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all of the questions and they'll be available on our website
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probably within a couple of weeks.
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So with that,
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we can get started.
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And I know that to date
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probably most of the public information
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that has been available regarding title protection
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has been mostly from the regulator.
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So you've heard all of the talking points about the fact that credential holders
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are now supervised, they're subject to a complaints process.
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They need to adhere to a code of conduct that puts
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clients interests first and sign an attestation, all of those things.
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But today is a chance to hear from the credentialing bodies
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themselves, which I'm very excited with.
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And I thought, Tashia, we would kick it off with you.
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So question number one,
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it's actually a two-parter.
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What do you see as the CB's role in supporting FSRA's mandate,
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particularly protecting the rights and interests of consumers?
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And then the second part of this question is
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how does your organization support
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consumer and investor protection through its credentialing program?
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That's a lot.
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I think I could take the full hour and just talk about that.
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But.
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So FP Canada is a public interest entity.
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We are not for profit and our focus 100% in everything
00:05:06:01 - 00:05:09:18
that we do is around consumer protection and protection of the public.
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And so for us, what really made a difference in this framework
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was the fact that there are now standards that
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credential holders have to adhere to in order to be able to provide
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services to the public. And we think that's very, very important.
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You know, we've worked closely with FSRA through this process.
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You know, for example, one of the things that we advocated for
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very strongly with FSRA was the best interest standard
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to be included into the legislation and into the rules.
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So from that perspective, we think it's really important
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the work that's been happening and we're happy to have participated.
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I think, you know, how we can continue to support the framework,
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you have to remember that the credentialing bodies are probably closest
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to the credential holders
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and to the customers that they serve and the Canadian public.
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And so when it comes down to that, I think we have a role
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to help FSRA, to understand what's changing in the industry,
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what's changing with the consumer, what you know, what's happening out there
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so that the framework can continue to evolve and continue to stay relevant
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and continue to uphold that very important
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focus on the consumer and consumer protection.
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So that's sort of the -
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I think that’s a really important role for the credentialing bodies to hold.
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With respect to,
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you know, our role and how we protect the consumer.
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I think it sort of sits upon three, you know, I always call it
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a three-legged stool.
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We have to have very high certification standards.
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So our certification standards, for example,
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are reviewed annually.
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They have to be we have to look at them as terms of
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we have to meet global standards because we are part of a global organization.
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And so we have that all built into our processes.
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You know, we're constantly evolving them.
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You know, just recently we've released standards related to technology
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because we know how important technology is in terms of the changes
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that are going to be impacting the financial planning industry.
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The second leg in that stool has to do with professional standards, whether,
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you know, code of ethics, practice standards, standards of responsibility,
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professional responsibility
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that all of our certificants are required to adhere to.
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And those standards have to be very robust.
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They have to be developed.
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You have to be very transparent with the standards.
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And, you know, that becomes really important.
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And we invest a lot of time and effort in setting standards both here in Canada
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and we also contribute to the setting of those standards on a global basis.
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And the third stool or the third leg in the stool
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comes down to making sure that you have the appropriate enforcement
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against those standards and that enforcement has to be transparent.
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You have to have accountability.
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It has to be impartial and it has to be robust.
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You know, a lot of the work that we do, whether it's responding to a complaint
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that comes in from a member of the public or actually going out and proactively
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looking to see whether there are instances out there,
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we would initiate a concern or a complaint against one of our credential holders.
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It's a very robust process.
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We do that and then making sure, for example,
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that you have public representation on your panels, making sure
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that your decisions are made public, that the transparency is there.
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Those are all of the important things that a credentialing body
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needs to do to ensure that consumer protection.
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I'm curious about your discipline.
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Do you run a program that is sort of progressive
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so you attempt to sort of rehab people where maybe it's
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a lower end infraction or is there a different way of doing it?
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Absolutely.
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We have different sanctions available to the panel.
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Sometimes it's guidance just, you know, talking to the individual.
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Here’s what you did wrong,
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here's what you need to do better.
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Sometimes, depending on the severity of the issue.
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It can be mandated professional development.
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Our panels have the ability and actually our standards council
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has the ability to suspend somebody if the incident
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is sufficiently egregious that we think that there is harm to the public
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if this person stays out providing services.
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And then finally, of course, we do have the ability to take somebody's
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credential away.
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If, again, the incident is sufficiently severe.
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That's great. Thank you.
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I'm going to move to question two.
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And this question is for the entirety of the panel.
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I'm going to start with you, Marie.
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What changes did you have to make, if any, to ensure
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that your organization had in place the appropriate governance structure
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and administrative policies and procedures to serve the public interest?
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I'd say we didn't have that many changes to make.
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We've been a credentialing body since,
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well, over 50 years.
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We were also part of the IDA back in the day.
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So regulation kind of rubs off on you when you're part of that kind
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of an organization for so long.
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We already had accreditation in place for all of our programs.
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We had a strict code of ethics for our designation holders.
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We already did
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sanctions for people who did not
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abide by their rules
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and their designation could be removed.
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And we've always seen ourselves as a group
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that is offering the possibility for all Canadians
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to have some kind of financial advice, whether you're going into
00:11:01:02 - 00:11:04:02
a simple financial advice or something very complex.
00:11:04:02 - 00:11:08:10
And so we have financial planning that goes from branch-level people
00:11:08:17 - 00:11:11:19
up to mid-market people
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right into the very wealthy.
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And so being able to address the needs
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of those markets all the way along has been really important.
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And so we're not looking just at the consumer of our
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our programs, which is the advisor or the financial planner or the
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investment advisor or whoever we're giving an exam to, but we're also
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looking at the public beyond that.
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What is the public going to need to know?
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What are they going to need to have as proper advice?
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And be able to protect them as we go forward.
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And so I think being able to take people who come into our industry
00:11:47:19 - 00:11:51:14
at the very, even at the very bottom level and take them through their careers
00:11:51:28 - 00:11:56:18
and be able to give them possibilities of increasing financial advisory services
00:11:56:25 - 00:12:00:07
all the way up to the very wealth management level.
00:12:00:07 - 00:12:01:20
So
00:12:01:20 - 00:12:04:20
we've really put an emphasis on
00:12:05:08 - 00:12:06:24
on making sure that
00:12:06:24 - 00:12:10:02
when we give somebody a designation, they are competent.
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And I think competence leads to confidence.
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And so we have people who are confident in their abilities
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because they have gotten the kind of education,
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deep education and the kind of rigorous exams
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that we can attest to their level of competence.
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Talk to me about maybe
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the complaints process that you would have had to put in place.
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I could see formerly maybe you would receive a complaint from someone
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who took a course, a credential, and they weren't happy about something.
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But this is a little bit different now.
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Any changes that you had to make in that area?
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Well, we've always had
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a process in place for people to complain.
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So a consumer could complain to us.
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We do an investigation or we look at what CIRO was doing,
00:13:02:05 - 00:13:05:10
because very often in our industry, we have CIRO,
00:13:05:10 - 00:13:09:13
who is taking someone to task for the kinds of things they're doing.
00:13:09:18 - 00:13:12:06
And if they are giving them a sanction,
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then we're looking at what do we do
00:13:13:25 - 00:13:17:08
as a sanction against a holder who is holding a designation.
00:13:17:18 - 00:13:20:04
And so we've kept that process.
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We've also bolstered our process by looking at
00:13:25:04 - 00:13:30:12
what are the common practices out there for people who are being taken to task.
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And we have an ethics committee, we have
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an appeals committee with all the levels that you need
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in order to ensure that you can take someone to task,
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hear them fairly, but also sanction those required.
00:13:44:23 - 00:13:46:09
That's great. Thank you.
00:13:46:09 - 00:13:48:11
Anthony, over to you.
00:13:48:11 - 00:13:52:10
Any changes in your governance structure and your organization
00:13:52:10 - 00:13:56:03
in light of now being a regulated entity under title protection?
00:13:56:10 - 00:13:59:10
Thank you, Wendy.
00:13:59:21 - 00:14:01:27
To sort of echo
00:14:01:27 - 00:14:05:03
what Marie had said, you know,
00:14:05:03 - 00:14:11:01
our organization has been around for 50 years, or, approaching that period of time
00:14:11:01 - 00:14:14:01
and during that time,
00:14:14:15 - 00:14:17:05
you know, we've been an accredited education provider,
00:14:17:05 - 00:14:19:25
an accredited continuing education provider.
00:14:20:09 - 00:14:22:19
We've managed all credentials over that period of time.
00:14:22:19 - 00:14:25:29
So I'd like to think that we had some very robust
00:14:25:29 - 00:14:29:20
processes and policies and procedures already in place.
00:14:29:20 - 00:14:33:05
Good governance structure, risk management, resource management.
00:14:33:29 - 00:14:37:07
That being said, though, we also recognize that
00:14:37:07 - 00:14:41:02
we're not perfect as as an organization and there is always room for improvement.
00:14:41:02 - 00:14:42:00
And I think
00:14:42:00 - 00:14:45:08
one of the benefits that we had, I call it a benefit now when I
00:14:45:08 - 00:14:47:16
was actually going through the process, I'm not sure it was a benefit,
00:14:47:16 - 00:14:53:26
but one of the benefits of going through this credentialing, credentialing body application
00:14:53:26 - 00:14:58:20
was it gave our organization an opportunity for some introspection.
00:15:00:04 - 00:15:04:06
Taking a look at the policies and procedures we have in place and have had in place.
00:15:04:26 - 00:15:08:27
Trying to identify some of our bad habits that have crept into the organization
00:15:09:10 - 00:15:12:21
and then really try to tighten up everything to make sure that, you know,
00:15:12:23 - 00:15:14:11
we're number one, more efficient.
00:15:14:11 - 00:15:17:11
Number two, we are truly addressing the
00:15:18:03 - 00:15:21:03
consumer protection mandate
00:15:21:05 - 00:15:23:24
and just tightening up the procedures
00:15:23:24 - 00:15:28:01
and making sure that we've got sort of the best practices in place.
00:15:28:11 - 00:15:30:03
So I think we went through that.
00:15:30:03 - 00:15:33:10
And in particular, I think one of the things,
00:15:33:10 - 00:15:36:09
two areas that we really
00:15:36:09 - 00:15:39:25
I think it did some changes to in amendments were in the area
00:15:39:25 - 00:15:44:04
of consumer protection as well as in professional ethics.
00:15:44:16 - 00:15:47:16
I think, you know, that's reflected in our course material,
00:15:48:25 - 00:15:52:00
Our organization, we've got many fronts
00:15:52:00 - 00:15:53:12
on which we operate in terms of
00:15:54:26 - 00:15:55:17
it's not just
00:15:55:17 - 00:15:58:23
about providing courses, but we also do a lot of live,
00:15:58:23 - 00:16:02:13
in-person activities, conferences, workshops, that kind of stuff.
00:16:02:24 - 00:16:06:18
And it's really reflected, I think, in our conferences and workshops
00:16:06:18 - 00:16:10:08
where we have the consumer protection and professional ethics come to the fore.
00:16:10:19 - 00:16:13:19
So I think it was a good opportunity in terms of,
00:16:14:05 - 00:16:15:23
you know, sort of
00:16:15:23 - 00:16:20:29
taking stock of where we are as an organization and where we want to be
00:16:21:00 - 00:16:24:09
going forward, and in particular further addressing
00:16:24:09 - 00:16:27:09
the consumer protection and
00:16:27:13 - 00:16:30:00
public protection mandate.
00:16:30:00 - 00:16:30:26
That’s great. Thank you.
00:16:30:26 - 00:16:33:11
Tashia,
00:16:34:10 - 00:16:37:10
I think I'm going to echo what my colleagues up here have said.
00:16:37:16 - 00:16:41:10
You know, FP Canada has always had a public interest mandate.
00:16:41:24 - 00:16:44:27
It's the core and the ethos of what we do.
00:16:44:28 - 00:16:48:24
So for us, there wasn't any significant change
00:16:48:24 - 00:16:51:25
having come under the auspices of the framework.
00:16:52:07 - 00:16:55:22
We just continued to do business the way that we've always done business.
00:16:55:22 - 00:16:59:28
And really, you know, with that heavy focus on the consumer
00:16:59:28 - 00:17:03:27
and making sure that our certificants are acting in their best interest.
00:17:05:09 - 00:17:05:26
Well, that's great.
00:17:05:26 - 00:17:08:10
And of course, we have the luxury of having, you know,
00:17:08:10 - 00:17:12:15
three organizations who have been around in each case for decades.
00:17:13:15 - 00:17:16:15
So I would have thought nothing else.
00:17:17:05 - 00:17:18:05
Okay.
00:17:18:05 - 00:17:21:05
This question is for Marie.
00:17:24:06 - 00:17:25:21
Just as you pointed out,
00:17:25:21 - 00:17:28:28
CSI has a long history of providing education
00:17:28:28 - 00:17:32:08
for financial services, both nationally and internationally.
00:17:33:02 - 00:17:37:04
How has your organization's culture shifted as a result of
00:17:37:06 - 00:17:40:06
becoming an approved CB?
00:17:41:26 - 00:17:44:05
I think that
00:17:44:05 - 00:17:46:14
we've probably
00:17:46:14 - 00:17:48:22
probably put more emphasis
00:17:48:22 - 00:17:51:29
in our discourse around putting the client first.
00:17:53:02 - 00:17:56:03
I would say it's always been there, right?
00:17:56:04 - 00:17:59:04
We have a code of ethics that talks about putting the client first.
00:17:59:06 - 00:18:02:22
We communicate that in our material.
00:18:04:11 - 00:18:06:19
We very much look to the customer.
00:18:06:19 - 00:18:11:16
And in fact, some of the the ways in which we have developed
00:18:11:16 - 00:18:16:04
our material has been to say, what will the customer ask for?
00:18:16:20 - 00:18:20:19
So your material, what you're going to give to the advisor
00:18:20:19 - 00:18:22:02
or the financial planner
00:18:22:02 - 00:18:25:15
has to reflect what the customer is going to need coming in.
00:18:25:23 - 00:18:28:11
So very much that discovery process with the client.
00:18:31:03 - 00:18:34:15
I think we didn't say it enough, right.
00:18:34:16 - 00:18:35:25
It was kind of there.
00:18:35:25 - 00:18:39:05
And so I think in the last year, we've certainly put a lot more emphasis.
00:18:39:05 - 00:18:43:02
We did a number of webinars where we put it out there and we
00:18:43:05 - 00:18:47:10
we put emphasis on it and we made sure that people were thinking about that,
00:18:47:25 - 00:18:51:24
putting the client's interest first and not just being a financial planner
00:18:51:24 - 00:18:53:21
and doing everything they're doing well,
00:18:53:21 - 00:18:56:08
but really, really thinking about that client.
00:18:56:08 - 00:18:59:08
So I would say that culturally that probably
00:18:59:19 - 00:19:02:10
it was there, but it wasn't apparent enough
00:19:02:10 - 00:19:05:10
and I think we've made it more apparent.
00:19:05:14 - 00:19:08:00
And the feedback from that webinar
00:19:08:00 - 00:19:10:12
you did, I think it was last November?
00:19:10:28 - 00:19:11:23
Very positive.
00:19:11:23 - 00:19:15:22
I mean, I think people understand that
00:19:17:06 - 00:19:20:18
being able to do something that is a greater good.
00:19:20:19 - 00:19:22:03
So if you're an advisor,
00:19:22:03 - 00:19:25:17
I think many people enjoy the job of advisor, a financial planner,
00:19:26:04 - 00:19:27:13
not so much because they're smart
00:19:27:13 - 00:19:30:13
or because they've got the competency or they've done all kinds of things,
00:19:30:17 - 00:19:35:19
but rather they have that opportunity to help people with their finances.
00:19:36:08 - 00:19:39:08
And it's kind of a noble, purposeful
00:19:41:02 - 00:19:42:01
job to have.
00:19:42:01 - 00:19:46:12
You're not just doing a job and making money for the company.
00:19:46:17 - 00:19:49:13
You are making a difference in people's lives.
00:19:49:13 - 00:19:54:05
And I think people see that you this “put your customer first” kind of thing.
00:19:54:09 - 00:19:58:20
So the kinds of reactions we get to the webinars are really positive
00:19:58:20 - 00:20:01:18
because people feel like if they're joining this industry,
00:20:01:18 - 00:20:04:05
they're joining something that is bigger than themselves
00:20:04:05 - 00:20:05:22
and that they can make a contribution.
00:20:07:07 - 00:20:07:22
That's great.
00:20:07:22 - 00:20:09:21
Thank you.
00:20:09:21 - 00:20:11:11
This next question is for you,
00:20:11:11 - 00:20:16:23
Anthony, and I'm going to preface this by saying to the benefit of everyone
00:20:16:23 - 00:20:22:09
in the room and also online listening in that this past Friday, March 1st,
00:20:22:09 - 00:20:27:08
FSRA launched their public registry for credential holders.
00:20:27:08 - 00:20:32:24
It's called the Check Credentials Tool, or CCT, if you will.
00:20:32:24 - 00:20:37:01
That's the new acronym for the day that you never knew that you needed.
00:20:38:04 - 00:20:39:22
Kind of rolls off the tongue, though.
00:20:40:23 - 00:20:42:22
That's worth $5, I'd say.
00:20:45:06 - 00:20:49:13
So, Anthony, how do you think the registry
00:20:49:13 - 00:20:53:19
is going to contribute to consumer awareness and protection?
00:20:55:06 - 00:20:57:13
I think in a very meaningful way.
00:20:57:13 - 00:21:00:12
So the public registry is
00:21:00:16 - 00:21:02:14
a very easy
00:21:02:14 - 00:21:08:19
one-stop tool that consumers can go to or consumers can use to check
00:21:08:19 - 00:21:13:02
on the financial planner or the financial advisor they're currently working with
00:21:13:02 - 00:21:16:13
or they’re considering working with at some point down the road.
00:21:17:02 - 00:21:21:17
And by using this tool, they can check to see if this financial planner,
00:21:21:17 - 00:21:25:01
financial advisor is in good standing, or in other words,
00:21:25:20 - 00:21:29:09
they've met and continue to meet the requirements of their credential.
00:21:29:16 - 00:21:33:11
And one very important aspect of that credential requirement
00:21:33:24 - 00:21:36:16
is adhering to a code of conduct.
00:21:36:16 - 00:21:41:13
So from that perspective, I think it's a very important consumer protection tool.
00:21:42:16 - 00:21:44:11
It also offers
00:21:44:11 - 00:21:48:05
a degree of comfort and a degree of peace of mind,
00:21:48:05 - 00:21:51:06
I think, to the consumer in having access to this tool and seeing
00:21:51:06 - 00:21:54:06
what the status is of their advisor or planner.
00:21:54:22 - 00:21:57:25
Now, one of the nice things I think about the registry
00:21:58:22 - 00:22:03:03
is it consolidates the information from the various
00:22:03:03 - 00:22:06:13
credentialing bodies and centralizes it on the FSRA website.
00:22:06:26 - 00:22:10:16
And and this makes it obviously very, very convenient, very simple
00:22:10:16 - 00:22:11:13
for the consumer to use.
00:22:11:13 - 00:22:14:13
So I think simplicity is the key here.
00:22:16:05 - 00:22:17:09
They want to be, you know,
00:22:17:09 - 00:22:20:15
if they want to get important and pertinent information
00:22:20:22 - 00:22:23:20
about the individual that they're working with,
00:22:23:20 - 00:22:26:20
they can use this tool in a very easy and simplistic way.
00:22:26:29 - 00:22:29:08
And it takes away a lot of the sleuthing,
00:22:30:09 - 00:22:33:09
the background work that an individual might have to do on their own
00:22:33:20 - 00:22:35:12
by having it this way.
00:22:35:12 - 00:22:40:03
So we often think about the public registry
00:22:40:04 - 00:22:43:28
from the consumer's perspective and obviously it is very important
00:22:43:28 - 00:22:44:18
from that perspective.
00:22:44:18 - 00:22:48:24
But I think it's worth also mentioning that the public registry has importance
00:22:48:24 - 00:22:51:00
for the advisor and the planner themselves.
00:22:51:00 - 00:22:52:19
Okay.
00:22:52:19 - 00:22:58:01
Keep in mind, if you hold an approved credential, then your name will appear
00:22:58:06 - 00:23:02:10
on this public registry and that will be in full view of the public.
00:23:02:10 - 00:23:05:10
It will be in full view of your clients, your firm, etc..
00:23:05:14 - 00:23:09:28
So having your name on the registry and then right beside it,
00:23:09:28 - 00:23:12:28
hopefully you've got a little tag that says in good standing.
00:23:13:04 - 00:23:15:13
I think that builds instant credibility.
00:23:15:13 - 00:23:15:20
Right?
00:23:15:20 - 00:23:19:20
So that's a very positive thing for the advisor and the planner themselves.
00:23:20:01 - 00:23:21:04
Now, on the flip side,
00:23:23:05 - 00:23:24:26
I think the public registry
00:23:24:26 - 00:23:27:21
and the fact that it is in full public view
00:23:28:11 - 00:23:32:29
also means that it will give the advisor and the planner,
00:23:34:02 - 00:23:35:29
I think, a greater incentive to make sure
00:23:35:29 - 00:23:38:29
that they've got their stuff in order
00:23:40:23 - 00:23:43:23
because you want to make sure that you're in good standing.
00:23:44:01 - 00:23:47:25
And any other status besides your name obviously is not going to reflect in there
00:23:47:25 - 00:23:50:25
in the most positive light. So, for example,
00:23:51:13 - 00:23:53:24
let's say you've got an individual
00:23:53:24 - 00:23:56:21
who's who's neglected or forgotten
00:23:56:21 - 00:24:00:26
or is late in renewing their annual dues or perhaps they're late
00:24:01:00 - 00:24:04:18
or haven't completed their continuing education requirements.
00:24:04:26 - 00:24:08:20
Now in the grand scheme of things, it may not be the biggest breaches
00:24:08:20 - 00:24:10:11
necessarily, but nonetheless
00:24:10:11 - 00:24:14:13
it will impact the status that shows beside their name on the registry.
00:24:14:29 - 00:24:18:26
So I think it's a very important thing in terms of getting planners and advisors
00:24:19:03 - 00:24:21:23
to sort of make sure that they're sort of on top of their affairs.
00:24:22:23 - 00:24:24:12
So in a sense then
00:24:24:12 - 00:24:27:09
I think the the public registry
00:24:27:18 - 00:24:30:27
is a very effective consumer protection tool that FSRA’s put in place
00:24:31:15 - 00:24:34:22
and I think it'll
00:24:35:25 - 00:24:37:16
do a lot of good in that regard.
00:24:37:16 - 00:24:40:14
Certainly different from what we've had
00:24:40:14 - 00:24:43:14
in the previous regimes where I think the consumer was sort of
00:24:43:26 - 00:24:47:21
in a position where if they had an issue, they didn't really know
00:24:48:02 - 00:24:51:15
where to go, where to start and how to proceed
00:24:51:20 - 00:24:52:29
and I think now this tool is there.
00:24:52:29 - 00:24:57:04
So the key from our perspective, I think, is about awareness, right?
00:24:57:04 - 00:25:00:20
Now as Wendy pointed out, this has just literally come out.
00:25:00:20 - 00:25:03:20
It's just been launched in the last couple of days.
00:25:03:28 - 00:25:06:07
But I think once
00:25:06:07 - 00:25:08:23
in an ideal world, if you get to the point where,
00:25:09:15 - 00:25:10:17
let's say a consumer does
00:25:10:17 - 00:25:13:17
have a concern about a financial advisor or financial planner,
00:25:13:24 - 00:25:17:02
and they can, you know, the first connection that they make
00:25:17:13 - 00:25:20:12
is to this public registry tool.
00:25:20:12 - 00:25:23:05
They go to the FSRA website, they gather some basic information.
00:25:23:05 - 00:25:26:00
Then they can sort of figure out what they want to do in the next steps.
00:25:26:00 - 00:25:27:25
If you can arrive at that stage.
00:25:27:25 - 00:25:30:25
I think that would be a big win in terms of the use of the tool.
00:25:31:13 - 00:25:32:02
Yeah, you know what?
00:25:32:02 - 00:25:34:22
I'm going to go to the rest of the panel on this question as well.
00:25:34:22 - 00:25:39:10
But I will tell you that in preparation for today,
00:25:39:10 - 00:25:44:04
I was playing with the CCT over the weekend, and I can tell you
00:25:44:04 - 00:25:48:25
that it is a powerful little tool and I can see the benefits
00:25:49:14 - 00:25:53:09
both for the consumer as well as any financial planner
00:25:53:09 - 00:25:58:12
or financial advisor out there or someone within the new categories of CIRO
00:25:58:16 - 00:25:59:16
that are now approved.
00:26:00:19 - 00:26:04:08
You can very plainly see that
00:26:04:13 - 00:26:07:23
there are people with multiple credentials.
00:26:08:03 - 00:26:13:06
It certainly gives you an idea of what they do holistically.
00:26:14:09 - 00:26:18:14
It's super easy to use and in fact, FSRA
00:26:18:14 - 00:26:22:26
we’re going through digital transformation across our whole organization.
00:26:22:26 - 00:26:25:02
We have registries for all of our sectors.
00:26:25:02 - 00:26:28:12
But this one I think by far is
00:26:28:13 - 00:26:31:29
honestly superior to our other ones.
00:26:31:29 - 00:26:32:26
And, you know,
00:26:32:26 - 00:26:38:04
we somehow did it in record time with the cooperation of all of the CB’s,
00:26:38:04 - 00:26:42:13
which really I would say above and beyond all of the other things
00:26:42:13 - 00:26:47:10
that we've had to do together to operationalize this regime.
00:26:47:23 - 00:26:50:20
This was such a great collaborative effort.
00:26:50:20 - 00:26:54:14
But Tashia, tell me what you think about the new registry.
00:26:55:20 - 00:26:58:16
Well, I mean, I would echo what Anthony said.
00:26:58:16 - 00:27:01:00
I think it's a really good product for consumers.
00:27:01:00 - 00:27:03:08
I think it's going to give them a lot of clarity.
00:27:03:08 - 00:27:06:22
You know, it's very easy for them to go in and make sure that the individual
00:27:06:22 - 00:27:09:02
with whom they're working, who's providing them with that advice,
00:27:09:02 - 00:27:11:21
as Marie was saying, that really important advice
00:27:11:21 - 00:27:14:16
does have the skills and competencies required under the framework.
00:27:14:16 - 00:27:17:12
So all of those things are great to see.
00:27:17:12 - 00:27:20:10
And as you said, it's early days, right?
00:27:20:10 - 00:27:24:25
So it's going to be really important to see how FSRA now proceeds
00:27:24:25 - 00:27:27:13
with helping the consumer understand
00:27:27:24 - 00:27:31:12
that the registry is there and they can find it easily
00:27:31:12 - 00:27:36:05
and they can work through it, which I know is part of the plan going forward.
00:27:36:17 - 00:27:40:16
And I would say that, you know, the other part of this
00:27:40:16 - 00:27:43:00
is that we have to think about is what happens
00:27:43:10 - 00:27:48:07
if someone doesn't find their advisor or their planner
00:27:49:07 - 00:27:50:15
in the registry.
00:27:50:15 - 00:27:50:22
Right.
00:27:50:22 - 00:27:51:22
What are the steps?
00:27:51:22 - 00:27:55:05
Helping the consumer know what the steps are in that circumstance.
00:27:55:15 - 00:27:59:03
Because that would mean that somebody is inappropriately using the titles.
00:27:59:03 - 00:28:03:11
And that's, I think, the next evolution of what we have to start to think about.
00:28:03:22 - 00:28:06:22
Yeah, it's a great point. Marie?
00:28:06:29 - 00:28:09:10
I think it's information, right?
00:28:09:10 - 00:28:13:11
I think if somebody needs to find out what their financial planner is about
00:28:13:11 - 00:28:16:16
and do they have the qualifications, they can look it up.
00:28:17:03 - 00:28:21:11
I think the challenge right now is to let consumers know that they can look it up.
00:28:21:11 - 00:28:23:03
Right?
00:28:23:03 - 00:28:26:03
A lot of consumers just don't know a lot of things.
00:28:27:00 - 00:28:31:22
How many in this room get a prospectus from their mutual fund company?
00:28:32:06 - 00:28:33:27
How many of you read it?
00:28:33:27 - 00:28:38:24
How many of you take it from the mail box to the blue box?
00:28:40:04 - 00:28:43:11
It's not something we like to think about.
00:28:43:23 - 00:28:47:17
And so we kind of trust people and can we trust people?
00:28:47:17 - 00:28:50:08
So I think it's really around
00:28:50:08 - 00:28:52:02
it's part of consumer education.
00:28:52:02 - 00:28:53:26
I think it's going to be a really important part
00:28:53:26 - 00:28:56:15
of what we have to do in the future is to bring consumers
00:28:56:15 - 00:28:59:05
to be much more comfortable with their finances
00:28:59:05 - 00:29:02:05
and be able to know in whom they can have confidence.
00:29:02:15 - 00:29:03:08
And that's great.
00:29:03:08 - 00:29:07:01
And just so everyone knows, this is phase one,
00:29:07:17 - 00:29:10:22
It isn't without a few little glitches.
00:29:11:15 - 00:29:14:14
I mean, not everyone uses the same terminology
00:29:14:14 - 00:29:16:21
for things like
00:29:16:21 - 00:29:20:10
‘in good standing’ versus ‘active.’
00:29:20:29 - 00:29:23:16
And we of course, would love to get to a point
00:29:23:16 - 00:29:27:02
where there is symmetry amongst all of the CB’s
00:29:27:29 - 00:29:33:18
and there are other refinements that can be made in future phases
00:29:34:27 - 00:29:37:08
but it is a great start.
00:29:37:08 - 00:29:37:16
Okay.
00:29:37:16 - 00:29:41:12
I've another question that will be for all of the panel,
00:29:41:12 - 00:29:44:01
and I'm going to go back to you, Tashia.
00:29:44:01 - 00:29:48:19
FP Canada has advanced professional financial planning for decades,
00:29:48:22 - 00:29:51:23
both nationally and internationally.
00:29:52:22 - 00:29:56:18
Please give us some insight into why your organization
00:29:56:18 - 00:30:00:00
decided to participate in the title protection framework,
00:30:00:22 - 00:30:04:00
and how has your participation been valuable
00:30:04:00 - 00:30:06:29
to your credential holders?
00:30:10:13 - 00:30:11:26
That's a great question, Wendy.
00:30:11:26 - 00:30:14:03
I mean, we,
00:30:14:03 - 00:30:17:11
I think, lobbied pretty actively for many, many years
00:30:17:16 - 00:30:20:16
for this, for the title protection framework.
00:30:20:26 - 00:30:25:16
You know, I always found it interesting that anybody could provide
00:30:25:16 - 00:30:29:02
financial advice or financial planning services.
00:30:29:15 - 00:30:31:02
And that's concerning
00:30:31:02 - 00:30:34:02
when you think about the world that we find ourselves in today
00:30:34:03 - 00:30:38:08
and how vulnerable people can be to advice that's not in their best interest.
00:30:38:22 - 00:30:41:21
And so for us, it was very important
00:30:41:21 - 00:30:45:26
that the individuals out there providing financial advice, financial planning
00:30:46:08 - 00:30:48:21
did have the appropriate skills and competencies
00:30:48:21 - 00:30:50:09
to make sure that they could protect
00:30:51:10 - 00:30:53:09
the consumers with whom they're working.
00:30:53:09 - 00:30:56:04
And so it's a no brainer, in effect, right?
00:30:56:04 - 00:30:59:00
I mean, it really is
00:30:59:00 - 00:31:03:01
so critical that consumers are aware.
00:31:03:01 - 00:31:04:00
And, you know,
00:31:04:00 - 00:31:07:19
the reality of it is, is the consumer may not even know what they don't know.
00:31:08:13 - 00:31:10:09
So, for example,
00:31:10:09 - 00:31:13:23
as we’ve been going through our discussions with various provinces,
00:31:14:19 - 00:31:17:20
with various individuals in some of those provinces,
00:31:17:29 - 00:31:19:23
a lot of them didn't even realize.
00:31:19:23 - 00:31:23:09
I remember having a conversation with the Minister of Finance who said to me,
00:31:23:28 - 00:31:27:00
I didn't even realize this wasn't already regulated.
00:31:27:14 - 00:31:30:13
And I think a lot of consumers feel the same way.
00:31:30:25 - 00:31:32:23
You know, we are a profession
00:31:32:23 - 00:31:34:26
and, you know,
00:31:34:26 - 00:31:38:13
whether it's a lawyers, accountants, doctors, they are all regulated.
00:31:38:24 - 00:31:40:02
So to see
00:31:41:06 - 00:31:43:14
to see Ontario step in and
00:31:43:14 - 00:31:46:26
establish this framework, I think is a really, really important precedent.
00:31:47:09 - 00:31:50:03
And it was very important for us to be part of that.
00:31:50:03 - 00:31:52:27
And I think what I hear from our certificants
00:31:52:27 - 00:31:56:08
is they like that fact that they are now
00:31:56:09 - 00:32:00:00
part of a profession that has standards that are recognized.
00:32:00:08 - 00:32:03:22
And, you know, just to be clear, our certificants always were subject
00:32:03:22 - 00:32:05:00
to a professional regime.
00:32:05:00 - 00:32:08:00
They always had to adhere to professional standards.
00:32:08:02 - 00:32:12:19
But what it does now is, you know, it standardize it.
00:32:12:19 - 00:32:14:20
It brings it across the industry.
00:32:14:20 - 00:32:16:01
And I think that really matters.
00:32:16:01 - 00:32:20:10
So that's what we're seeing, is people are generally pleased to be able
00:32:20:10 - 00:32:24:01
to see that they are part of a framework where the consumers
00:32:24:09 - 00:32:27:22
best interest is put forward, where the credentialing bodies
00:32:27:22 - 00:32:32:11
are expected to have certain standards, certain requirements
00:32:32:11 - 00:32:36:20
around certification, standard codes, professional ethics, etc..
00:32:36:20 - 00:32:40:10
It just raises the expectations for the whole profession.
00:32:42:04 - 00:32:43:24
Yes, I take your point.
00:32:43:24 - 00:32:47:14
I feel like in future we may have to be monitoring
00:32:47:20 - 00:32:50:20
TikTok and things because,
00:32:51:08 - 00:32:54:08
you know, everybody is an expert.
00:32:54:12 - 00:32:57:12
Same question to you, Anthony.
00:33:00:12 - 00:33:03:08
I think
00:33:03:08 - 00:33:09:24
I think in terms of why we participate in the framework, it's pretty basic.
00:33:10:01 - 00:33:11:25
It's a very fundamental reason, actually,
00:33:11:25 - 00:33:15:27
is that we believe very strongly in the mandate as an organization.
00:33:15:27 - 00:33:17:02
We always have.
00:33:17:02 - 00:33:20:01
So where would there be an objection?
00:33:21:00 - 00:33:24:00
I mean, if we think about the financial services industry
00:33:24:09 - 00:33:29:01
and really the founding principles are trust and confidence.
00:33:29:15 - 00:33:32:10
So why would we have an objection
00:33:32:10 - 00:33:35:28
to a framework where the overriding tenet is basically about consumer protection?
00:33:35:28 - 00:33:38:28
So I think it was very easy to use, you know, Tashia's
00:33:38:28 - 00:33:41:28
phrase, it was a no brainer for my organization as well.
00:33:42:06 - 00:33:46:12
I should add, you know, from a more practical level,
00:33:47:26 - 00:33:49:10
I think when we
00:33:49:10 - 00:33:53:22
as an organization, we're surveying the landscape
00:33:54:08 - 00:33:58:12
and this is, you know, several years prior to the implementation
00:33:58:12 - 00:34:02:05
of the actual title protection legislation, in Ontario anyway,
00:34:02:09 - 00:34:05:29
but when we were surveying the landscape, when we were talking to
00:34:05:29 - 00:34:07:12
our corporate partners,
00:34:07:12 - 00:34:10:18
when we were talking to our academic partners, the colleges and universities
00:34:10:18 - 00:34:13:18
across the country, and we did our own analysis,
00:34:14:09 - 00:34:17:09
I think we very quickly came to the understanding that
00:34:17:16 - 00:34:20:15
if title protection legislation was going to be a reality,
00:34:20:15 - 00:34:25:02
and particularly if it started to roll out outside of just Ontario's borders
00:34:25:02 - 00:34:28:02
and rolled out across the country, as we imagine it will,
00:34:30:04 - 00:34:31:24
then I think it became very clear
00:34:31:24 - 00:34:35:07
from our standpoint as an education provider
00:34:35:18 - 00:34:39:16
and as a credentialing body, that if we were to remain relevant
00:34:39:16 - 00:34:43:24
in this new regime, then we had to participate in the framework.
00:34:43:24 - 00:34:46:23
So there's a practical side as well, you know, a business side as well
00:34:46:23 - 00:34:48:11
that comes into play.
00:34:48:17 - 00:34:50:02
I think for our credential holders,
00:34:50:02 - 00:34:51:25
I think the other part of the question was, you know,
00:34:51:25 - 00:34:55:11
the value to credential holders in terms of our participation,
00:34:56:03 - 00:34:57:05
again, very valuable.
00:34:57:05 - 00:34:59:15
It's instant credibility.
00:34:59:15 - 00:35:01:09
Our credential holders,
00:35:01:09 - 00:35:04:00
if they are holding one of our designations,
00:35:04:00 - 00:35:07:14
can have the confidence that they're holding a credential
00:35:07:26 - 00:35:10:25
that has been vetted against various metrics
00:35:10:27 - 00:35:14:21
and at the end of the day has been approved by FSRA, the oversight body.
00:35:15:21 - 00:35:16:18
And that has
00:35:16:18 - 00:35:20:12
sort of a, you know, a secondary benefit or a derivative benefit,
00:35:20:12 - 00:35:25:05
if you like, because that then gives the credential holder the confidence
00:35:26:06 - 00:35:28:24
when they're speaking to their clients,
00:35:28:24 - 00:35:33:14
it gives the clients confidence and trust, which is what we've been, you know,
00:35:33:14 - 00:35:38:00
sort of talking about as being sort of of paramount interest to everyone here.
00:35:39:10 - 00:35:42:22
But I also think from the planner and the advisors perspective,
00:35:44:02 - 00:35:47:04
it's not just the fact that they hold an approved credential,
00:35:47:04 - 00:35:51:18
it's the derivative of that is it gives them the ability to now
00:35:51:26 - 00:35:55:13
call themselves a financial planner or a financial advisor,
00:35:55:17 - 00:35:57:12
at least in the province of Ontario.
00:35:57:12 - 00:36:00:22
And what that means then is in terms of them
00:36:00:22 - 00:36:05:22
building their practice, again, that's a very valuable platform
00:36:05:22 - 00:36:10:24
from which to build their career and their longevity in the field.
00:36:11:04 - 00:36:12:18
So multiple benefits, I think.
00:36:13:24 - 00:36:14:21
That's great.
00:36:14:21 - 00:36:15:23
Marie.
00:36:16:04 - 00:36:19:15
So we've been offering financial planning since 1996.
00:36:20:23 - 00:36:23:02
We started it because we could see
00:36:23:02 - 00:36:29:12
that consumers were going to need advice on how to place their finances
00:36:29:12 - 00:36:31:05
and how to manage their money.
00:36:31:23 - 00:36:34:23
And so we set up a number of designations that were
00:36:35:07 - 00:36:38:27
in keeping with the kind of career path, I've mentioned this earlier,
00:36:38:27 - 00:36:40:28
the kind of career path that people would have.
00:36:40:28 - 00:36:42:18
If you're coming into a bank, you're starting
00:36:42:18 - 00:36:45:15
with a mutual funds license, what are you going to do next?
00:36:45:15 - 00:36:48:15
And the banks, we worked very closely with the banks
00:36:48:18 - 00:36:51:16
to really align
00:36:51:16 - 00:36:55:14
our program with the moves that some would make in the industry.
00:36:55:24 - 00:36:57:07
What do you do at the bottom level?
00:36:57:07 - 00:36:58:25
When you’re promoted
00:36:58:27 - 00:37:00:15
you do something else and so on.
00:37:00:15 - 00:37:04:13
Our courses were added into people's career paths
00:37:05:23 - 00:37:07:17
right up to financial planning.
00:37:07:17 - 00:37:12:00
On the security side, again, you had licensing that you were required to do.
00:37:12:09 - 00:37:14:28
We had added things like wealth management essentials.
00:37:14:28 - 00:37:17:28
It was a natural to add financial planning to that,
00:37:18:09 - 00:37:20:27
but we had to have ISO accreditation
00:37:20:27 - 00:37:26:10
in order to be credible as a provider of credentials in the space.
00:37:26:20 - 00:37:28:14
And so
00:37:28:14 - 00:37:32:02
for us it was a natural next step, here is a regulator coming in,
00:37:32:02 - 00:37:35:06
we had already aligned with the Quebec requirements.
00:37:35:11 - 00:37:40:04
We already had a program of ten courses to meet the 450 hours in English
00:37:40:04 - 00:37:44:20
and French to be able to allow people to become a financial planner in Quebec.
00:37:45:00 - 00:37:48:00
Here, Ontario was now bringing in legislation
00:37:49:00 - 00:37:53:15
natural for us to go in and say, okay, we can have,
00:37:53:20 - 00:37:57:07
we can now put out our credentials aligned with the financial planner
00:37:57:14 - 00:37:59:16
and the financial advisor title.
00:37:59:16 - 00:38:01:28
So it was for us a next step.
00:38:01:28 - 00:38:03:24
That was a normal one, I think, Anthony said.
00:38:03:24 - 00:38:05:10
It's kind of a no brainer.
00:38:05:10 - 00:38:07:26
So it was very much
00:38:07:26 - 00:38:10:25
if there's going to be regulation and people are going to be required.
00:38:10:25 - 00:38:13:12
We wanted to make sure that our designations were right there.
00:38:14:18 - 00:38:17:17
And that ISO accreditation,
00:38:17:17 - 00:38:22:24
is that sort of just a look at competencies or what does that do for you?
00:38:23:04 - 00:38:27:23
It really looks at the the way that you manage the entire organization,
00:38:28:03 - 00:38:32:14
for example, to separate exams from the building of material
00:38:32:21 - 00:38:36:11
to make sure that you have a code of ethics in place, that you have
00:38:37:23 - 00:38:40:15
processes and procedures in place, that you,
00:38:40:15 - 00:38:43:22
you come up with competencies and you can say how you got to them.
00:38:43:22 - 00:38:45:07
And it's all documented.
00:38:45:07 - 00:38:48:23
It's, Natasha, you can attest to this.
00:38:48:28 - 00:38:51:06
It is tremendously
00:38:51:06 - 00:38:54:06
time consuming and, very, very,
00:38:55:04 - 00:38:58:08
very, very onerous to be able to be ISO accredited.
00:38:58:17 - 00:39:02:26
And so now being accredited by FSRA doesn't mean you're not going to come in
00:39:03:02 - 00:39:04:03
and check us out.
00:39:04:03 - 00:39:09:10
But it's sort of a different layer from the ISO layer, right?
00:39:09:12 - 00:39:13:12
Well, hopefully we add a little bit of value with those examinations as well.
00:39:16:12 - 00:39:17:18
Okay.
00:39:17:18 - 00:39:23:02
We have another question that is for the whole panel.
00:39:23:02 - 00:39:28:12
And I'm going to ask you to tap into your crystal ball
00:39:28:12 - 00:39:31:12
a little bit
00:39:31:22 - 00:39:34:22
by looking at the future.
00:39:34:26 - 00:39:38:07
So how do you see the framework evolving
00:39:38:11 - 00:39:42:10
in the next couple of years, particularly the role of CB’s and supporting
00:39:42:10 - 00:39:47:23
credential holders to continue to adhere to the client's interest first principle?
00:39:47:23 - 00:39:50:23
We're going to start with you, Anthony.
00:39:53:01 - 00:39:55:24
I think the biggest
00:39:55:24 - 00:40:00:22
trend or factor that's sort of looming out there
00:40:00:22 - 00:40:04:20
is the roll out of title protection legislation across the country
00:40:06:02 - 00:40:08:20
to jurisdictions outside of Ontario.
00:40:08:20 - 00:40:11:10
So I think that's inevitable.
00:40:11:10 - 00:40:14:10
We know that there are the jurisdictions that already got the ball rolling,
00:40:14:19 - 00:40:18:06
so it would be very interesting to see how that all emerges and how that all plays out.
00:40:19:13 - 00:40:20:18
Obviously, that's a good thing.
00:40:20:18 - 00:40:23:18
I mean, if we're talking about title protection in Ontario
00:40:23:27 - 00:40:26:25
in the positive light that that we have been, then clearly
00:40:26:25 - 00:40:30:04
that's going to be very positive if we have it on a national level as well.
00:40:31:15 - 00:40:34:04
I think the concern
00:40:34:04 - 00:40:36:16
that we have as an organization
00:40:36:16 - 00:40:39:16
is ensuring that
00:40:40:07 - 00:40:43:03
as the model rolls out,
00:40:43:03 - 00:40:45:12
that there is uniformity,
00:40:45:12 - 00:40:48:12
that there's harmonization across the country.
00:40:49:23 - 00:40:53:10
And, you know, we would certainly hope and encourage FSRA
00:40:53:10 - 00:40:54:26
in their conversations
00:40:54:26 - 00:40:57:26
with these other bodies in the other jurisdictions,
00:40:58:06 - 00:41:01:02
that they really emphasize this point and they really promote
00:41:01:02 - 00:41:04:02
the benefits of harmonization and uniformity.
00:41:04:18 - 00:41:08:05
The last thing we want is a national framework
00:41:08:05 - 00:41:11:07
that is splintered or fractured or where
00:41:11:07 - 00:41:14:12
we have too many of the jurisdictions sort of doing their own thing.
00:41:15:05 - 00:41:17:19
Now we understand that there's going to be some sort
00:41:17:19 - 00:41:21:08
of idiosyncratic differences in the jurisdictions.
00:41:21:08 - 00:41:25:06
That's just normal because it would reflect sort of their population base.
00:41:25:18 - 00:41:28:15
But in the main, I think it has to be
00:41:28:15 - 00:41:31:25
a harmonized approach, and I think that's really critical for the long term
00:41:32:04 - 00:41:34:29
sustainability and viability of any title protection.
00:41:34:29 - 00:41:39:14
So really hope, you know, FSRA promotes this and encourages this,
00:41:39:14 - 00:41:42:14
which I'm sure they have been doing in their conversations.
00:41:43:07 - 00:41:44:09
I think the other
00:41:45:24 - 00:41:48:16
evolving trend is,
00:41:48:16 - 00:41:51:18
perhaps not evolving, it’s already evolved,
00:41:51:18 - 00:41:53:01
is the role of technology.
00:41:53:21 - 00:41:56:21
We know it's an ever increasing role.
00:41:57:29 - 00:42:00:08
You know, I was just thinking today about AI
00:42:00:08 - 00:42:01:29
in this whole AI conversation.
00:42:03:12 - 00:42:04:28
It's moved so rapidly.
00:42:04:28 - 00:42:07:28
I mean, if we think about a year ago or two years ago,
00:42:08:07 - 00:42:10:07
it almost seemed like a bit of science fiction.
00:42:10:07 - 00:42:13:07
We knew it was there and we knew it was coming,
00:42:13:13 - 00:42:16:04
but it was always the conversation was always, it's five years down the road,
00:42:16:04 - 00:42:17:15
it's ten years down the road.
00:42:17:15 - 00:42:21:04
Fast forward in just like the short span of a year.
00:42:21:04 - 00:42:22:20
And it's already here.
00:42:22:20 - 00:42:25:25
It's already, you know, it's today's technology.
00:42:26:08 - 00:42:29:04
So I think the evolving role of technology
00:42:29:04 - 00:42:32:24
in the financial services industry, it's very clearly there.
00:42:32:24 - 00:42:35:12
We can't put the lid back on it, even if you want to do that.
00:42:35:12 - 00:42:38:05
Not that you do, but I'm just saying you can't put the lid on it.
00:42:38:05 - 00:42:42:05
So how do we embrace it and how do we manage it
00:42:42:14 - 00:42:44:27
and regulate it
00:42:44:27 - 00:42:50:01
in the positive use of that word, not an overbearing use of the word,
00:42:50:09 - 00:42:56:09
but regulate it, particularly from the standpoint of the use of technology
00:42:56:09 - 00:43:00:28
and the ethical use of technology from the client’s perspective.
00:43:01:13 - 00:43:04:16
So I think, you know, for FSRA, for example,
00:43:04:29 - 00:43:09:01
when we're reviewing the proficiencies for financial planners,
00:43:09:01 - 00:43:12:19
financial standards, should there be proficiencies that talk about
00:43:14:11 - 00:43:16:22
being adept in technology and understanding
00:43:16:22 - 00:43:19:22
the role of technology, particularly the ethical use of technology.
00:43:20:15 - 00:43:24:01
In fact, if you think about it, I mean, an argument could be made
00:43:24:06 - 00:43:27:15
if there's so much emphasis on technical knowledge,
00:43:28:16 - 00:43:31:04
but perhaps the shift
00:43:31:04 - 00:43:34:10
should be on understanding the use of technology more so doing
00:43:34:10 - 00:43:37:10
just on being able to sort of
00:43:37:16 - 00:43:40:16
regurgitate facts about, you know,
00:43:40:20 - 00:43:43:01
the Canada pension plan or the tax code or whatever it is.
00:43:43:01 - 00:43:43:08
Right.
00:43:43:08 - 00:43:44:11
So I think
00:43:44:11 - 00:43:47:11
the role of technology, I think obviously would be a very important trend.
00:43:48:17 - 00:43:50:19
So you see, I guess
00:43:50:19 - 00:43:54:19
maybe adding to the proficiency where, you know,
00:43:54:19 - 00:43:59:07
applicable uses of AI in financial planning and financial advice.
00:43:59:19 - 00:44:00:08
Absolutely.
00:44:00:08 - 00:44:04:07
And I think, you know, look, we all know there are so many benefits
00:44:04:26 - 00:44:09:02
that come from technology, but we have to be, particularly with AI
00:44:09:19 - 00:44:13:24
because we're in the early stages of it, various iterations.
00:44:13:24 - 00:44:17:18
So I think we really have to be cognizant of the ethical use of it and
00:44:17:18 - 00:44:18:19
being very mindful of
00:44:19:21 - 00:44:22:13
not misleading clients
00:44:22:13 - 00:44:25:18
and even for advisors and planners
00:44:25:18 - 00:44:28:20
themselves to understand exactly what goes into the technology.
00:44:30:18 - 00:44:32:17
You know, it's so easy
00:44:32:17 - 00:44:35:18
to print out a report, but do they understand
00:44:36:23 - 00:44:41:02
what the numbers represent in that report and can they explain it to the client?
00:44:41:15 - 00:44:44:15
It's a challenge even for many advisors and many planners.
00:44:44:21 - 00:44:46:14
Absolutely.
00:44:46:14 - 00:44:49:07
Marie, over to you.
00:44:49:07 - 00:44:52:00
I think that
00:44:52:00 - 00:44:53:29
over time
00:44:53:29 - 00:44:57:24
we have seen a real push on education
00:44:58:10 - 00:45:01:10
in the financial services industry.
00:45:02:09 - 00:45:05:09
Over time,
00:45:05:13 - 00:45:08:10
our financial institutions, when we got into this,
00:45:08:10 - 00:45:13:00
were already developing their people in terms of their competencies.
00:45:13:15 - 00:45:16:14
So in a way they were kind of ahead of the game.
00:45:17:16 - 00:45:20:21
So I'm confident that even if we have differences
00:45:20:28 - 00:45:23:29
and we will have differences, we have differences right now.
00:45:23:29 - 00:45:27:10
Quebec has a very different regime from Ontario.
00:45:28:26 - 00:45:30:13
Saskatchewan is talking about
00:45:30:13 - 00:45:33:22
a different regime and New Brunswick is talking about something else.
00:45:33:22 - 00:45:36:18
And then we've got eight other provinces,
00:45:36:18 - 00:45:40:03
seven other provinces haven't declared anything yet.
00:45:40:14 - 00:45:41:29
What I'm what I'm seeing
00:45:41:29 - 00:45:44:29
and this is what I think financial institutions will look to,
00:45:45:04 - 00:45:49:16
is if we can't have harmonization, then what is the standard out there?
00:45:49:25 - 00:45:52:20
And they will probably go to the highest standard
00:45:52:20 - 00:45:55:20
because they want to have a national standard.
00:45:55:28 - 00:45:59:23
And so, for example, when we got into financial planning,
00:45:59:23 - 00:46:01:27
or at least the financial advisory service,
00:46:01:27 - 00:46:03:25
financial planning was much more obvious.
00:46:03:25 - 00:46:06:25
Financial advisory was a bit different, right?
00:46:06:25 - 00:46:08:20
What is a financial advisor?
00:46:08:20 - 00:46:13:22
But we already had our financial institutions taking courses to be able to
00:46:14:26 - 00:46:17:13
develop the competencies of their individuals
00:46:17:13 - 00:46:20:18
such that they could call themselves a financial advisor
00:46:21:23 - 00:46:23:25
credibly and so
00:46:23:25 - 00:46:25:17
I'm heartened, especially when I visit
00:46:25:17 - 00:46:29:14
other places around the world, where the education coming from financial
00:46:29:14 - 00:46:33:17
institutions is not such a strong culture as what we have here in Canada.
00:46:33:26 - 00:46:37:18
I think between the regulation that will give us maybe variations
00:46:37:18 - 00:46:41:04
on a theme, but we will probably come out to something over time.
00:46:41:04 - 00:46:44:02
We're at the beginning of this process, right?
00:46:44:02 - 00:46:44:22
Over time,
00:46:44:22 - 00:46:48:15
I think things will sort themselves out and we'll come to a single standard.
00:46:48:28 - 00:46:51:28
But, well, in Canada that might not be impossible.
00:46:52:10 - 00:46:54:06
Because this is Canada.
00:46:54:06 - 00:46:58:14
But that said, I'm confident that will come to some kind of a stage.
00:46:58:20 - 00:47:02:05
It'll just take a little bit of time as each of the provinces sorts out
00:47:02:16 - 00:47:05:21
what level they should be at and how to set those standards.
00:47:06:16 - 00:47:08:12
So I'm more confident than not.
00:47:09:25 - 00:47:12:01
So I have a question about
00:47:12:01 - 00:47:17:02
your your comment about, you know, increasing the education
00:47:17:02 - 00:47:20:09
standards for financial advisors and financial planners.
00:47:20:09 - 00:47:25:01
But at the same time, we have a population where every study
00:47:25:01 - 00:47:29:22
that I read indicates that financial literacy is is quite low.
00:47:31:01 - 00:47:36:25
You know, is there a risk of these two things having vastly divergent paths?
00:47:36:25 - 00:47:41:04
It seems to me that even though you're very educated, you still have to connect
00:47:41:22 - 00:47:42:27
with your client.
00:47:42:27 - 00:47:45:23
And so if you can comment on that.
00:47:45:23 - 00:47:50:06
Yeah, I think it's very important, the ability to be able to understand
00:47:50:09 - 00:47:53:16
the clients needs and not talk at them about products or services,
00:47:53:23 - 00:47:56:23
not talk at them about your expertise, but rather listen.
00:47:57:09 - 00:48:00:09
So I think one of the developments and again,
00:48:00:19 - 00:48:03:02
Anthony was talking about the future of technology.
00:48:03:02 - 00:48:06:02
I think there's also a development in terms of soft skills,
00:48:06:10 - 00:48:09:29
in terms of being able to talk to the client, being able to listen
00:48:10:19 - 00:48:13:12
not talk about what you've got to offer
00:48:13:12 - 00:48:15:28
but rather understand really well the client.
00:48:15:28 - 00:48:20:28
Part of that ‘putting your client first’ is really around what have you heard?
00:48:21:09 - 00:48:23:11
Where do you think your client is going?
00:48:23:11 - 00:48:27:09
What are they going to need and how can you accommodate those needs
00:48:27:14 - 00:48:31:00
and show them how they can manage their finances
00:48:31:11 - 00:48:34:27
and maybe explain to them that thing they get in the mail, right?
00:48:35:06 - 00:48:38:03
Tell them to read page ten and twelve
00:48:38:03 - 00:48:41:03
and here's the essence of what you need to know.
00:48:41:10 - 00:48:44:01
I think it's incumbent on us to really educate the client
00:48:44:01 - 00:48:47:16
from the individual level into the government level
00:48:47:24 - 00:48:52:24
and then set a standard that I think people can be confident of on.
00:48:54:15 - 00:48:56:10
Yes. Thank you.
00:48:56:10 - 00:48:59:11
Tashia, we're going to end this one with you.
00:48:59:11 - 00:49:03:29
So the future of the regime and also I'd be interested
00:49:03:29 - 00:49:08:07
in your thoughts on this, hopefully not diverge in path
00:49:08:07 - 00:49:09:13
with
00:49:10:19 - 00:49:11:24
professionals, sort of
00:49:11:24 - 00:49:15:06
not being in line with the needs of their client.
00:49:16:19 - 00:49:18:17
Yeah, I was going to comment on the last question
00:49:18:17 - 00:49:21:06
and this sort of relates to it in terms of the future of the regime.
00:49:21:06 - 00:49:25:11
I think, I've been involved in professional regulation for 25 years
00:49:25:22 - 00:49:29:08
and I would say, you know, in some very mature industries
00:49:29:23 - 00:49:32:18
and I would say that the lesson learned
00:49:32:18 - 00:49:35:18
is that regulation is dynamic.
00:49:35:19 - 00:49:38:13
It's not that you put a framework out and then you say, well,
00:49:38:13 - 00:49:42:16
thank you very much, I'm done and we'll just move on to the next thing.
00:49:42:27 - 00:49:45:05
You have to actually spend the time
00:49:45:05 - 00:49:49:00
sort of evolving the framework, looking at the best practices.
00:49:49:08 - 00:49:51:19
You know, you're probably not going to get it perfect
00:49:51:19 - 00:49:52:25
the first time out of the gate.
00:49:52:25 - 00:49:55:20
And I think we've seen that, you know,
00:49:55:20 - 00:49:58:20
I think FSRA has already started to recognize, you know, that there's
00:49:58:20 - 00:50:01:28
probably some refinement needed to the framework
00:50:02:22 - 00:50:05:22
with respect to harmonization across the country.
00:50:05:22 - 00:50:10:12
I think there are some interesting points being raised by other provinces
00:50:10:22 - 00:50:14:13
that probably, you know, FSRA and the CB’s
00:50:14:21 - 00:50:18:17
need to reflect back on and say, does that make sense in Ontario?
00:50:19:13 - 00:50:22:14
So I would say that, you know, I'm very much
00:50:22:14 - 00:50:26:09
looking forward to the commitment that FSRA has made to do a bit
00:50:26:09 - 00:50:28:00
of a review of the framework.
00:50:28:00 - 00:50:31:22
You know, Anthony, I go back to your discussion around technology.
00:50:32:01 - 00:50:36:04
There is a perfect example of not only where the framework
00:50:36:04 - 00:50:39:04
may need to adapt in terms of proficiencies,
00:50:39:11 - 00:50:43:08
but also may need to adapt in terms of standards
00:50:43:14 - 00:50:46:02
that are in place to protect consumers
00:50:46:02 - 00:50:48:08
and also with respect to how you discipline
00:50:48:08 - 00:50:50:08
or how you enforce against those standards.
00:50:50:08 - 00:50:56:14
So it's very much a dynamic process that we need to be evaluating on
00:50:56:14 - 00:51:02:00
a regular basis and sort of seeing where that best practice moves the industry.
00:51:02:07 - 00:51:03:14
Because at the end of the day,
00:51:03:14 - 00:51:07:08
that is the way that we're going to make sure that not only is the consumer
00:51:07:15 - 00:51:11:13
protected in the environment in which they find themselves today,
00:51:11:22 - 00:51:13:21
but they're also protected in the environment
00:51:13:21 - 00:51:17:02
in which they find themselves getting advice into the future.
00:51:19:06 - 00:51:21:12
And I'm trying to go back to the second part of your question.
00:51:21:28 - 00:51:22:24
Maybe you could repeat it?
00:51:22:24 - 00:51:25:05
It’s just about financial literacy
00:51:25:27 - 00:51:28:06
and the fact that advisors
00:51:28:06 - 00:51:33:16
and planners keep knowing more, but there's a whole subset of people
00:51:33:16 - 00:51:38:23
that they don't really keep up with financial literacy.
00:51:38:23 - 00:51:42:24
And so it's just how they would keep that connection with their client.
00:51:43:20 - 00:51:47:05
I think it comes down to providing their clients with information.
00:51:47:10 - 00:51:48:28
Taking the time.
00:51:48:28 - 00:51:51:13
Marie, you spoke about sort of those human skills
00:51:51:22 - 00:51:56:14
and taking the time through that process to explain what their options are.
00:51:56:23 - 00:52:00:13
You know, planning is such a goals-based approach.
00:52:00:23 - 00:52:05:25
So the job of the planner is really to understand the client,
00:52:05:26 - 00:52:08:26
what's important to them, what do they need,
00:52:08:29 - 00:52:10:16
and then helping them understand
00:52:10:16 - 00:52:13:16
the options that they have available to them to get there.
00:52:13:25 - 00:52:17:13
And that means taking the time to explain
00:52:18:09 - 00:52:21:10
what their options are, explain what their choices are,
00:52:21:21 - 00:52:25:10
and and to give them that very clear coaching of how to get there.
00:52:25:13 - 00:52:28:03
It's not just about the plan or the advice.
00:52:28:03 - 00:52:31:00
It's also about taking them along on the journey
00:52:31:00 - 00:52:34:03
and helping them achieve their goals at the end of the day.
00:52:34:14 - 00:52:38:05
And I think that is where really when you look at financial planning,
00:52:38:10 - 00:52:41:19
it's all about goals and achieving those goals
00:52:41:22 - 00:52:44:24
and being that coach and that partner
00:52:44:24 - 00:52:48:17
to your client to help them achieve what's really important to them.
00:52:48:17 - 00:52:50:03
So it's a very personal
00:52:51:06 - 00:52:52:13
relationship.
00:52:52:13 - 00:52:53:21
It's really important.
00:52:53:21 - 00:52:56:26
You know, Marie, you spoke about trust and confidence.
00:52:57:03 - 00:53:00:25
You can't build that relationship without trust and confidence,
00:53:01:06 - 00:53:02:18
and then they trust you
00:53:02:18 - 00:53:05:26
to take the advice that you're providing and trying to implement it
00:53:06:07 - 00:53:09:21
and helping them understand what it all means
00:53:09:21 - 00:53:12:24
and what not necessarily just the technical,
00:53:13:02 - 00:53:17:10
but what it means to them and why is it important to them.
00:53:17:20 - 00:53:20:19
There's lots of financial literacy programs out there
00:53:20:21 - 00:53:24:26
and honestly, a lot of you know, the unfortunate thing is we've got
00:53:25:00 - 00:53:28:19
people have lots of opportunities to learn financial literacy,
00:53:28:19 - 00:53:33:16
but it's not making a difference in terms of what we're seeing in the average client.
00:53:34:15 - 00:53:37:28
And I think what gets lost sometimes is if somebody
00:53:37:28 - 00:53:41:13
is going to learn something, it has to be because it matters to them.
00:53:42:02 - 00:53:45:10
And that's the role of the planner, I think, is to really make sure
00:53:45:18 - 00:53:49:05
that the advice that you're giving is relevant to the individual and it's
00:53:49:05 - 00:53:50:06
in their best interest.
00:53:51:16 - 00:53:52:16
Well, that's great.
00:53:52:16 - 00:53:53:22
Thank you.
00:53:53:22 - 00:53:57:07
Well, that is actually the end of our questions for the panel.
00:53:57:07 - 00:54:00:22
I want to thank our expert panel here today.
00:54:00:22 - 00:54:01:20
That was amazing.
00:54:01:20 - 00:54:05:18
And we should have lots of time for questions. So,
00:54:07:00 - 00:54:10:00
Karabell, if you have any questions, we're ready.
00:54:10:01 - 00:54:11:25
All right.
00:54:11:25 - 00:54:14:10
This question is, can each speaker
00:54:14:10 - 00:54:18:12
describe their respective organizations complaint handling process?
00:54:18:17 - 00:54:21:16
How about we start on the end there with you, Anthony?
00:54:22:12 - 00:54:24:02
Sure.
00:54:24:02 - 00:54:27:26
So I think we have a very robust
00:54:28:13 - 00:54:31:13
complaint handling process.
00:54:31:15 - 00:54:34:25
And I guess from our perspective we can have complaints
00:54:35:15 - 00:54:38:10
that can sort of be initiated in two ways.
00:54:38:10 - 00:54:41:19
One could be a complaint that's initiated by the public
00:54:42:12 - 00:54:46:15
and then another
00:54:47:27 - 00:54:50:27
way would be something that we sort of identify
00:54:51:25 - 00:54:55:14
either through a disciplinary hearing from another organization or another entity
00:54:56:12 - 00:54:59:09
and that sort of kickstarts a separate process.
00:54:59:09 - 00:55:02:08
But essentially what happens is if we're talking about
00:55:02:08 - 00:55:05:16
a complaint from the public against one of our credential holders,
00:55:06:24 - 00:55:10:15
clearly the first thing we have to do is gather the information from
00:55:12:04 - 00:55:14:10
from the complainant
00:55:14:10 - 00:55:18:05
and verify first and foremost that it is in fact,
00:55:19:10 - 00:55:21:11
it does in fact, have merit.
00:55:21:11 - 00:55:24:20
Just a case in point, just probably last week
00:55:24:20 - 00:55:28:26
we had a complaint come in and it was about
00:55:29:24 - 00:55:32:11
investment returns
00:55:32:11 - 00:55:36:16
and sort of not keeping up with the market.
00:55:36:19 - 00:55:39:19
Clearly, that has nothing to do with
00:55:40:03 - 00:55:43:03
all of the factors considered in the case, had nothing to do
00:55:43:06 - 00:55:46:15
with anything that the advisor had done incorrectly.
00:55:46:15 - 00:55:50:06
So it's first of all, establishing whether there is merit to this complaint.
00:55:51:13 - 00:55:54:13
Once that's established, then obviously we open a file,
00:55:54:28 - 00:55:58:06
then we have to speak to the advisor or to speak to the planner
00:55:58:08 - 00:56:00:03
to get their side of the story.
00:56:00:03 - 00:56:02:16
And we share this information with the complainant.
00:56:02:16 - 00:56:06:12
And then it's really then about the investigative process
00:56:06:12 - 00:56:08:22
that that sort of kicks in at that point.
00:56:08:22 - 00:56:12:28
and our initial conduct committee
00:56:12:28 - 00:56:15:06
will look at it and if they can rule on it,
00:56:15:06 - 00:56:18:17
there are various sanctions that they can implement.
00:56:18:28 - 00:56:22:24
Typically what we find in most instances is
00:56:23:25 - 00:56:26:14
education is really the key.
00:56:26:14 - 00:56:29:14
So we would like to take an approach where
00:56:29:21 - 00:56:32:21
we can educate the advisor if they are in fact
00:56:33:01 - 00:56:36:01
guilty of some sort of breach with the code of conduct
00:56:37:18 - 00:56:38:23
rather than,
00:56:38:23 - 00:56:41:23
because oftentimes what we do find is that
00:56:42:13 - 00:56:43:20
the breach is because
00:56:43:20 - 00:56:48:22
of a misunderstanding or an oversight or something along those lines.
00:56:48:22 - 00:56:52:12
Nothing that was sort of malicious intent.
00:56:52:25 - 00:56:55:25
And if that is the case, then we often find that education
00:56:56:10 - 00:56:58:04
can be a very, very valuable tool.
00:56:58:04 - 00:57:03:13
And obviously we're mindful of them not repeating that breach.
00:57:03:22 - 00:57:06:00
But usually that works.
00:57:06:00 - 00:57:08:21
If it's something of a more serious nature than obviously we'd
00:57:08:21 - 00:57:10:08
have to look at other sanctions.
00:57:10:08 - 00:57:12:14
It could be
00:57:12:14 - 00:57:15:22
it could be to the extreme, I guess, revoking the credential
00:57:15:22 - 00:57:17:07
from that individual.
00:57:17:07 - 00:57:19:04
Now, in the more serious cases,
00:57:20:04 - 00:57:20:25
the case would be
00:57:20:25 - 00:57:24:02
then transferred over to the hearing panel from the conduct committee.
00:57:24:07 - 00:57:27:19
And then the hearing panel would be a panel where we would have the
00:57:27:26 - 00:57:30:23
advisor or the planner, we would speak to them directly,
00:57:30:23 - 00:57:34:28
virtually or directly gather the facts, make a ruling.
00:57:34:28 - 00:57:37:29
And again, a variety of sanctions could take place from there,
00:57:38:28 - 00:57:43:28
including, I guess, worst case scenario, an outright revocation of the credential
00:57:44:02 - 00:57:47:13
and a future ban from ever getting the credential again.
00:57:47:25 - 00:57:50:25
So I skipped a lot of steps just in the interest of time.
00:57:50:26 - 00:57:54:17
But that's sort of the synopsis of our complaint handling process.
00:57:54:21 - 00:57:56:10
Thank you. Tashia.
00:57:56:10 - 00:57:59:02
Okay, I'm going to say this, and I've got four three staff
00:57:59:02 - 00:58:03:02
from my standards council in the room.
00:58:03:02 - 00:58:05:17
So I'm going to try to make sure I get this right.
00:58:05:17 - 00:58:09:15
So the first thing is how do we manage a complaint when it comes in?
00:58:09:15 - 00:58:13:10
So we would take two approaches, very similar to what Anthony said.
00:58:14:07 - 00:58:19:19
Obviously, we have mechanisms whereby we make consumers aware
00:58:19:27 - 00:58:24:14
on both our website and our consumer site where they can make a complaint
00:58:24:26 - 00:58:27:27
or we also are very proactive in reaching out.
00:58:27:27 - 00:58:28:15
We have
00:58:29:24 - 00:58:31:02
mutual
00:58:31:02 - 00:58:34:00
sort of memorandums of understanding with other regulators
00:58:34:00 - 00:58:38:24
Whereby we will share information around complaints and we are actively
00:58:39:02 - 00:58:44:16
seeking out the work that happens across the regulatory community to make that
00:58:44:16 - 00:58:47:16
there are not other complaints that we're just not aware of.
00:58:47:25 - 00:58:51:17
Once a complaint comes in, we have a team of investigators
00:58:51:17 - 00:58:55:19
and the team of investigators will then look into the complaint,
00:58:55:29 - 00:58:58:26
make sure, first of all, it relates to our professional standards.
00:58:58:26 - 00:59:01:09
So we have a code of ethics.
00:59:01:09 - 00:59:03:23
We have standards of professional responsibility,
00:59:03:23 - 00:59:05:02
we have practice standards.
00:59:05:02 - 00:59:07:11
Then we have what we call a fitness standard.
00:59:07:11 - 00:59:11:12
So they're first looking to see how does that complaint apply
00:59:11:12 - 00:59:14:28
against these standards and where is the
00:59:15:14 - 00:59:18:14
where are the actions that we need to look at enforcement activity?
00:59:19:03 - 00:59:22:03
Once that investigation is complete
00:59:22:11 - 00:59:25:05
it then gets handled by our
00:59:26:20 - 00:59:28:20
conduct panel.
00:59:28:20 - 00:59:31:11
And our conduct panel
00:59:31:11 - 00:59:34:11
will sit back and they will say, okay,
00:59:34:12 - 00:59:36:04
is this something that's egregious?
00:59:36:04 - 00:59:37:15
Is this something that needs to go on
00:59:37:15 - 00:59:41:06
to a disciplinary panel or is this something that we feel
00:59:41:26 - 00:59:43:25
needs to be handled through an advisement?
00:59:43:25 - 00:59:45:09
Or possibly they could say,
00:59:45:09 - 00:59:48:11
you know what, this is not anything that we need to be concerned about.
00:59:48:18 - 00:59:51:11
You know, to your point, it could be something that
00:59:51:11 - 00:59:54:11
where the planner hadn’t done anything wrong.
00:59:54:13 - 00:59:57:13
And so those are the three actions there.
00:59:57:26 - 01:00:00:24
If something is deemed to be sufficiently egregious,
01:00:00:24 - 01:00:03:12
then it will go on to our hearing panel.
01:00:03:12 - 01:00:05:03
Our hearing panel is a roster.
01:00:05:03 - 01:00:09:07
And so we will generally pick three people from that roster.
01:00:09:16 - 01:00:12:16
Typically, they are all members of the public
01:00:12:18 - 01:00:17:25
and they will hear and often they’re lawyers who will volunteer and work with us
01:00:18:06 - 01:00:21:13
and they will then hear the matter and make a decision.
01:00:21:13 - 01:00:22:14
And as I said before,
01:00:22:14 - 01:00:25:28
there are various sanctions that they can apply based on that decision.
01:00:26:13 - 01:00:29:08
I would say that the other part of our process
01:00:29:08 - 01:00:33:21
is our conduct review panel is actually got public representation on it as well.
01:00:33:21 - 01:00:37:22
So we try to make sure that we have public representation throughout the process
01:00:38:07 - 01:00:40:16
and then all of our decisions are public.
01:00:40:16 - 01:00:44:23
So everything that happens through the process becomes public.
01:00:45:00 - 01:00:50:07
When there's a hearing, it's public. When there is a decision, it's public.
01:00:50:13 - 01:00:53:13
And so somebody can go on our website and see
01:00:53:19 - 01:00:56:19
it's very transparent in terms of the entire process.
01:00:57:05 - 01:01:00:06
And the other thing I wanted to add is what the team does a very, very good
01:01:00:06 - 01:01:06:00
job of is they have sort of standards around how long it should take
01:01:06:00 - 01:01:09:03
to give back to a complainant and various parts of the process.
01:01:09:11 - 01:01:12:10
One of the worst things that can happen, I think, is somebody makes a complaint
01:01:12:10 - 01:01:15:15
and it's three years later before they actually find out
01:01:16:05 - 01:01:18:21
what happened as a result of their complaint.
01:01:18:21 - 01:01:21:21
So we have timelines that we try to adhere to
01:01:22:02 - 01:01:26:09
and we also report annually, we put out a Standards Council report
01:01:26:09 - 01:01:30:06
annually that sort of highlights all the work that we've been doing
01:01:30:06 - 01:01:32:26
around the enforcement of the standard setting process.
01:01:32:26 - 01:01:37:11
So it's very transparent, very open and very much designed
01:01:37:11 - 01:01:40:06
so as the public can see the work that we're doing.
01:01:40:06 - 01:01:40:22
That's great.
01:01:40:22 - 01:01:41:08
Thank you.
01:01:41:08 - 01:01:44:02
And lots of call outs for the team today, guys.
01:01:44:02 - 01:01:45:13
Way to go!
01:01:45:13 - 01:01:46:18
Marie?
01:01:46:18 - 01:01:49:00
Yeah, without sounding like an echo,
01:01:50:11 - 01:01:51:26
we have similar processes.
01:01:51:26 - 01:01:55:19
I think the most important starting point is what is the complaint
01:01:56:04 - 01:01:58:20
and how should it be handled
01:01:58:20 - 01:02:01:19
and is it something that we can handle right?
01:02:02:07 - 01:02:06:17
Is it something where we can eventually take the person's title away?
01:02:06:28 - 01:02:10:01
And so we will look at each each complaint
01:02:10:08 - 01:02:13:08
and then determine how it should be handled.
01:02:13:08 - 01:02:16:23
We have a complaints process, a complaints board.
01:02:17:10 - 01:02:19:23
We have someone who's external who oversees it.
01:02:19:23 - 01:02:21:00
So it's not us.
01:02:21:00 - 01:02:24:11
It's a sort of third party, someone who knows the area very well
01:02:24:18 - 01:02:28:12
and who can make a judgment on the way we should process.
01:02:28:20 - 01:02:31:25
And then we go through the processes similar to the
01:02:32:17 - 01:02:35:24
the functions described by Tashia and Anthony
01:02:36:18 - 01:02:39:25
to be able to say, okay, what are we going to do with this person?
01:02:40:01 - 01:02:42:28
And ultimately, do we take the designation away?
01:02:42:28 - 01:02:46:03
We also look at what are the other bodies doing.
01:02:46:03 - 01:02:49:15
So is this person also under investigation by somebody else?
01:02:49:15 - 01:02:52:24
Has this person complained to the FSRA?
01:02:52:24 - 01:02:54:00
Have they complained to CIRO?
01:02:54:00 - 01:02:57:12
Have they complained to FP Canada or to Anthony's group?
01:02:58:00 - 01:03:01:05
Because we kind of have to work in concert, if we have someone
01:03:01:12 - 01:03:05:21
who's not acting properly, but they also have another designation,
01:03:05:27 - 01:03:08:27
we need to make sure that we're acting kind of in concert.
01:03:08:29 - 01:03:12:08
And so we try to make sure that we're at least working together
01:03:12:08 - 01:03:14:15
so that we aren't working at cross-purposes.
01:03:14:15 - 01:03:16:04
Or two of us are investigating this thing
01:03:16:04 - 01:03:18:09
because a client has gone from one to the other
01:03:18:09 - 01:03:20:16
and we're all working on something that we should be working on it
01:03:20:16 - 01:03:24:06
together to make sure that we have a proper process in place.
01:03:24:24 - 01:03:26:18
That's really good to hear, because I think it's
01:03:26:18 - 01:03:30:28
one of the things we worry about, is that a bad actor out there
01:03:30:28 - 01:03:35:02
just, you know, jumping ship from one CB to another?
01:03:35:02 - 01:03:38:02
So I'm really glad to hear that that's going on.
01:03:38:07 - 01:03:38:14
Okay.
01:03:38:14 - 01:03:42:24
We have another question, and this one is, what steps can we take to improve
01:03:42:24 - 01:03:47:18
financial literacy through secondary and tertiary education levels?
01:03:47:26 - 01:03:49:07
Marie, do you want to start with that one?
01:03:50:21 - 01:03:52:16
Yeah, there's a lot to do.
01:03:52:16 - 01:03:55:24
It probably starts when children are very young and they need
01:03:55:24 - 01:03:59:01
to understand the basics of finances, which is something we didn't do
01:04:00:02 - 01:04:00:24
back in the day.
01:04:00:24 - 01:04:03:09
Certainly I didn't have anything like that.
01:04:03:09 - 01:04:06:13
I think it starts in high school or even in primary school,
01:04:07:04 - 01:04:11:20
and it's developing a comfort with your financial situation,
01:04:11:20 - 01:04:16:00
even if it's a very simple one and then bringing that culture to them.
01:04:16:00 - 01:04:19:05
So it's part of what they think about and not something that's like,
01:04:19:23 - 01:04:22:14
you know, don't don't think about that or don't understand budgeting
01:04:22:14 - 01:04:24:23
or don't understand I've got a part time job.
01:04:24:23 - 01:04:27:22
What can I do? How should I manage my money?
01:04:27:22 - 01:04:31:07
And so bring that mentality of managing money
01:04:31:20 - 01:04:34:28
into people very young and then develop that over time.
01:04:35:16 - 01:04:39:21
I think also there are lots of sort of consumer or type
01:04:41:14 - 01:04:42:22
programs that are out there
01:04:42:22 - 01:04:47:02
for financial literacy that we need to encourage people to take.
01:04:47:02 - 01:04:48:15
But it's really hard
01:04:48:15 - 01:04:51:06
because if you don't have a culture of looking at your finances
01:04:51:06 - 01:04:55:05
or you sort of take that prospectus and move it to the blue box
01:04:55:18 - 01:04:59:09
you haven't really developed any kind of knowledge of your financials,
01:04:59:18 - 01:05:02:21
your financials or what your financial products are doing for you.
01:05:03:04 - 01:05:04:29
So it's a huge job.
01:05:04:29 - 01:05:08:01
I think even having a consumer understand the difference
01:05:08:01 - 01:05:11:01
between a financial advisor and a financial planner,
01:05:11:15 - 01:05:14:15
I'm sure lots of people have no idea what the difference is.
01:05:14:19 - 01:05:17:12
And so the education piece is going to be really important.
01:05:17:12 - 01:05:19:14
The fact that the FSRA is stepping in
01:05:19:14 - 01:05:21:28
to do education, I think will be really important.
01:05:22:22 - 01:05:23:26
I'll leave it at that. So we Tashia,
01:05:23:26 - 01:05:25:07
Absolutely. Tashia?
01:05:26:27 - 01:05:27:26
I think, you know,
01:05:27:26 - 01:05:31:02
to improve financial literacy, you really have to look at two things.
01:05:31:02 - 01:05:33:21
You have to look at the modality about how you deliver it,
01:05:33:21 - 01:05:37:18
because that delivery is not the same to every group that you're working with.
01:05:37:18 - 01:05:40:09
If you're trying to provide financial literacy
01:05:40:09 - 01:05:43:09
for a high school student or for somebody in primary,
01:05:43:23 - 01:05:49:04
going in and talking about money is not going to be of interest to them.
01:05:49:04 - 01:05:50:08
So you've got to employ a little,
01:05:50:08 - 01:05:54:07
you got to be a little bit more creative in how you involve gamification.
01:05:54:07 - 01:05:57:13
You've got to get them engaged, you've got to get them involved in that manner.
01:05:57:25 - 01:06:00:16
And I think that becomes really important.
01:06:00:16 - 01:06:03:22
And then the second thing I think you have to realize is
01:06:03:29 - 01:06:07:20
not all financial literacy is equal, that there are different groups
01:06:07:20 - 01:06:10:27
that are facing different challenges, and you've got to address
01:06:10:27 - 01:06:14:12
that diversity in the types of programing that you're providing.
01:06:14:26 - 01:06:18:24
So although I'm not, we're talking about secondary and tertiary education levels.
01:06:18:24 - 01:06:22:13
I would say, you know, one of the things that we're doing is
01:06:22:28 - 01:06:25:19
we have financial literacy education that we're starting
01:06:25:19 - 01:06:28:28
to deliver through our Canadian Foundation for Financial Planning.
01:06:29:27 - 01:06:33:06
One of the first courses that we're offering is for new Canadians.
01:06:33:12 - 01:06:37:11
And one of the things that we're doing in those courses is, for example,
01:06:37:11 - 01:06:40:15
providing offerings in Farsi and in Hindi
01:06:40:21 - 01:06:43:21
and then the languages that the new Canadians are speaking
01:06:43:23 - 01:06:46:24
so as they can actually benefit
01:06:47:18 - 01:06:50:06
from the knowledge that they're gaining.
01:06:50:06 - 01:06:53:23
And I think having that lens of who are you speaking to
01:06:54:01 - 01:06:56:27
and how are you going to resonate with those individuals?
01:06:56:27 - 01:06:59:24
Because there's a lot of financial literacy training out there.
01:06:59:24 - 01:07:02:24
Every financial institution is doing financial literacy.
01:07:02:28 - 01:07:05:29
There are a number of not-for-profits, doing financial literacy.
01:07:06:08 - 01:07:09:11
But I think the key is, is to try to get that approach
01:07:09:18 - 01:07:12:19
whereby people are actually going to be able to understand it
01:07:12:24 - 01:07:16:03
and it's going to be meaningful to their particular circumstances.
01:07:17:18 - 01:07:18:03
That's great.
01:07:18:03 - 01:07:18:26
Thank you.
01:07:18:26 - 01:07:22:02
Now, Anthony, I know a lot of all of your designations
01:07:22:02 - 01:07:25:09
really have a retirement sort of bent to them.
01:07:26:12 - 01:07:30:02
And everything I read about people thinking about retiring
01:07:30:02 - 01:07:33:09
is usually in the negative that they're not ready,
01:07:33:09 - 01:07:35:04
they don't have enough money.
01:07:35:04 - 01:07:37:17
So talk to us, you know, specifically
01:07:37:17 - 01:07:40:17
about education in that realm.
01:07:41:16 - 01:07:45:12
Well, I think the focus of our curriculum
01:07:45:12 - 01:07:49:16
and some of our designation on retirement is simply because so much
01:07:49:16 - 01:07:52:16
of the financial planning conversation
01:07:52:28 - 01:07:55:28
that individuals have,
01:07:56:13 - 01:07:59:07
what's what's top of mind is am I going to be able to retire?
01:07:59:07 - 01:08:00:29
And if so, what level of,
01:08:00:29 - 01:08:03:14
you know, lifestyle can I can I maintain my current lifestyle?
01:08:03:14 - 01:08:08:24
It's such a dominating theme in all conversations with financial planning.
01:08:10:01 - 01:08:12:23
So I think that's sort of the angle that we looked at it.
01:08:12:23 - 01:08:16:21
But, you know, we want to make sure that when we're talking about retirement,
01:08:18:18 - 01:08:21:17
sort of to Tashia's point
01:08:21:17 - 01:08:24:17
in terms of the mode that it's delivered in
01:08:24:19 - 01:08:27:19
and it's an appropriate discussion
01:08:28:02 - 01:08:30:18
for the recipient of this information.
01:08:30:18 - 01:08:30:23
Okay.
01:08:30:23 - 01:08:33:22
So, for example,
01:08:34:27 - 01:08:37:27
back in the day with with your designation, Tashia,
01:08:37:27 - 01:08:41:11
with the CFP designation, when you used to have the capstone course requirement.
01:08:42:24 - 01:08:44:06
We used to have,
01:08:44:06 - 01:08:46:22
there used to be a requirement where
01:08:46:22 - 01:08:52:05
students would submit a financial plan based on a mock case study.
01:08:52:22 - 01:08:55:15
And oftentimes it had to deal with retirement,
01:08:55:15 - 01:08:57:04
not always, but sometimes.
01:08:57:04 - 01:09:00:04
So we would get advisors and planners and, you know,
01:09:00:14 - 01:09:03:26
bless them for the time and the effort that they put into this,
01:09:04:07 - 01:09:08:17
they would sometimes come in and produce a 100 page document, 120 page document
01:09:09:07 - 01:09:13:15
with all kinds of calculations and projections
01:09:14:25 - 01:09:15:27
for a
01:09:15:27 - 01:09:20:03
for an individual that's 25 years old, that's just finished university
01:09:20:03 - 01:09:23:10
and just entering into the workforce.
01:09:23:20 - 01:09:27:04
And could you imagine, I would often say to the student,
01:09:27:04 - 01:09:30:14
when I'm reviewing their plan, I would say, could you imagine
01:09:30:14 - 01:09:33:17
if you dropped this tome in front of this
01:09:33:17 - 01:09:36:17
individual with 125 pages,
01:09:37:00 - 01:09:40:21
are they likely to be overwhelmed and push that document away?
01:09:41:08 - 01:09:44:02
Or do you think that they're going to embrace that document?
01:09:44:02 - 01:09:44:29
In other words,
01:09:44:29 - 01:09:47:29
the whole idea of a financial plan is it should be something that
01:09:48:06 - 01:09:49:12
a client embraces.
01:09:49:12 - 01:09:53:28
So when you've left their house and they're still sitting at the kitchen table
01:09:53:28 - 01:09:56:05
you know, are they pushing that document away
01:09:56:05 - 01:09:59:07
because it's too intimidating or too overwhelming, or
01:09:59:07 - 01:10:02:07
are they going to pull it in and, you know, continue reading?
01:10:02:12 - 01:10:04:29
So I think it's having an understanding.
01:10:04:29 - 01:10:07:29
I think that's one of the, you know, areas where I think
01:10:08:03 - 01:10:11:17
advisors, prospective advisors and planners can can really learn
01:10:11:17 - 01:10:16:04
a lot is understanding their audience and what is appropriate.
01:10:17:04 - 01:10:18:09
What is appropriate language?
01:10:18:09 - 01:10:20:03
That's another thing as well.
01:10:20:03 - 01:10:23:21
You see so many planners throw jargon, technical terms around
01:10:23:28 - 01:10:25:02
and it's dizzying, right?
01:10:25:02 - 01:10:26:23
I mean, the amount of acronyms that are out there,
01:10:26:23 - 01:10:29:17
it's really dizzying and it's overwhelming.
01:10:29:17 - 01:10:34:01
In some cases, it may be appropriate, but in other cases less so.
01:10:34:01 - 01:10:37:20
And I think a really important skill for planners and advisors,
01:10:37:20 - 01:10:40:28
that’s where the role of education comes in, is
01:10:41:23 - 01:10:44:04
teaching them what is or being able
01:10:44:04 - 01:10:47:04
to recognize what is the appropriate level to speak to a client at.
01:10:47:09 - 01:10:51:14
Because if you want to get that client to buy into what you're saying,
01:10:51:20 - 01:10:54:20
you're going to have to connect with them right?
01:10:57:11 - 01:10:57:27
Well, that's great.
01:10:57:27 - 01:10:58:09
Thank you.
01:10:58:09 - 01:11:01:01
Yes, I think I would be rather daunted by
01:11:02:05 - 01:11:05:05
a 120 page document.
01:11:05:18 - 01:11:06:12
But it's true.
01:11:06:12 - 01:11:10:07
I mean, we're all entrenched in this work.
01:11:10:07 - 01:11:12:20
And sometimes you forget that
01:11:12:20 - 01:11:16:01
those who you're speaking to are not so we all struggle with that.
01:11:16:10 - 01:11:18:04
That is for sure.
01:11:18:04 - 01:11:22:21
We have a question that is actually for myself.
01:11:22:21 - 01:11:26:21
How does FSRA supervise the principle of putting clients interests first?
01:11:28:27 - 01:11:30:26
Well, I can tell you that
01:11:30:26 - 01:11:35:14
in the title protection rule and actually I'll read it to you,
01:11:36:09 - 01:11:41:18
it requires people using approved credentials to deal with clients
01:11:41:18 - 01:11:45:10
competently, professionally, fairly, honestly, and in good faith.
01:11:46:28 - 01:11:48:20
So we believe, of course,
01:11:48:20 - 01:11:54:14
that part of meeting that standard is to put the client's interest first
01:11:54:14 - 01:11:58:07
when preparing a financial plan or providing financial advice.
01:11:58:24 - 01:12:02:14
It is our expectation that all approved CB’s,
01:12:02:18 - 01:12:07:28
including of course, those on this panel, would put this principle
01:12:07:28 - 01:12:13:06
at the core of what they do when providing a financial planner advice.
01:12:14:18 - 01:12:16:25
So some of the key metrics
01:12:16:25 - 01:12:21:26
that we would use and we did this most recently with the examination,
01:12:22:08 - 01:12:26:28
the first examination that took place of our approved CB’s
01:12:27:15 - 01:12:33:09
was, we would ensure that the CBs hold their credential holders accountable
01:12:33:09 - 01:12:37:12
for a code of conduct that includes putting the client's interests first.
01:12:37:23 - 01:12:41:01
And not only that, they would have to attest
01:12:41:11 - 01:12:44:11
yearly to the fact that they're doing so,
01:12:44:11 - 01:12:47:16
and not only would they attest, but they would have a metric
01:12:47:16 - 01:12:51:03
that they run to ensure that everybody's actually doing it.
01:12:51:03 - 01:12:54:18
So they're there fleshing out those that maybe forgot
01:12:54:18 - 01:12:57:18
to check the box and finding out why.
01:12:58:13 - 01:13:00:13
We would also ensure
01:13:00:13 - 01:13:04:28
we talked about CSI’s webinar that they are
01:13:04:28 - 01:13:09:07
actively communicating this principle to their credential holders.
01:13:09:19 - 01:13:12:23
So whether it is having seminars,
01:13:12:23 - 01:13:18:09
webinars, it's in your CE programs, but it is at the forefront
01:13:18:22 - 01:13:22:11
of just continuous learning for credential holders.
01:13:24:02 - 01:13:26:29
And then finally,
01:13:26:29 - 01:13:30:05
you know, you're verifying through consumers
01:13:30:05 - 01:13:34:04
that they feel satisfied with the work that has been done.
01:13:35:22 - 01:13:39:12
So I think this will remain
01:13:39:13 - 01:13:43:09
a principle of title protection.
01:13:43:09 - 01:13:45:19
It's at the core of consumer protection.
01:13:45:19 - 01:13:49:15
And I think really at the root of it, it is
01:13:50:16 - 01:13:52:23
that, you know,
01:13:52:23 - 01:13:56:15
sometimes and this has been, I think the criticism of late
01:13:56:15 - 01:13:59:15
that there's just a sales process going on here,
01:14:00:12 - 01:14:02:24
not with planning but with advice.
01:14:02:24 - 01:14:06:23
And that is obviously what we don't want to see.
01:14:07:08 - 01:14:10:27
So it will remain a principle of title protection.
01:14:11:08 - 01:14:14:08
It does look like maybe we have time for one more question.
01:14:16:23 - 01:14:21:14
Is FSRA going to increase the minimum standard for financial advisor
01:14:21:14 - 01:14:24:23
title use, similar to what Saskatchewan is proposing?
01:14:25:15 - 01:14:29:25
So we talked a little bit about harmonization today.
01:14:30:29 - 01:14:35:08
I can tell you that one of the things we are doing and I'm quite
01:14:35:08 - 01:14:39:02
proud of just two years into this regime
01:14:39:02 - 01:14:41:10
is we're reviewing the framework already.
01:14:43:01 - 01:14:45:06
And I think that is important to do.
01:14:45:06 - 01:14:48:18
Our most recent sector was health service providers.
01:14:48:18 - 01:14:55:19
That happened in 2014 and we didn't review it on this type of pace.
01:14:56:01 - 01:15:00:09
So I'm proud that we're doing so so that we can apply
01:15:00:09 - 01:15:03:09
lessons learned very early on.
01:15:03:14 - 01:15:07:04
So one of the obviously
01:15:07:13 - 01:15:10:13
Saskatchewan came out with their paper
01:15:10:22 - 01:15:13:14
that not only had a higher
01:15:13:14 - 01:15:18:07
standard for financial advisors, but also had additional
01:15:19:00 - 01:15:22:00
disciplinary powers that we don't have.
01:15:22:12 - 01:15:27:17
So as we gather evidence in the evaluation of the framework,
01:15:27:17 - 01:15:31:29
we will look at what Saskatchewan is proposing.
01:15:32:08 - 01:15:35:00
There is, over time
01:15:35:00 - 01:15:38:03
looking at the future phases of title protection,
01:15:38:03 - 01:15:42:03
a sort of continuous improvement principle,
01:15:44:01 - 01:15:46:18
but it will be based on evidence.
01:15:46:18 - 01:15:49:18
So we're gathering evidence right now
01:15:50:19 - 01:15:54:02
and if we believe that that is the right thing to do,
01:15:54:02 - 01:15:57:02
then we will certainly look at that.
01:15:57:09 - 01:16:00:11
I can tell you that New Brunswick, which is the other
01:16:00:11 - 01:16:03:11
province, who I mean, our policy
01:16:04:01 - 01:16:07:26
folks are in touch with both Saskatchewan and New Brunswick all of the time.
01:16:08:16 - 01:16:11:28
They put out their paper, I think, just this past January,
01:16:11:28 - 01:16:16:07
and they did not propose an increase to those standards.
01:16:17:23 - 01:16:20:23
So there is yet to be uniformity.
01:16:21:14 - 01:16:24:19
But as we go forward, evaluating the framework,
01:16:24:19 - 01:16:27:19
that will certainly be under consideration.
01:16:29:00 - 01:16:31:13
And I think with that we are at time.
01:16:31:13 - 01:16:33:19
So I want to again thank the panel.
01:16:33:19 - 01:16:39:10
I know I learned a lot and it was almost like another little mini consultation
01:16:39:10 - 01:16:41:29
for us as we do evaluate this framework.
01:16:41:29 - 01:16:45:19
So I appreciate that and thank you again.
01:16:45:19 - 01:16:49:07
I hope that both those of you listening in
01:16:49:07 - 01:16:52:14
and here in the room, that you enjoyed it as well and got something out of it.
01:16:52:27 - 01:16:55:26
So thank you all very much. We have actually
01:16:56:27 - 01:16:57:22
a reception
01:16:57:22 - 01:17:03:08
happening I think it is 2:30 till 3:30, probably out in the main area.
01:17:03:22 - 01:17:05:04
So please join us.
01:17:05:04 - 01:17:07:29
And I think there's a cash bar, maybe
01:17:07:29 - 01:17:11:22
and a chance for you all to network.
01:17:11:28 - 01:17:13:00
So thanks again.
00:00:05,138 -- 00:00:06,740
Thank you very much for,
00:00:06,740 -- 00:00:09,209
coming to the Credit Union breakout session.
00:00:09,209 -- 00:00:11,311
We got the big room because we got the biggest turnout.
00:00:11,311 -- 00:00:12,345
You look around, you like
00:00:12,345 -- 00:00:14,814
it doesn't look like a big turnout, but it actually is.
00:00:14,814 -- 00:00:17,083
It's just a huge room, so we're not feeling it.
00:00:17,083 -- 00:00:19,319
If you feel like coming up to the front of the room,
00:00:19,319 -- 00:00:22,889
there are tons of spaces, so please come up if you wish.
00:00:22,889 -- 00:00:25,091
And this isn't your only chance at any point
00:00:25,091 -- 00:00:27,160
in this session. You want to come up? Please move up.
00:00:27,160 -- 00:00:31,731
No problem. Oh, Chandra is already coming.
00:00:31,731 -- 00:00:34,934
So this session is called Long Term
00:00:34,934 -- 00:00:37,270
Vision and Evolution of the Credit Union System.
00:00:37,270 -- 00:00:39,139
You may have seen
00:00:39,139 -- 00:00:41,007
instead of the word evolution, transformation
00:00:41,007 -- 00:00:45,211
somewhere. At some point in discussing this with,
00:00:45,211 -- 00:00:47,614
some of FSRA colleagues and the panel,
00:00:47,614 -- 00:00:49,649
we decided it would be more fitting and more accurate
00:00:49,649 -- 00:00:51,618
to call it evolution as opposed to transformation.
00:00:52,685 -- 00:00:55,788
So if you see that word change, that's why.
00:00:55,788 -- 00:00:58,825
We have a fantastic turnout in person.
00:00:58,825 -- 00:01:02,228
I'm not sure how many people we have online, but
00:01:02,228 -- 00:01:03,463
thank you very much for all of you,
00:01:03,463 -- 00:01:08,468
all of you that are joining online as well.
00:01:09,369 -- 00:01:13,339
Is this advancing?
00:01:13,339 -- 00:01:14,874
I swear I'm pushing the button.
00:01:14,874 -- 00:01:17,710
There you go. You got it. Good.
00:01:17,710 -- 00:01:18,244
Wait.
00:01:18,244 -- 00:01:21,481
What did I do differently the third time?
00:01:21,481 -- 00:01:23,916
All right, so, this is the agenda.
00:01:23,916 -- 00:01:28,121
We have 75 minutes. Let me take a look.
00:01:28,121 -- 00:01:30,189
Yeah, we got 75 minutes.
00:01:30,189 -- 00:01:32,592
A couple of minutes more, maybe.
00:01:32,592 -- 00:01:34,527
I will first introduce our panelists.
00:01:34,527 -- 00:01:35,194
And I think
00:01:35,194 -- 00:01:38,731
probably many of, you know, most of our panelists already.
00:01:38,731 -- 00:01:39,699
Then I will talk about
00:01:39,699 -- 00:01:42,101
why this topic is important for FSRA
00:01:42,101 -- 00:01:43,536
and why we're doing this.
00:01:43,536 -- 00:01:46,205
That will probably take about ten minutes.
00:01:46,205 -- 00:01:48,608
Then we'll go into the panel discussion
00:01:48,608 -- 00:01:50,109
and I'm just facilitating
00:01:50,109 -- 00:01:51,277
the attention should be on
00:01:51,277 -- 00:01:53,379
these four fantastic people here, not on me.
00:01:54,480 -- 00:01:56,349
And then we're going to save some time
00:01:56,349 -- 00:01:57,950
for questions at the end.
00:01:57,950 -- 00:01:59,852
So we got a little monitor here.
00:01:59,852 -- 00:02:01,654
And your questions do appear on the monitor.
00:02:01,654 -- 00:02:03,289
So we all see it.
00:02:03,289 -- 00:02:06,759
And we'll go through some of those.
00:02:06,759 -- 00:02:09,762
If you have a question
00:02:09,762 -- 00:02:14,100
while we're going through the session, please send it in.
00:02:14,100 -- 00:02:16,669
Oh. Thank you. If this doesn't work, use this.
00:02:16,669 -- 00:02:19,505
All right. Cool.
00:02:19,505 -- 00:02:22,542
I'm just going to go straight to that one.
00:02:22,542 -- 00:02:22,809
Yeah.
00:02:22,809 -- 00:02:23,976
Don't, don't wait to remember
00:02:23,976 -- 00:02:26,212
what your question is to the end. Send it.
00:02:26,212 -- 00:02:28,548
You can also do anonymous on your Chime app.
00:02:28,548 -- 00:02:29,749
I think that's what it's called.
00:02:29,749 -- 00:02:30,283
Send it.
00:02:30,283 -- 00:02:31,184
It'll go into the queue
00:02:31,184 -- 00:02:35,054
and then we'll address it at the end of the session.
00:02:35,054 -- 00:02:36,455
All right.
00:02:36,455 -- 00:02:38,291
So,
00:02:38,291 -- 00:02:41,294
you have the Bios for everybody that's on panel.
00:02:41,294 -- 00:02:42,995
So I'm not going to give you a long description
00:02:42,995 -- 00:02:46,165
because we have a fantastic panel.
00:02:46,165 -- 00:02:48,901
But I will give you a very short description and introduce
00:02:48,901 -- 00:02:50,236
our four panel members.
00:02:50,236 -- 00:02:55,007
We'll do it by alphabetical order, by last name.
00:02:55,007 -- 00:02:56,809
So Jacquie Davison first.
00:02:57,910 -- 00:03:01,514
She is the Board of Libro Credit Union.
00:03:01,514 -- 00:03:04,183
And, she's held a number of senior public,
00:03:04,183 -- 00:03:07,420
sector positions and has been leading Libro’s evolution
00:03:07,420 -- 00:03:09,388
for, the past four years,
00:03:09,388 -- 00:03:12,658
since 2020, when she took a Chair role.
00:03:12,658 -- 00:03:13,893
Chris Dobrzanski,
00:03:13,893 -- 00:03:18,064
who is sitting to the right of Jacquie.
00:03:18,064 -- 00:03:20,633
He flew in, I think, this weekend.
00:03:20,633 -- 00:03:21,867
You flew in from Vancouver.
00:03:21,867 -- 00:03:24,203
So Chris lives in Vancouver,
00:03:24,203 -- 00:03:26,739
but our panel members could not.
00:03:26,739 -- 00:03:28,808
We were told that we could not do this remotely.
00:03:28,808 -- 00:03:30,643
People can join in remotely to listen,
00:03:30,643 -- 00:03:32,445
but we couldn't have panel members remotely.
00:03:32,445 -- 00:03:34,947
So Chris was kind enough to join us
00:03:34,947 -- 00:03:37,516
and fly here specifically for this panel.
00:03:37,516 -- 00:03:40,353
So thank you very much, Chris.
00:03:40,353 -- 00:03:43,723
Chris is the retired CEO of Citizens Bank of Canada,
00:03:43,723 -- 00:03:47,760
now known as the Vancity Community Investment Bank.
00:03:47,760 -- 00:03:50,363
Chris served for many decades.
00:03:50,363 -- 00:03:51,664
Chris, I won't say how many decades
00:03:51,664 -- 00:03:52,765
because nobody will believe it.
00:03:53,866 -- 00:03:55,401
On the,
00:03:55,401 -- 00:03:57,670
serving the Credit Unions in British Columbia,
00:03:57,670 -- 00:04:02,308
but also the Canadian, Canadian system, across the country.
00:04:02,308 -- 00:04:06,979
So, Chris has been a very devoted leader
00:04:06,979 -- 00:04:07,713
in the credit system.
00:04:07,713 -- 00:04:08,647
I've known him for many years.
00:04:08,647 -- 00:04:10,549
And I can attest to that, that,
00:04:10,549 -- 00:04:13,452
that he is incredibly devoted to Credit Unions.
00:04:13,452 -- 00:04:15,821
Michael Hatch.
00:04:15,821 -- 00:04:19,992
Jeff Guthrie initially was on our panel. Last minute,
00:04:19,992 -- 00:04:21,160
he throws this at Michael.
00:04:21,160 -- 00:04:23,262
He's like, Michael, you go
00:04:23,262 -- 00:04:25,731
because he had some travel plans that turned sideways.
00:04:25,731 -- 00:04:28,000
So Jeff wanted to be here, but he can't.
00:04:28,000 -- 00:04:29,935
Michael, thank you very much for last minute.
00:04:29,935 -- 00:04:33,405
It was literally last week when Jeff and I told you that,
00:04:33,405 -- 00:04:36,141
if you could please step in for Jeff.
00:04:36,141 -- 00:04:38,143
So, you should get a big bonus.
00:04:38,143 -- 00:04:39,712
It was my decision. I'd give it to you.
00:04:39,712 -- 00:04:41,547
So you got to talk to Jeff. Maybe I'll talk to Jeff.
00:04:41,547 -- 00:04:42,815
This session being recorded?
00:04:44,717 -- 00:04:49,722
So, Michael Hatch is the CCUA’s Vice President of Government...
00:04:49,755 -- 00:04:52,024
Government, Government Relations.
00:04:52,024 -- 00:04:55,227
And, thank you very much, Michael, for stepping in.
00:04:55,227 -- 00:04:58,230
And Lloyd Smith, I think most of you know Lloyd Smith.
00:04:58,230 -- 00:05:01,033
He is the CEO of FirstOntario Credit Union.
00:05:01,033 -- 00:05:03,569
He has been the CEO since 2019,
00:05:03,569 -- 00:05:05,471
but he has served as a leader
00:05:05,471 -- 00:05:07,873
in the credit system in Ontario for,
00:05:07,873 -- 00:05:09,375
hard to believe what 30 years.
00:05:09,375 -- 00:05:10,876
So, you look really good.
00:05:10,876 -- 00:05:12,578
So, thank you very much
00:05:12,578 -- 00:05:15,014
for all the panel members for joining us.
00:05:15,014 -- 00:05:19,852
And, so what we'll do, this session is not about FSRA
00:05:19,852 -- 00:05:22,554
or me presenting, but we want to put things in context
00:05:22,554 -- 00:05:25,224
and give you an understanding of why we have this session.
00:05:25,224 -- 00:05:26,225
But ultimately,
00:05:26,225 -- 00:05:27,660
I will stop talking at some point
00:05:27,660 -- 00:05:28,761
and we'll turn it over to our panel.
00:05:30,129 -- 00:05:33,699
So the financial services sector is always evolving
00:05:33,699 -- 00:05:35,701
and always has been evolving,
00:05:35,701 -- 00:05:38,237
which means that financial institutions must adapt
00:05:38,237 -- 00:05:41,673
and serve their members to remain competitive.
00:05:41,673 -- 00:05:45,711
The pace of change has and is expected to pick up
00:05:45,711 -- 00:05:47,746
over the next few years.
00:05:47,746 -- 00:05:49,915
And some of these change drivers,
00:05:49,915 -- 00:05:50,983
and we put five of them there.
00:05:50,983 -- 00:05:52,718
Now, this is not an exhaustive list,
00:05:52,718 -- 00:05:55,921
but there are some very important ones that are up there.
00:05:55,921 -- 00:05:59,925
These change drivers were discussed in this morning session.
00:05:59,925 -- 00:06:01,360
I know a few of these have already come up.
00:06:01,360 -- 00:06:02,428
Not all of them necessarily,
00:06:02,428 -- 00:06:04,096
but a few of them have come up this morning.
00:06:04,096 -- 00:06:06,165
So I'll just go through them pretty quickly.
00:06:06,165 -- 00:06:09,268
Big banks are becoming more efficient and effective at,
00:06:09,268 -- 00:06:11,570
member services,
00:06:11,570 -- 00:06:12,437
and Fintech’s
00:06:12,437 -- 00:06:13,839
and other entrants seek to take
00:06:13,839 -- 00:06:15,741
market share away from established players
00:06:15,741 -- 00:06:16,809
like Credit Unions.
00:06:17,843 -- 00:06:20,112
New technologies are redefining back
00:06:20,112 -- 00:06:23,348
into customer facing service delivery.
00:06:23,348 -- 00:06:27,219
Ontario's demographics is changing and evolving
00:06:27,219 -- 00:06:31,990
as we welcome immigrants and become increasingly urbanized.
00:06:31,990 -- 00:06:33,125
The manner in which Credit Unions
00:06:33,125 -- 00:06:37,062
collaborate on shared services is under pressure.
00:06:37,062 -- 00:06:39,998
And it is going to increase costs and complexity,
00:06:39,998 -- 00:06:41,900
which is a very important point.
00:06:41,900 -- 00:06:43,368
And we'll talk about scale
00:06:43,368 -- 00:06:45,971
and how Credit Unions can achieve that needed skill.
00:06:45,971 -- 00:06:48,674
And we'll take this to panel in a few minutes.
00:06:48,674 -- 00:06:52,344
And lastly, in the bottom-right corner there,
00:06:52,344 -- 00:06:55,013
consumer expectations regarding service
00:06:55,013 -- 00:06:59,351
levels and usability are, rapidly increasing.
00:06:59,351 -- 00:07:01,420
And so, these are some of the things
00:07:01,420 -- 00:07:06,425
that, that we'll be discussing as we go forward.
00:07:08,894 -- 00:07:12,597
So why has FSRA chosen this topic
00:07:12,597 -- 00:07:15,500
for today's breakout session?
00:07:15,500 -- 00:07:18,670
I'll start by assuring everybody, especially those that
00:07:18,670 -- 00:07:20,539
are either a member of management,
00:07:20,539 -- 00:07:23,241
at a Credit Union or Board Members.
00:07:23,241 -- 00:07:25,010
This is not a precursor
00:07:25,010 -- 00:07:27,045
to us issuing further Guidance
00:07:27,045 -- 00:07:30,248
or issuing a new rule or new regulations.
00:07:30,248 -- 00:07:32,417
That's not what is for.
00:07:32,417 -- 00:07:33,585
Strategic planning,
00:07:33,585 -- 00:07:35,454
which really is a big part
00:07:35,454 -- 00:07:36,822
of what we're going to talk about today
00:07:36,822 -- 00:07:38,490
is already a part of,
00:07:38,490 -- 00:07:39,825
and covered under the Sound Business
00:07:39,825 -- 00:07:41,293
and Financial Practices Rule,
00:07:41,293 -- 00:07:43,428
which has been in effect for a couple of years now.
00:07:43,428 -- 00:07:44,162
And all
00:07:44,162 -- 00:07:46,398
Credit Unions, regardless of size and complexity,
00:07:46,398 -- 00:07:47,499
are meeting the requirements
00:07:47,499 -- 00:07:48,100
of the Sound Business
00:07:48,100 -- 00:07:49,468
Financial Practices Rule.
00:07:49,468 -- 00:07:51,069
And the expectations and the requirements
00:07:51,069 -- 00:07:52,737
for strategic planning,
00:07:52,737 -- 00:07:54,306
including the involvement of the Boards
00:07:54,306 -- 00:07:55,841
and the accountability of the Boards,
00:07:55,841 -- 00:07:57,542
is already covered under the Sound
00:07:57,542 -- 00:07:59,111
Business and Financial Practices Rule.
00:08:00,345 -- 00:08:02,981
So some of the questions we ask are, what opportunities...
00:08:02,981 -- 00:08:06,918
what opportunities, do you see looking forward?
00:08:06,918 -- 00:08:07,853
How will your business model
00:08:07,853 -- 00:08:11,389
need to adapt in response to these external changes,
00:08:11,389 -- 00:08:14,092
some of which we talked about in the last slide?
00:08:14,092 -- 00:08:15,794
How will you mitigate,
00:08:15,794 -- 00:08:20,198
the related risks and some of the new and emerging risks?
00:08:20,198 -- 00:08:23,101
FSRA wants to emphasize the critical role
00:08:23,101 -- 00:08:27,005
that Boards play in strategic planning process.
00:08:27,005 -- 00:08:30,375
And Board members are ultimately like, I said, accountable
00:08:30,375 -- 00:08:33,545
for setting the Credit Union’s strategy and setting the direction.
00:08:33,545 -- 00:08:34,779
Now, of course, Senior Management
00:08:34,779 -- 00:08:36,248
have a very important role,
00:08:36,248 -- 00:08:38,250
but really, the accountability sets where the Boards
00:08:38,250 -- 00:08:39,351
and the direction that they give to
00:08:39,351 -- 00:08:41,319
Senior Management comes from the Boards.
00:08:41,319 -- 00:08:43,688
And so Board Members must be actively involved
00:08:43,688 -- 00:08:45,790
in providing guidance and direction to Management
00:08:45,790 -- 00:08:47,993
on your Credit Unions long term
00:08:47,993 -- 00:08:50,862
objectives and strategic direction.
00:08:50,862 -- 00:08:53,898
So what does this look like in practice?
00:08:57,168 -- 00:08:57,969
The following that
00:08:57,969 -- 00:09:00,672
we'll be discussing is just an example
00:09:00,672 -- 00:09:03,041
that we're going to use on these,
00:09:03,041 -- 00:09:04,376
external change factors
00:09:04,376 -- 00:09:06,277
that one of those five that we discussed
00:09:06,277 -- 00:09:09,714
in a couple of slides ago.
00:09:09,714 -- 00:09:13,385
So, this example that we're going to use is not necessarily
00:09:13,385 -- 00:09:15,086
the most important one,
00:09:15,086 -- 00:09:18,156
but it is certainly one of the important
00:09:18,156 -- 00:09:18,957
change factors
00:09:18,957 -- 00:09:22,527
that are driving these, changes and considerations.
00:09:22,527 -- 00:09:25,630
So, let's look at a representative,
00:09:25,630 -- 00:09:29,134
external force and its impact on the Credit Union sector.
00:09:29,134 -- 00:09:30,835
As a critical leader,
00:09:30,835 -- 00:09:32,070
how will you and your organization
00:09:32,070 -- 00:09:35,673
respond to long term changes in Ontario's demographics?
00:09:35,673 -- 00:09:36,374
And that's what
00:09:36,374 -- 00:09:38,943
we'll be discussing in the next couple of slides.
00:09:38,943 -- 00:09:40,178
This provides challenges
00:09:40,178 -- 00:09:43,047
and opportunities for Credit Unions.
00:09:43,047 -- 00:09:46,618
Depending on how you prepare for Ontario, that is quickly,
00:09:46,618 -- 00:09:47,986
changing and evolving.
00:09:51,222 -- 00:09:54,759
Okay, so the next three slides are about demographics.
00:09:54,759 -- 00:09:57,128
And again, just keep this in mind. This is an example.
00:09:57,128 -- 00:09:59,030
We're not using this because we're saying
00:09:59,030 -- 00:10:01,199
this is the thing that FSRA is focusing on.
00:10:01,199 -- 00:10:03,635
This is the thing that FSRA finds most important.
00:10:03,635 -- 00:10:07,172
It's just an example, context setting.
00:10:07,172 -- 00:10:08,973
Ontario is Canada's most populated
00:10:08,973 -- 00:10:12,944
province with over 15 million inhabitants,
00:10:12,944 -- 00:10:17,549
and by 2046, this number is going to surpass 21 million.
00:10:17,549 -- 00:10:19,417
Over 85% of this growth
00:10:19,417 -- 00:10:22,987
is expected to come from net migration.
00:10:22,987 -- 00:10:25,990
Each year, around a quarter million people,
00:10:25,990 -- 00:10:30,528
international immigrants will settle in Ontario.
00:10:30,528 -- 00:10:32,196
New Ontarians,
00:10:32,196 -- 00:10:33,998
generally come from,
00:10:33,998 -- 00:10:36,567
India, China, Philippines and the Middle East.
00:10:36,567 -- 00:10:38,236
You can see the kind of big bars
00:10:38,236 -- 00:10:42,407
in the upper right hand side. So the question to ask is,
00:10:43,641 -- 00:10:47,078
if you primarily serve an Ontario,
00:10:47,078 -- 00:10:49,247
ethno religious community,
00:10:49,247 -- 00:10:52,383
will you continue to have access to new immigrants
00:10:52,383 -- 00:10:54,452
and these new immigrant members?
00:10:54,452 -- 00:10:57,088
If you serve the general population,
00:10:57,088 -- 00:10:58,122
are you positioned to capture
00:10:58,122 -- 00:11:02,226
a share of these new Canadians that, that are coming in
00:11:02,226 -- 00:11:03,027
and these numbers
00:11:03,027 -- 00:11:08,032
are steadily increasing us as we go forward?
00:11:08,332 -- 00:11:12,870
Immigration also impacts geographic strategy,
00:11:12,870 -- 00:11:14,539
especially with the placement of branches
00:11:14,539 -- 00:11:16,774
for Credit Unions. For example.
00:11:16,774 -- 00:11:19,877
two thirds of new immigrants settled in the Greater Toronto
00:11:19,877 -- 00:11:21,779
Area, the GTA,
00:11:21,779 -- 00:11:26,484
but also Ottawa, Hamilton and the Kitchener, London, corridor
00:11:26,484 -- 00:11:28,686
are very popular areas as well.
00:11:28,686 -- 00:11:33,658
So by 2048, almost half of Ontarians will live in the GTA.
00:11:34,959 -- 00:11:36,994
and rural regions will not experience
00:11:36,994 -- 00:11:41,999
the same population growth that these areas will.
00:11:44,569 -- 00:11:45,436
As well,
00:11:45,436 -- 00:11:49,540
Ontario's population is going to continue to age
00:11:49,540 -- 00:11:50,541
over the next few years.
00:11:51,576 -- 00:11:54,812
a combination of longer life expectancy
00:11:54,812 -- 00:11:58,316
and lower birth rates means that the number of seniors
00:11:58,316 -- 00:11:58,983
in the province
00:11:58,983 -- 00:12:03,988
will continue to rise in both relative and real terms.
00:12:04,021 -- 00:12:06,557
The share of seniors in rural
00:12:06,557 -- 00:12:08,259
areas will become even more pronounced
00:12:08,259 -- 00:12:11,095
because there will be less immigration
00:12:11,095 -- 00:12:12,930
to boost the working age population.
00:12:12,930 -- 00:12:15,499
So that's another consideration.
00:12:15,499 -- 00:12:16,000
For Credit
00:12:16,000 -- 00:12:17,969
Unions, these trends are even more accelerated
00:12:17,969 -- 00:12:19,070
and more pronounced
00:12:19,070 -- 00:12:21,439
because the average age of a Credit Union member
00:12:21,439 -- 00:12:23,908
is somewhere in the 50s,
00:12:23,908 -- 00:12:26,877
whereas the average age of an Ontarian is about 40.
00:12:26,877 -- 00:12:30,548
So a big difference of more than a decade.
00:12:30,548 -- 00:12:31,415
As we noted earlier,
00:12:31,415 -- 00:12:34,952
demographics is just one external force.
00:12:34,952 -- 00:12:38,289
Competition is also evolving very rapidly.
00:12:38,289 -- 00:12:40,191
Consumer expectations are rising.
00:12:40,191 -- 00:12:43,594
Technology is changing everything.
00:12:43,594 -- 00:12:47,331
So as a resilient financial institution, a Credit Union,
00:12:49,266 -- 00:12:50,534
actively planning for these
00:12:50,534 -- 00:12:51,402
changes,
00:12:51,402 -- 00:12:53,537
seeking opportunities and mitigating
00:12:53,537 -- 00:12:56,107
related risks are very important.
00:12:56,107 -- 00:12:56,707
A resilient
00:12:56,707 -- 00:13:00,611
financial institution also anticipates change, and changes
00:13:00,611 -- 00:13:02,646
and positions itself
00:13:02,646 -- 00:13:06,450
to be very ready for these changes.
00:13:06,450 -- 00:13:08,185
Many of these changes are too large
00:13:08,185 -- 00:13:11,489
and out of the control of us and Credit Unions,
00:13:11,489 -- 00:13:13,257
and it would be very difficult,
00:13:13,257 -- 00:13:14,625
if not impossible for Credit Unions
00:13:14,625 -- 00:13:15,760
to manage this on their own.
00:13:15,760 -- 00:13:17,895
So they have to do this as a sector.
00:13:17,895 -- 00:13:20,998
And that's a big part of what we'll be talking about today.
00:13:20,998 -- 00:13:23,400
Sector solutions are required.
00:13:23,400 -- 00:13:26,370
Sector leadership is required.
00:13:26,370 -- 00:13:28,839
And that is why we have our panelists here today.
00:13:28,839 -- 00:13:31,809
And that's what they're going to be talking about.
00:13:31,809 -- 00:13:33,878
So this is my last slide.
00:13:33,878 -- 00:13:38,249
And then we'll go into the panel. So just to reiterate,
00:13:39,717 -- 00:13:43,921
why is long term planning and strategy a priority for FSRA?
00:13:43,921 -- 00:13:47,324
Mark, early on today talking about the FSRA objects
00:13:47,324 -- 00:13:49,126
of protecting consumers,
00:13:49,126 -- 00:13:51,295
of maintaining financial stability,
00:13:51,295 -- 00:13:54,331
but also one of our priorities is,
00:13:54,331 -- 00:13:56,467
to promote sustainable, competitive
00:13:56,467 -- 00:13:58,469
and innovative financial sectors.
00:13:58,469 -- 00:14:00,938
That's actually listed as one of our objects.
00:14:00,938 -- 00:14:01,539
And you can see that
00:14:01,539 -- 00:14:04,375
in our annual business planning, document
00:14:04,375 -- 00:14:07,645
and in our FSRA strategy.
00:14:07,645 -- 00:14:09,079
FSRA’s interest is in the long
00:14:09,079 -- 00:14:11,448
term viability of the Credit Union sector.
00:14:11,448 -- 00:14:14,351
And this interest is rooted in our objects.
00:14:14,351 -- 00:14:17,788
You know, as Mark alluded to earlier on today.
00:14:17,788 -- 00:14:20,824
FSRA believes that a strong,
00:14:20,824 -- 00:14:22,059
that strong sector leadership
00:14:22,059 -- 00:14:25,162
is required to address these challenges.
00:14:25,162 -- 00:14:29,233
and that's why we're here today, to hear from, our panelists
00:14:29,233 -- 00:14:30,968
and not from FSRA.
00:14:30,968 -- 00:14:35,172
So our panelists are very deeply rooted, very passionate,
00:14:35,172 -- 00:14:37,808
very involved in the Credit Union sector.
00:14:37,808 -- 00:14:42,780
And with that, we'll go to the panel discussion.
00:14:43,480 -- 00:14:47,918
And will...we leave the slides on or should we take it off?
00:14:47,918 -- 00:14:50,287
I'll leave it to whoever's managing this.
00:14:50,287 -- 00:14:51,488
All right. So I'm going to stay up here.
00:14:51,488 -- 00:14:53,390
And at this point I'm just going to ask some questions.
00:14:54,358 -- 00:14:55,492
We'll take this to panel.
00:14:55,492 -- 00:14:57,361
So,
00:14:57,361 -- 00:14:59,163
this question is
00:14:59,163 -- 00:15:01,198
directed at all of you and Lloyd,
00:15:01,198 -- 00:15:03,700
if we could start with you first, please.
00:15:03,700 -- 00:15:06,403
What do you see as big challenges and opportunities
00:15:06,403 -- 00:15:07,738
facing the Credit Unions
00:15:07,738 -- 00:15:09,940
and the Credit Union sector in the next 3 to 5 years?
00:15:09,940 -- 00:15:14,578
Thank you Mehrdad. Everybody hear me okay? Perfect.
00:15:14,578 -- 00:15:16,914
There's obviously a lot of challenges and opportunities
00:15:16,914 -- 00:15:19,550
that we've been facing for decades.
00:15:19,550 -- 00:15:23,020
I'll comment on, I think, you know, four common
00:15:23,020 -- 00:15:26,123
challenges and maybe 2 or 3 opportunities.
00:15:26,123 -- 00:15:27,424
The first one that I think we're
00:15:27,424 -- 00:15:30,727
all facing is rising operating costs,
00:15:30,727 -- 00:15:34,531
mainly in people and technology. In the people side,
00:15:34,531 -- 00:15:35,399
I would,
00:15:35,399 -- 00:15:36,099
look to,
00:15:36,099 -- 00:15:39,203
you know, what it takes to attract and retain talent.
00:15:39,203 -- 00:15:42,139
Talent is required to run the Credit Union.
00:15:42,139 -- 00:15:46,844
In technology, again, it's your core systems, infrastructure,
00:15:46,844 -- 00:15:48,512
supportive systems.
00:15:48,512 -- 00:15:49,580
Think cyber security.
00:15:49,580 -- 00:15:51,949
I think we all have to invest pretty heavily into
00:15:51,949 -- 00:15:53,016
cyber to support.
00:15:54,151 -- 00:15:57,888
The second one for me would be, compressed margins.
00:15:57,888 -- 00:16:00,891
And again, Mehrdad’s comments talk about the Fintech’s,
00:16:00,891 -- 00:16:03,727
the new entrants that are coming into our sector.
00:16:03,727 -- 00:16:05,262
They have lower cost structures.
00:16:05,262 -- 00:16:07,197
They don't have legacy systems.
00:16:07,197 -- 00:16:10,300
As a result, they can sort of operate on lower margins.
00:16:10,300 -- 00:16:11,935
And then just technology in general,
00:16:11,935 -- 00:16:14,738
I think, has suppressed margins.
00:16:14,738 -- 00:16:16,707
back 34 years ago,
00:16:16,707 -- 00:16:21,178
our margins were a lot larger than they are today.
00:16:21,178 -- 00:16:25,916
Third, for me would be growth and relevancy.
00:16:25,916 -- 00:16:29,453
Again, as a member or new members coming into our sector,
00:16:29,453 -- 00:16:32,356
they have lots of choices, Mehrdad’s comments,
00:16:32,356 -- 00:16:35,892
again, the average age of our members is aging
00:16:35,892 -- 00:16:37,794
well into the 50s.
00:16:37,794 -- 00:16:40,630
How are we being relevant to a younger demographic?
00:16:40,630 -- 00:16:44,668
How are we going to attract the younger demographic?
00:16:44,668 -- 00:16:47,838
I see that as a, you know, a pretty, pretty big change.
00:16:47,838 -- 00:16:49,072
Or a big challenge, rather.
00:16:49,072 -- 00:16:52,175
And then the banks, here in Ontario, the banks
00:16:52,175 -- 00:16:54,211
dominate the marketplace.
00:16:54,211 -- 00:16:57,981
93% plus or minus have a market share,
00:16:57,981 -- 00:16:59,683
dictated by the banks.
00:16:59,683 -- 00:17:00,617
And as a result,
00:17:00,617 -- 00:17:02,085
they have more resources
00:17:02,085 -- 00:17:03,987
and more access to capital
00:17:03,987 -- 00:17:05,622
to build systems and processes
00:17:05,622 -- 00:17:07,457
and procedures to serve their customers.
00:17:08,558 -- 00:17:10,660
Again, a good example of the
00:17:10,660 -- 00:17:13,497
slides was immigration here in Ontario
00:17:13,497 -- 00:17:16,032
and Canada, for that matter.
00:17:16,032 -- 00:17:18,068
The banks have done a good job
00:17:18,068 -- 00:17:18,802
at building out
00:17:18,802 -- 00:17:20,303
those onboarding processes
00:17:20,303 -- 00:17:24,674
for welcoming new Canadians to our country and to Ontario.
00:17:24,674 -- 00:17:26,710
So it's a challenge, but I do feel
00:17:26,710 -- 00:17:31,715
it's also an opportunity for us. On the opportunities side,
00:17:32,048 -- 00:17:33,149
I said there about three,
00:17:33,149 -- 00:17:36,720
but there's lots of opportunities for us to,
00:17:36,720 -- 00:17:39,890
embrace the Credit Union system in Ontario.
00:17:39,890 -- 00:17:43,360
First for me is expanding the revenue sources.
00:17:43,360 -- 00:17:46,997
For the longest time, 30, 40, 50 years ago,
00:17:46,997 -- 00:17:47,597
the Credit Unions
00:17:47,597 -- 00:17:50,200
operated on what I would call a margin model.
00:17:50,200 -- 00:17:51,234
And the banks today,
00:17:51,234 -- 00:17:54,137
about 50% of their revenue is in margin
00:17:54,137 -- 00:17:57,807
and 50% is in non-margin income sources.
00:17:57,807 -- 00:18:01,278
So compare that to Credit Unions.
00:18:01,278 -- 00:18:05,782
It's around 75 to 85% of our revenue is margin.
00:18:05,782 -- 00:18:07,150
I do think that we need to look
00:18:07,150 -- 00:18:09,486
for other sources of revenue
00:18:09,486 -- 00:18:13,590
to diversify and to continue to thrive in Ontario.
00:18:13,590 -- 00:18:16,059
Again, a couple examples of obviously
00:18:16,059 -- 00:18:18,061
most I think would have wealth,
00:18:18,061 -- 00:18:20,830
I think we need to expand the wealth offerings,
00:18:20,830 -- 00:18:23,733
foreign exchange, again, I think there's,
00:18:23,733 -- 00:18:25,535
you know, good income opportunities for,
00:18:26,536 -- 00:18:28,738
to our Credit Unions. And,
00:18:28,738 -- 00:18:31,808
alternative investments is something that,
00:18:31,808 -- 00:18:32,475
I would throw it
00:18:32,475 -- 00:18:34,511
there as a way to diversify
00:18:34,511 -- 00:18:38,415
our revenue away from non margin income.
00:18:38,415 -- 00:18:39,816
Another opportunity
00:18:39,816 -- 00:18:43,420
I think, that really exists for all of us is in the area,
00:18:43,420 -- 00:18:45,722
what I would call operational excellence.
00:18:45,722 -- 00:18:48,058
It's the how we do business.
00:18:48,058 -- 00:18:49,125
Remember to,
00:18:49,125 -- 00:18:50,493
employee to members
00:18:50,493 -- 00:18:52,262
and even front office to back office,
00:18:52,262 -- 00:18:54,130
employees to employees.
00:18:54,130 -- 00:18:56,800
We need to figure out how to make things easier
00:18:56,800 -- 00:18:59,169
for members to want to do business.
00:18:59,169 -- 00:19:00,603
So operational excellence for me
00:19:00,603 -- 00:19:04,240
means a consistent, error free and fast experience.
00:19:04,240 -- 00:19:06,443
What else would you want as a consumer?
00:19:06,443 -- 00:19:07,977
So again, if you can make it
00:19:07,977 -- 00:19:09,579
consistent, error free and fast,
00:19:09,579 -- 00:19:11,514
make it easier to do business with,
00:19:11,514 -- 00:19:15,985
I think, that's going to be a real opportunity for us to,
00:19:15,985 -- 00:19:18,354
gain market share in Ontario.
00:19:18,354 -- 00:19:18,955
And again,
00:19:18,955 -- 00:19:22,625
some of the technologies that we heard this morning around,
00:19:22,625 -- 00:19:24,194
machine learning and AI,
00:19:26,095 -- 00:19:27,096
again, robotics,
00:19:27,096 -- 00:19:27,997
process automation,
00:19:27,997 -- 00:19:28,898
using technology
00:19:28,898 -- 00:19:32,235
for automating processes, continuous improvement.
00:19:32,235 -- 00:19:36,172
All of that will basically make a much stronger,
00:19:36,172 -- 00:19:37,574
what I call operating engine
00:19:37,574 -- 00:19:39,809
for your Credit Union going forward.
00:19:39,809 -- 00:19:41,311
And then on the other side of the
00:19:41,311 -- 00:19:43,646
AI that we heard this morning,
00:19:43,646 -- 00:19:45,081
using those advanced technologies
00:19:45,081 -- 00:19:47,684
for enhancing your customer experience.
00:19:47,684 -- 00:19:48,818
So I'll stop there.
00:19:48,818 -- 00:19:50,853
But, you know, certainly there's a lot of challenges,
00:19:50,853 -- 00:19:52,522
but I also feel
00:19:52,522 -- 00:19:55,658
there's tremendous opportunities for Ontario Credit Unions
00:19:55,658 -- 00:19:58,027
in the years to come.
00:19:58,027 -- 00:19:58,595
Thank you, Lloyd.
00:19:58,595 -- 00:20:01,798
Jacquie, please.
00:20:01,798 -- 00:20:04,334
So I,
00:20:04,334 -- 00:20:06,202
I think I'm going to focus a little bit on
00:20:06,202 -- 00:20:09,639
what is going to become table stakes.
00:20:09,639 -- 00:20:13,676
And I think that's where our new owners
00:20:13,676 -- 00:20:18,181
have a very low tolerance for technological drag.
00:20:18,181 -- 00:20:22,318
Or for process drag and they've got choices as, as Lloyd said.
00:20:22,318 -- 00:20:25,688
So they're going to move to wherever they can get
00:20:25,688 -- 00:20:28,958
they, what they need earlier and quicker.
00:20:28,958 -- 00:20:32,528
And so that's going to become the
00:20:32,528 -- 00:20:35,698
the means for, for it's going to become table stakes.
00:20:35,698 -- 00:20:38,234
That's really in order to play the game.
00:20:38,234 -- 00:20:40,369
That's what you're going to need to do.
00:20:40,369 -- 00:20:41,738
And that's where AI and
00:20:41,738 -- 00:20:44,807
all those technologies produce
00:20:44,807 -- 00:20:47,310
a little bit of a hesitation.
00:20:47,310 -- 00:20:48,644
But the positive side
00:20:48,644 -- 00:20:52,748
is that we can really differentiate ourselves
00:20:52,748 -- 00:20:54,917
by what makes us different.
00:20:54,917 -- 00:20:59,922
So instead of trying to, say we're bank light,
00:20:59,922 -- 00:21:00,823
we're different,
00:21:00,823 -- 00:21:03,693
we can do all your financial services
00:21:03,693 -- 00:21:07,797
and we can offer some kind of addition.
00:21:07,797 -- 00:21:11,567
So whether that addition is like, Vancity’s had
00:21:11,567 -- 00:21:13,970
putting a stake in the environmental,
00:21:13,970 -- 00:21:18,975
well, world, which is incredibly attractive to people.
00:21:18,975 -- 00:21:23,980
Whether it's having a community of ethnic, that you,
00:21:24,280 -- 00:21:29,285
support, whatever it is, I think that's where the value is.
00:21:29,585 -- 00:21:33,756
It's not ‘value add’ is in a capital world, but ‘values add.’
00:21:33,756 -- 00:21:37,360
What are the values that we're adding to the AI?
00:21:37,360 -- 00:21:40,696
If AI is going to be able to do your transactions,
00:21:40,696 -- 00:21:42,098
then we're going to differentiate
00:21:42,098 -- 00:21:43,432
by being
00:21:43,432 -- 00:21:45,167
something more than that
00:21:45,167 -- 00:21:48,337
and bringing the soul back to our banking.
00:21:50,706 -- 00:21:51,274
Thank you, Jacquie.
00:21:51,274 -- 00:21:52,675
Chris.
00:21:52,675 -- 00:21:55,478
So my three are more short term.
00:21:55,478 -- 00:21:59,649
I'm not denying the need for a longer term vision,
00:21:59,649 -- 00:22:00,850
but I'd like to see that vision
00:22:00,850 -- 00:22:03,052
built on a very strong foundation.
00:22:03,052 -- 00:22:04,987
And so the first one is,
00:22:04,987 -- 00:22:08,491
some Credit Unions are going to have low earnings.
00:22:08,491 -- 00:22:10,826
Some may even publish losses.
00:22:10,826 -- 00:22:11,927
And I think it's really important
00:22:11,927 -- 00:22:12,628
to think
00:22:12,628 -- 00:22:14,196
how the system collectively
00:22:14,196 -- 00:22:17,533
will maintain depositor confidence
00:22:17,533 -- 00:22:22,505
as, media or individuals, pick up that story.
00:22:22,505 -- 00:22:24,106
The second one,
00:22:24,106 -- 00:22:26,409
which has been my experience, had been at Vancity
00:22:26,409 -- 00:22:29,512
and Vancity Community Investment Bank.
00:22:29,512 -- 00:22:34,316
Maintain your capital adequacy and a cushion.
00:22:34,316 -- 00:22:37,920
Without capital adequacy compliance,
00:22:37,920 -- 00:22:39,555
you might be thrown off your strategy.
00:22:39,555 -- 00:22:42,958
You might be thrown off your investment requirements.
00:22:42,958 -- 00:22:45,394
So that's my second one.
00:22:45,394 -- 00:22:48,531
And then,
00:22:48,531 -- 00:22:51,300
before some of you were born, I started a Credit Union
00:22:51,300 -- 00:22:53,068
at the University of British Columbia.
00:22:53,068 -- 00:22:57,540
It was the third time we tried it, it merged with teachers.
00:22:57,540 -- 00:22:59,975
That then merged with Vancity. And it's operating today.
00:23:01,210 -- 00:23:06,182
I strongly believe that Credit Unions in the history
00:23:06,749 -- 00:23:08,284
of our Credit Union movement,
00:23:08,284 -- 00:23:09,985
especially shown in the prairies
00:23:09,985 -- 00:23:11,954
during the Great Depression,
00:23:11,954 -- 00:23:13,756
that we have a unique opportunity
00:23:13,756 -- 00:23:16,258
to offer selected forbearance
00:23:16,258 -- 00:23:19,228
rather than quick foreclosure.
00:23:19,228 -- 00:23:21,697
And I think that's a huge opportunity
00:23:21,697 -- 00:23:24,066
and a huge responsibility.
00:23:24,066 -- 00:23:25,401
During COVID,
00:23:25,401 -- 00:23:28,270
the regulatory environment and Credit Unions
00:23:28,270 -- 00:23:30,739
provided all kinds of deferrals
00:23:30,739 -- 00:23:32,641
to enable physical health
00:23:32,641 -- 00:23:36,478
and let the community get to the other side.
00:23:36,478 -- 00:23:40,816
My own practice has been to let, through stagflation,
00:23:40,816 -- 00:23:42,518
get the members to the other side
00:23:42,518 -- 00:23:45,854
so the communities can get back on their feet.
00:23:45,854 -- 00:23:49,124
It's selected, but I think it's a huge opportunity
00:23:49,124 -- 00:23:51,193
and it's a great differentiator.
00:23:51,193 -- 00:23:53,896
And I'll talk about that a bit more.
00:23:53,896 -- 00:23:56,298
Chris, you said forbearance instead of foreclosure.
00:23:56,298 -- 00:23:59,768
Can you just provide a bit more detail on that, please?
00:23:59,768 -- 00:24:01,670
What do you mean by that? Well,
00:24:02,871 -- 00:24:04,973
I'll give you a specific case.
00:24:04,973 -- 00:24:05,708
During the great
00:24:05,708 -- 00:24:09,878
financial crisis, a family couldn't afford their home.
00:24:09,878 -- 00:24:11,780
So what's the point of throwing them out on the street
00:24:11,780 -- 00:24:13,082
and putting another house
00:24:13,082 -- 00:24:17,653
for sale on distress to lower the housing prices?
00:24:17,653 -- 00:24:19,521
What we did is, on our own account,
00:24:19,521 -- 00:24:24,526
wrote down the mortgage to the income of the family at 30%.
00:24:24,793 -- 00:24:26,562
You know what happened?
00:24:26,562 -- 00:24:30,032
The loyalty of that family is forever.
00:24:30,032 -- 00:24:33,502
The staff were engaged because of...
00:24:33,502 -- 00:24:36,972
we sent, not the sheriff, but a solution.
00:24:36,972 -- 00:24:40,609
And on average, the costs of providing forbearance
00:24:40,609 -- 00:24:42,277
relative to a lawyer,
00:24:42,277 -- 00:24:44,780
taking people through the courts for six months
00:24:44,780 -- 00:24:46,448
came out on top.
00:24:46,448 -- 00:24:49,384
It's not a blanket opportunity,
00:24:49,384 -- 00:24:53,121
but it's selected and it has huge impact.
00:24:53,121 -- 00:24:54,490
That's what I mean.
00:24:54,490 -- 00:24:55,958
Thank you, Chris. Michael. And,
00:24:55,958 -- 00:24:56,825
as I said,
00:24:56,825 -- 00:24:59,094
we offered that a few years ago
00:24:59,094 -- 00:25:01,964
with regulatory approval during COVID.
00:25:01,964 -- 00:25:03,532
So I'm not making stuff up.
00:25:05,934 -- 00:25:07,269
Yeah, that's a remarkable story, Chris.
00:25:07,269 -- 00:25:09,471
And, you know, that's a really good example of,
00:25:09,471 -- 00:25:10,739
you know, what can differentiate us
00:25:10,739 -- 00:25:14,910
from some of our larger federally regulated, competitors.
00:25:14,910 -- 00:25:15,911
I'm going to focus on
00:25:15,911 -- 00:25:20,916
more of the members/consumer angle, I guess.
00:25:21,650 -- 00:25:23,318
From where I sit in Ottawa.
00:25:23,318 -- 00:25:25,087
You know, we can call it open banking,
00:25:25,087 -- 00:25:28,056
call it consumer direct finance, call it whatever you want.
00:25:28,056 -- 00:25:29,858
But to me, it's,
00:25:29,858 -- 00:25:34,396
both, a threat and an opportunity at the same time.
00:25:34,396 -- 00:25:36,798
Just the growing consumer
00:25:36,798 -- 00:25:41,136
awareness of the simple reality of, you know, guess what?
00:25:41,136 -- 00:25:43,271
You can shop around for your financial services.
00:25:43,271 -- 00:25:44,840
You know, people shop around for their cars.
00:25:44,840 -- 00:25:46,174
They shop around for their cell phones.
00:25:46,174 -- 00:25:48,410
They shop around for their groceries.
00:25:48,410 -- 00:25:51,546
But there's been a history in Canada of just inertia
00:25:51,546 -- 00:25:55,684
or a humongous amounts of friction,
00:25:55,684 -- 00:25:58,687
at the idea of shifting financial institutions.
00:25:58,687 -- 00:25:59,621
And I personally am
00:25:59,621 -- 00:26:01,289
an example of the same old story
00:26:01,289 -- 00:26:03,058
we've heard a thousand times of,
00:26:04,059 -- 00:26:04,359
you know, when
00:26:04,359 -- 00:26:04,726
I started
00:26:04,726 -- 00:26:05,727
my professional career,
00:26:05,727 -- 00:26:06,928
I still had the same bank account
00:26:06,928 -- 00:26:09,364
that I opened when I was ten years old.
00:26:09,364 -- 00:26:12,200
And there's no real reason that, that should be the case,
00:26:12,200 -- 00:26:13,769
except for all of the,
00:26:13,769 -- 00:26:14,503
you know, the friction
00:26:14,503 -- 00:26:16,004
that people think exists
00:26:16,004 -- 00:26:18,373
when it comes to the notion of switching
00:26:18,373 -- 00:26:20,108
financial institutions.
00:26:20,108 -- 00:26:21,476
Because I think there used to be a lot of friction,
00:26:21,476 -- 00:26:22,577
but now it's so much easier.
00:26:22,577 -- 00:26:24,746
You can get an app, you can do it on your phone
00:26:24,746 -- 00:26:28,884
with a few clicks, putting your info.
00:26:28,884 -- 00:26:32,954
And quickly and easily and cheaply or without any cost
00:26:32,954 -- 00:26:34,956
at all. Switch financial institutions.
00:26:34,956 -- 00:26:37,559
So I think there's a growing consumer awareness of that.
00:26:37,559 -- 00:26:40,295
Again, you can call it open banking or whatever the
00:26:40,295 -- 00:26:41,763
the term you want to use.
00:26:43,165 -- 00:26:43,498
but that's
00:26:43,498 -- 00:26:45,100
obviously a threat and an opportunity
00:26:45,100 -- 00:26:49,137
because on the downside, it means that it's easier for,
00:26:49,137 -- 00:26:50,438
for us perhaps to lose members.
00:26:50,438 -- 00:26:51,139
But the upside is
00:26:51,139 -- 00:26:52,741
that it becomes easier for us
00:26:52,741 -- 00:26:56,411
to show our value proposition and, and to gain membership.
00:26:56,411 -- 00:26:58,480
So, you know, that trend is,
00:26:58,480 -- 00:27:00,949
I would say, in it's not quite in its infancy.
00:27:00,949 -- 00:27:03,051
It's probably in the puppy stage still, too,
00:27:03,051 -- 00:27:06,221
to use a metaphor, that was used this morning,
00:27:06,221 -- 00:27:09,758
referring to, to FSRA.
00:27:09,758 -- 00:27:11,059
But it's, it's going to,
00:27:11,059 -- 00:27:12,961
you know, it's going to continue more and more.
00:27:12,961 -- 00:27:14,429
And the more people,
00:27:14,429 -- 00:27:14,663
you know,
00:27:14,663 -- 00:27:15,797
realize that
00:27:15,797 -- 00:27:18,099
it is, in fact, seamless and easy
00:27:18,099 -- 00:27:20,869
to move around and shop around for financial services.
00:27:20,869 -- 00:27:24,205
It'll, it'll gather like a snowball going down a hill.
00:27:24,205 -- 00:27:24,973
The other,
00:27:26,074 -- 00:27:28,076
challenge again, from where I sit in my role
00:27:28,076 -- 00:27:30,312
running the lobbying and the and the government relations
00:27:30,312 -- 00:27:33,848
for the sector, both in Ottawa at the federal level and,
00:27:33,848 -- 00:27:36,685
across the country, at the provincial level.
00:27:36,685 -- 00:27:38,053
Is that,
00:27:38,053 -- 00:27:38,687
you know, there
00:27:38,687 -- 00:27:42,057
there are some divisions that exist in, in the sector
00:27:42,057 -- 00:27:44,526
largely, you know, between big and small,
00:27:44,526 -- 00:27:46,761
I would say, although that's,
00:27:46,761 -- 00:27:48,663
you know, a broad generalization
00:27:48,663 -- 00:27:51,966
just in terms of what the future state of the sector
00:27:51,966 -- 00:27:53,668
should look like.
00:27:53,668 -- 00:27:54,069
and, you know,
00:27:54,069 -- 00:27:56,538
I know that the regulator here and elsewhere,
00:27:56,538 -- 00:27:59,107
are neutral or agnostic or whatever
00:27:59,107 -- 00:28:03,511
the word is on consolidation and that's, as it should be.
00:28:03,511 -- 00:28:05,613
And, and we're the same way. Though,
00:28:05,613 -- 00:28:07,449
part of my organization's,
00:28:07,449 -- 00:28:10,485
objectives is to work with regulators and governments
00:28:10,485 -- 00:28:12,987
to make mergers and consolidation,
00:28:13,955 -- 00:28:15,490
easier and to bring down some of the,
00:28:15,490 -- 00:28:17,826
some of the obstacles that exist in those processes
00:28:17,826 -- 00:28:19,461
at both levels of government.
00:28:19,461 -- 00:28:21,729
But there is a divide
00:28:21,729 -- 00:28:24,199
amongst Credit Unions across Canada about,
00:28:24,199 -- 00:28:26,768
you know, perhaps what the future state of the sector
00:28:26,768 -- 00:28:31,039
should look like. And in my role and my team's role,
00:28:31,039 -- 00:28:32,640
when we're lobbying or talking
00:28:32,640 -- 00:28:34,209
to governments about an issue,
00:28:34,209 -- 00:28:35,577
we really do our best
00:28:35,577 -- 00:28:36,711
because there's no shortage of issues,
00:28:36,711 -- 00:28:38,279
there's no shortage of policy challenges
00:28:38,279 -- 00:28:40,181
no shortage of things that we could go
00:28:40,181 -- 00:28:41,049
and advocate
00:28:41,049 -- 00:28:43,017
on, either in Ottawa or Queen's
00:28:43,017 -- 00:28:46,387
Park or Victoria or Saint John's or wherever.
00:28:46,387 -- 00:28:48,356
but we really try to focus on those issues
00:28:48,356 -- 00:28:49,657
that bring everybody together.
00:28:49,657 -- 00:28:49,958
You know,
00:28:49,958 -- 00:28:51,292
when the feds step in and say, well,
00:28:51,292 -- 00:28:53,628
you can't use the word bank or banking in your
00:28:53,628 -- 00:28:55,330
in your marketing terminology,
00:28:55,330 -- 00:28:57,398
it's obvious that everybody is going to be
00:28:57,398 -- 00:28:59,467
on the same side of that in the sector.
00:28:59,467 -- 00:29:00,868
It's going to create consensus.
00:29:00,868 -- 00:29:02,971
Everybody's going to be rowing in the same position.
00:29:02,971 -- 00:29:05,607
So for us, in a way that, that was a crisis moment
00:29:05,607 -- 00:29:06,908
and there's been others since then.
00:29:08,376 -- 00:29:09,244
Um, it's obvious
00:29:09,244 -- 00:29:10,111
what the direction is
00:29:10,111 -- 00:29:12,080
and that there's consensus in the sector,
00:29:12,080 -- 00:29:14,616
but that's really the exception.
00:29:14,616 -- 00:29:17,018
On a lot of issues that are of importance to the sector,
00:29:17,018 -- 00:29:20,989
there's, you know, an emerging sort of division,
00:29:20,989 -- 00:29:22,657
not along regional lines necessarily,
00:29:22,657 -- 00:29:26,194
but more along sort of big, big vs. small, I would say.
00:29:26,194 -- 00:29:28,296
I guess I'll stop there and hand it back to Mehrdad.
00:29:28,296 -- 00:29:29,897
So, Michael, you talked about open
00:29:29,897 -- 00:29:32,033
banking and digital solutions.
00:29:32,033 -- 00:29:34,969
And in an earlier conversation, I think it was last week.
00:29:34,969 -- 00:29:36,437
And I've written this down as a note,
00:29:36,437 -- 00:29:37,572
you said, “younger
00:29:37,572 -- 00:29:40,274
people are aligned with Credit Union ethos,” which I agree.
00:29:40,274 -- 00:29:42,677
I have three daughters in her 20s. They are.
00:29:42,677 -- 00:29:45,680
And yet none of them do their banking with Credit Unions.
00:29:45,680 -- 00:29:46,547
So you said, “younger people
00:29:46,547 -- 00:29:47,915
who are aligned with Credit Union ethos,
00:29:47,915 -- 00:29:48,783
but they're turned off
00:29:48,783 -- 00:29:51,219
by the state of the digital solution.”
00:29:51,219 -- 00:29:52,019
What did you mean by that?
00:29:53,488 -- 00:29:56,557
Well, I mean, I feel that's, that's fairly self-explanatory.
00:29:56,557 -- 00:29:57,692
Like, the
00:29:57,692 -- 00:29:59,260
everybody knows in every conference
00:29:59,260 -- 00:30:01,229
that I've ever attended,
00:30:01,229 -- 00:30:03,197
in the sector has spoken about the challenging
00:30:03,197 -- 00:30:04,866
demographics of the industry.
00:30:04,866 -- 00:30:06,067
And I think you said it was,
00:30:06,067 -- 00:30:07,535
you know, 57 or whatever
00:30:07,535 -- 00:30:09,904
the average ages of a Credit Union member across Canada
00:30:09,904 -- 00:30:13,141
versus a median age in the low 40s for the population
00:30:13,141 -- 00:30:15,443
as a whole. That's an obvious challenge.
00:30:15,443 -- 00:30:18,045
And there is an obvious value proposition
00:30:18,045 -- 00:30:20,281
when you look at, again, the word I used was ethos.
00:30:20,281 -- 00:30:23,951
The, the, the ethos of, of, of, of the movement.
00:30:23,951 -- 00:30:24,752
You know,
00:30:24,752 -- 00:30:27,588
no other provider of financial services in Canada can,
00:30:27,588 -- 00:30:27,989
you know,
00:30:27,989 -- 00:30:29,557
reliably call itself a movement
00:30:29,557 -- 00:30:30,625
as the Credit Union
00:30:30,625 -- 00:30:33,427
Movement/sector industry often does,
00:30:33,427 -- 00:30:36,230
because it does have that co-operative history and ethos.
00:30:36,230 -- 00:30:39,333
We still have to compete, obviously, and, and, and,
00:30:39,333 -- 00:30:40,501
earn margins.
00:30:40,501 -- 00:30:42,770
But we do have a really compelling story
00:30:42,770 -- 00:30:45,373
to tell, particularly, I think, to young people.
00:30:45,373 -- 00:30:48,509
As a person who was young not that long ago.
00:30:48,509 -- 00:30:50,878
I'm sort of in between now, young and old.
00:30:50,878 -- 00:30:52,880
I think that, that opportunity is there.
00:30:52,880 -- 00:30:58,319
But of course, you got to have a digital offering that is,
00:30:58,519 -- 00:30:59,086
you know, that
00:30:59,086 -- 00:31:01,188
that my eight-year old daughter
00:31:01,188 -- 00:31:02,390
can navigate with ease,
00:31:02,390 -- 00:31:04,859
which is increasingly the norm across the sector.
00:31:06,060 -- 00:31:06,427
Okay.
00:31:06,427 -- 00:31:06,761
Well, one of
00:31:06,761 -- 00:31:08,696
the very big issues that need to be,
00:31:08,696 -- 00:31:11,866
needs to be resolved and solved for.
00:31:11,866 -- 00:31:13,501
Chris, I'm going to turn to you.
00:31:13,501 -- 00:31:15,469
Start this for the next question, please.
00:31:15,469 -- 00:31:17,872
How can Credit Unions leverage co-operative principles
00:31:17,872 -- 00:31:20,875
and social values for long term competitive advantage?
00:31:20,875 -- 00:31:23,010
Yeah, so let me tell you a little bit
00:31:23,010 -- 00:31:26,380
about the Vancity model.
00:31:26,380 -- 00:31:31,652
And there are a number of realities that we always face.
00:31:32,553 -- 00:31:35,089
The community need,
00:31:35,089 -- 00:31:39,427
is not necessarily a conventional banking solution.
00:31:39,427 -- 00:31:40,928
Take a housing co-op.
00:31:40,928 -- 00:31:44,598
How does it get the down-payment.
00:31:44,598 -- 00:31:47,635
Does it not need some kind of interest reserve in case
00:31:47,635 -- 00:31:49,837
some of the members are unemployed
00:31:49,837 -- 00:31:52,173
or have cashflow difficulties?
00:31:52,173 -- 00:31:55,042
So to structure a community solution,
00:31:55,042 -- 00:31:58,012
of course, the Credit Union steps up.
00:31:58,012 -- 00:32:02,216
But we had Vancity Capital that provided subordinated
00:32:02,216 -- 00:32:03,517
debt and patient capital.
00:32:04,518 -- 00:32:05,653
And we also had Vancity
00:32:05,653 -- 00:32:06,887
Foundation
00:32:06,887 -- 00:32:11,459
that would create a grant to not-for-profit or a co-op.
00:32:11,459 -- 00:32:16,463
So you could what I'm trying to paint is, the community need
00:32:16,497 -- 00:32:21,302
is very uniquely positioned as an opportunity
00:32:21,302 -- 00:32:26,173
at this point in time, demographically, politically
00:32:26,173 -- 00:32:29,443
and generationally.
00:32:29,443 -- 00:32:32,379
But the solution is not through a regulated deposit
00:32:32,379 -- 00:32:35,649
financial institution alone.
00:32:35,649 -- 00:32:39,887
In my work, you may have seen my badge with some of you.
00:32:39,887 -- 00:32:42,289
I am the Chair of Community Forward Fund,
00:32:42,289 -- 00:32:43,924
and we have the privilege
00:32:43,924 -- 00:32:48,929
of, managing the portfolio for the Canadian Cooperative
00:32:49,129 -- 00:32:51,432
Investment Fund.
00:32:51,432 -- 00:32:53,601
And so the Canadian Cooperative Investment
00:32:53,601 -- 00:32:56,637
Fund provides patient capital.
00:32:56,637 -- 00:32:57,738
The Credit Union provides
00:32:57,738 -- 00:33:02,209
the conventional loan, often with CMHC Insurance,
00:33:02,209 -- 00:33:03,677
with zero capital.
00:33:03,677 -- 00:33:06,880
And you have an efficient model.
00:33:06,880 -- 00:33:10,617
And the partnership increasingly has the government
00:33:10,617 -- 00:33:13,754
and CMHC saying, I'm looking for those partners.
00:33:13,754 -- 00:33:16,156
I'm looking for those partners in community,
00:33:16,156 -- 00:33:18,192
and then I'm looking for a financial institution
00:33:18,192 -- 00:33:23,197
that's not afraid of funding a co-op or a women's shelter,
00:33:23,230 -- 00:33:25,032
because the banks are afraid of catching that,
00:33:25,032 -- 00:33:28,635
because the publicity of foreclosure is their mentality.
00:33:28,635 -- 00:33:30,070
And oh, no, we can't let them do that.
00:33:31,171 -- 00:33:32,873
What I will say about
00:33:32,873 -- 00:33:35,175
Vancity is that we found a niche, maybe
00:33:35,175 -- 00:33:37,177
20 to 30% of the population,
00:33:37,177 -- 00:33:40,547
which is sufficient for scale and impact,
00:33:40,547 -- 00:33:43,450
but to the discipline of the long term strategy.
00:33:43,450 -- 00:33:47,287
This solidifies the brand and the value proposition,
00:33:47,287 -- 00:33:50,591
but it's not sufficient for financial solvency.
00:33:50,591 -- 00:33:52,493
You still need the other work
00:33:52,493 -- 00:33:55,129
that Lloyd talked about on, on margin
00:33:55,129 -- 00:33:57,698
and cost and attraction.
00:33:57,698 -- 00:33:59,433
So I think we're in the sweet spot
00:33:59,433 -- 00:34:02,469
of the opportunity through partnership.
00:34:02,469 -- 00:34:07,441
And I’ve named some of the players that Credit Unions can, you know.
00:34:08,876 -- 00:34:09,109
Thank you,
00:34:09,109 -- 00:34:11,111
Chris. So, Lloyd, as an operator
00:34:11,111 -- 00:34:14,348
who's operating in the Ontario system right now,
00:34:14,348 -- 00:34:18,352
to Chris's point on community and social values.
00:34:18,352 -- 00:34:20,554
What's your position on this?
00:34:20,554 -- 00:34:26,593
Yeah, I mean, I think, you go back to 80 years ago or so,
00:34:27,160 -- 00:34:28,262
people helping people.
00:34:29,663 -- 00:34:31,365
I think there's,
00:34:31,365 -- 00:34:33,200
lots of those co-operative,
00:34:33,200 -- 00:34:36,904
principles and values that we have where we can,
00:34:36,904 -- 00:34:37,337
you know, do
00:34:37,337 -- 00:34:40,040
well for our community and,
00:34:40,040 -- 00:34:43,443
and still be very viable and thrive in a market.
00:34:43,443 -- 00:34:44,978
At FirstOntario,
00:34:44,978 -- 00:34:49,149
we did a few interesting projects in support of community.
00:34:49,149 -- 00:34:50,050
One was we,
00:34:50,050 -- 00:34:52,719
you know, co-developed a nine-story apartment building,
00:34:52,719 -- 00:34:56,089
127 units, it was a big endeavor.
00:34:56,089 -- 00:34:57,157
We worked,
00:34:57,157 -- 00:35:02,129
very supportive with, the city and the, the Niagara region,
00:35:02,195 -- 00:35:03,430
giving it basically
00:35:03,430 -- 00:35:04,598
some certain designations
00:35:04,598 -- 00:35:06,700
that allowed us to create these units.
00:35:06,700 -- 00:35:08,935
As Chris said, you've got to look at the stock.
00:35:08,935 -- 00:35:12,572
And, we also had, support from,
00:35:12,572 -- 00:35:15,575
CMHC, who ultimately, is carrying,
00:35:15,575 -- 00:35:17,577
we have a COI on that mortgage.
00:35:17,577 -- 00:35:19,446
But, you know, again, that was a good example
00:35:19,446 -- 00:35:21,815
where we're trying to be part of the solution.
00:35:21,815 -- 00:35:23,817
Housing is, is obviously,
00:35:24,785 -- 00:35:26,853
terrible in all our communities.
00:35:26,853 -- 00:35:29,589
And so this is a particular, project
00:35:29,589 -- 00:35:32,225
that we're very proud of, the work we did,
00:35:32,225 -- 00:35:34,061
obviously we can't solve all the problems,
00:35:34,061 -- 00:35:36,029
but we just want to lead by example.
00:35:36,029 -- 00:35:38,565
A couple other small ones, I'll mention,
00:35:38,565 -- 00:35:40,734
around food insecurity.
00:35:40,734 -- 00:35:43,837
We try to support, various food banks, and their work,
00:35:43,837 -- 00:35:45,439
the good work that they're doing.
00:35:45,439 -- 00:35:48,608
Both in terms of, work in kind.
00:35:48,608 -- 00:35:50,444
Myself and other of our employees
00:35:50,444 -- 00:35:52,846
go out to various food banks and donate our time.
00:35:52,846 -- 00:35:54,981
We call it Blue Wave.
00:35:54,981 -- 00:35:57,284
But we also provide a monetary cheque
00:35:57,284 -- 00:35:59,286
to support those organizations.
00:35:59,286 -- 00:36:00,587
And the last one, I'll leave you with it,
00:36:00,587 -- 00:36:02,489
which is, one that is, it's
00:36:02,489 -- 00:36:04,958
a combination again of Blue Wave,
00:36:04,958 -- 00:36:07,160
and obviously providing, money.
00:36:07,160 -- 00:36:10,463
But we, we, we provide $250,000 a year,
00:36:10,463 -- 00:36:14,467
and that money goes to various, grade schools,
00:36:14,467 -- 00:36:16,803
and they use that money to buy food.
00:36:16,803 -- 00:36:19,005
And then again, our Blue Wave of volunteers
00:36:19,005 -- 00:36:19,506
go out
00:36:19,506 -- 00:36:23,109
and we work, sort of side by side with the teachers,
00:36:23,109 -- 00:36:25,912
and we get to, you know, make breakfast for the kids.
00:36:25,912 -- 00:36:28,148
It's an absolute blast that melts your heart.
00:36:28,148 -- 00:36:30,350
But you realize that obviously,
00:36:30,350 -- 00:36:31,618
that goes back to those
00:36:31,618 -- 00:36:32,052
what I call
00:36:32,052 -- 00:36:34,454
Credit union principles or people helping people.
00:36:34,454 -- 00:36:36,756
I do think that we have to, act
00:36:36,756 -- 00:36:38,858
and behave and work as a community.
00:36:38,858 -- 00:36:40,427
And that's a good example, again,
00:36:40,427 -- 00:36:42,095
of what we're doing for the small kids
00:36:42,095 -- 00:36:44,297
that, you know, are coming to school hungry.
00:36:44,297 -- 00:36:46,599
We're able to provide food for their,
00:36:46,599 -- 00:36:48,234
you know, in their stomach so they can learn.
00:36:49,502 -- 00:36:51,638
Can I just jump in real quick Mehrdad. Of course.
00:36:51,638 -- 00:36:54,975
Just to add to some of that. You know, the
00:36:54,975 -- 00:36:57,077
the banks are obviously big and
00:36:57,077 -- 00:36:59,479
and rich and well-resourced and everything else,
00:36:59,479 -- 00:37:02,048
but they're also giant, bureaucracies.
00:37:02,048 -- 00:37:03,416
They're not at all nimble.
00:37:03,416 -- 00:37:07,053
And more importantly, they don't, as we all know, exactly
00:37:07,053 -- 00:37:10,523
enjoy a surplus of public regard,
00:37:10,523 -- 00:37:12,292
if I can put it in such terms.
00:37:12,292 -- 00:37:16,896
You know, they're kind of seen as a necessary evil. And,
00:37:16,896 -- 00:37:19,299
my, my role, you know, it's national in scope.
00:37:19,299 -- 00:37:20,800
I have a sort of a view of what's,
00:37:20,800 -- 00:37:22,135
what's going on across country
00:37:22,135 -- 00:37:24,237
and in different jurisdictions.
00:37:24,237 -- 00:37:25,739
And, you know, Ontario, of course, is
00:37:25,739 -- 00:37:26,940
is the biggest province,
00:37:26,940 -- 00:37:30,210
the biggest share of, of our country's GDP.
00:37:30,210 -- 00:37:32,045
But, in the Credit Union sector,
00:37:32,045 -- 00:37:34,180
it's one of the lowest market share provinces.
00:37:34,180 -- 00:37:35,348
So I'm not sure why that is.
00:37:35,348 -- 00:37:37,984
That's a function of history and other, other factors.
00:37:39,085 -- 00:37:41,020
But in this province, there's, there's
00:37:41,020 -- 00:37:42,922
there's tremendous upside.
00:37:42,922 -- 00:37:43,189
You know,
00:37:43,189 -- 00:37:45,325
if we could just get a quarter of the way
00:37:45,325 -- 00:37:46,793
between where we are in Ontario
00:37:46,793 -- 00:37:48,461
to what the market share is in some,
00:37:48,461 -- 00:37:50,630
some other provinces of Canada,
00:37:50,630 -- 00:37:52,398
that's, that would be like bringing
00:37:52,398 -- 00:37:54,400
on hundreds of thousands of, of new members.
00:37:54,400 -- 00:37:57,370
And I know that there's no magic wand,
00:37:57,370 -- 00:37:58,938
that, that'll do that.
00:37:58,938 -- 00:38:01,407
But there is a tremendous upside in this province,
00:38:01,407 -- 00:38:02,709
I would say, just because,
00:38:02,709 -- 00:38:03,309
you know, frankly,
00:38:03,309 -- 00:38:04,744
our market share is lower here
00:38:04,744 -- 00:38:08,014
than in other parts of the country.
00:38:08,014 -- 00:38:09,082
Thanks, Michael. So Lloyd,
00:38:09,082 -- 00:38:11,684
I want to continue from where you left off.
00:38:11,684 -- 00:38:15,355
And tying this back to the challenges and opportunities.
00:38:15,355 -- 00:38:17,757
and I've heard you say, you know, Credit Unions,
00:38:17,757 -- 00:38:20,760
especially now need to, as they should,
00:38:20,760 -- 00:38:22,695
and they have in the past, they need to hold hands.
00:38:22,695 -- 00:38:27,033
So how can Credit Unions work together more effectively?
00:38:27,033 -- 00:38:28,134
Yeah. I think,
00:38:29,435 -- 00:38:31,838
again, one of the things that,
00:38:31,838 -- 00:38:33,239
we're, I'll say
00:38:33,239 -- 00:38:34,907
talking about at FirstOntario
00:38:34,907 -- 00:38:36,042
and one that we're,
00:38:36,042 -- 00:38:38,044
you know, certainly very happy to talk to other Credit Unions
00:38:38,044 -- 00:38:40,279
in the province is what we're calling,
00:38:40,279 -- 00:38:41,948
a Shared Service Model.
00:38:41,948 -- 00:38:43,983
And really, a Shared Service Model is about,
00:38:43,983 -- 00:38:45,885
you know, one Credit Union,
00:38:45,885 -- 00:38:47,887
sharing in what they're doing
00:38:47,887 -- 00:38:49,689
could be, on an expense
00:38:49,689 -- 00:38:51,524
reduction side or expense management
00:38:51,524 -- 00:38:54,894
or could be on a revenue, opportunity side.
00:38:54,894 -- 00:38:56,529
And, so that's something
00:38:56,529 -- 00:38:58,965
that, again, I think, where Credit Unions,
00:38:58,965 -- 00:39:01,134
a lot of Credit Unions are doing amazing work.
00:39:01,134 -- 00:39:03,069
And so I think the, the whole idea
00:39:03,069 -- 00:39:05,004
of working together and collaborating
00:39:05,004 -- 00:39:06,339
on some kind of Shared Service
00:39:06,339 -- 00:39:09,942
Model is something that I think we all need to embrace.
00:39:09,942 -- 00:39:13,246
I was talking, at the break there with Rob Patterson and,
00:39:13,246 -- 00:39:14,080
you know, again,
00:39:15,081 -- 00:39:15,882
we're not competitors.
00:39:15,882 -- 00:39:18,284
We're all part of this, wonderful sector
00:39:18,284 -- 00:39:18,951
and the
00:39:18,951 -- 00:39:20,653
Credit Union sector and again, working together,
00:39:20,653 -- 00:39:21,554
I do think to
00:39:21,554 -- 00:39:23,990
what Michael said, is that we can really dominate,
00:39:23,990 -- 00:39:26,859
or at least have a much, much bigger market share.
00:39:26,859 -- 00:39:30,329
Another area, again, where I think that,
00:39:30,329 -- 00:39:32,465
you know, Credit Unions can sort of work,
00:39:32,465 -- 00:39:34,267
I'll say, work better together.
00:39:34,267 -- 00:39:35,201
If you look in the U.S.,
00:39:35,201 -- 00:39:36,969
they have what I would call a CUSO,
00:39:36,969 -- 00:39:38,738
or a Credit Union Service Organization.
00:39:38,738 -- 00:39:41,707
I don't think we really have any good examples of that
00:39:41,707 -- 00:39:44,210
in Ontario or in Canada. If there are, I apologize.
00:39:44,210 -- 00:39:45,578
But the one that I would say
00:39:45,578 -- 00:39:48,648
maybe is the closest to that might be League Data,
00:39:48,648 -- 00:39:49,749
which is in the Maritimes,
00:39:49,749 -- 00:39:51,450
where they basically run,
00:39:51,450 -- 00:39:55,154
banking systems for 40 of the maritime Credit Unions.
00:39:55,154 -- 00:39:55,788
And so,
00:39:55,788 -- 00:39:56,255
you know, it
00:39:56,255 -- 00:39:58,257
just sort of dawns on me that there's opportunities,
00:39:58,257 -- 00:40:00,826
I think, for CUSO like organizations.
00:40:00,826 -- 00:40:02,528
And I'll give you one sort of idea
00:40:02,528 -- 00:40:04,130
that's sort of germinating my head is
00:40:04,130 -- 00:40:04,630
the banks
00:40:04,630 -- 00:40:06,165
have basically been doing back office
00:40:06,165 -- 00:40:09,669
processing through SIM core and inter i3 for decades.
00:40:09,669 -- 00:40:12,572
And again, they compete like crazy on street corners,
00:40:12,572 -- 00:40:13,439
but yet
00:40:13,439 -- 00:40:15,575
they basically have these back office companies
00:40:15,575 -- 00:40:18,344
that are obviously just processing and fulfillment.
00:40:18,344 -- 00:40:19,612
And they're good with that.
00:40:20,680 -- 00:40:25,451
Another idea that I keep wondering about is
00:40:25,451 -- 00:40:30,456
again, with I guess, with support of CCUA is, why we can't maybe host,
00:40:30,456 -- 00:40:31,324
some webinars
00:40:31,324 -- 00:40:33,459
and we have a sponsor Credit Union
00:40:33,459 -- 00:40:36,429
that basically is taking us all through,
00:40:36,429 -- 00:40:38,698
a use, study, or a case study
00:40:38,698 -- 00:40:40,299
on something particular
00:40:40,299 -- 00:40:41,133
that they've done in terms
00:40:41,133 -- 00:40:44,070
of solving a challenge or solving an opportunity.
00:40:44,070 -- 00:40:45,404
I think it would be,
00:40:45,404 -- 00:40:46,706
you know, very beneficial for us
00:40:46,706 -- 00:40:48,607
to all sort of learn from that and of course,
00:40:48,607 -- 00:40:49,942
then have it maybe written out.
00:40:49,942 -- 00:40:51,077
So there's a repository
00:40:51,077 -- 00:40:54,180
where you can access it on your own time.
00:40:54,180 -- 00:40:56,682
And the last thing I'll leave you with is,
00:40:56,682 -- 00:40:59,318
in Ontario, years ago,
00:40:59,318 -- 00:41:01,420
we had what was called the ALOCU.
00:41:01,420 -- 00:41:03,522
And it's the Alliance of Large
00:41:03,522 -- 00:41:06,525
Ontario Credit Unions...is the top ten.
00:41:06,525 -- 00:41:09,161
It's since somewhat, disbanded a little bit,
00:41:09,161 -- 00:41:11,397
but a few of my colleagues,
00:41:11,397 -- 00:41:13,866
were away last week, and we were talking about,
00:41:13,866 -- 00:41:15,167
I call it reconstituting.
00:41:15,167 -- 00:41:16,335
A repurposing ALOCU.
00:41:16,335 -- 00:41:18,871
And the intent of ALOCU for me
00:41:18,871 -- 00:41:21,707
is really about sort of addressing,
00:41:21,707 -- 00:41:23,609
issues or challenges or opportunities
00:41:23,609 -- 00:41:25,311
that are common to all of us.
00:41:25,311 -- 00:41:26,712
And with that, again,
00:41:26,712 -- 00:41:28,881
what we were talking about last week is,
00:41:28,881 -- 00:41:31,250
you know, certainly we should be looking to,
00:41:31,250 -- 00:41:32,051
communicate down
00:41:32,051 -- 00:41:34,720
to all Credit Unions on the work that we're doing.
00:41:34,720 -- 00:41:37,089
So I know that a few of us were talking last week,
00:41:37,089 -- 00:41:38,858
and I hope that we can actually bring
00:41:38,858 -- 00:41:41,126
the ALOCU back to life, I'll say.
00:41:41,126 -- 00:41:42,728
But certainly what comes out of that,
00:41:42,728 -- 00:41:45,664
make sure that we're sharing all of that knowledge,
00:41:45,664 -- 00:41:46,265
to everyone.
00:41:46,265 -- 00:41:49,101
So what I leave you with is for me,
00:41:49,101 -- 00:41:51,503
I think going forward over the next 3 to 5 years,
00:41:51,503 -- 00:41:54,173
it's really important that we information share
00:41:54,173 -- 00:41:57,243
that we obviously consider these service,
00:41:57,243 -- 00:41:59,845
or I guess, you know, Shared Service Models, ways
00:41:59,845 -- 00:42:01,547
in which we can collaborate and work together.
00:42:03,582 -- 00:42:04,083
Thanks, Lloyd.
00:42:04,083 -- 00:42:07,586
So, Michael, given that we've,
00:42:07,586 -- 00:42:09,822
talked about some of these problems
00:42:09,822 -- 00:42:10,956
each individual creditor
00:42:10,956 -- 00:42:12,458
may not be able to address on their own.
00:42:12,458 -- 00:42:17,463
And you through CCUA have visibility into many Credit Unions
00:42:17,763 -- 00:42:21,967
and all the Credit Unions definitely in Ontario.
00:42:21,967 -- 00:42:23,469
How do you think Credit Unions can work
00:42:23,469 -- 00:42:24,436
more effectively to address
00:42:24,436 -- 00:42:25,838
some of these challenges and opportunities?
00:42:25,838 -- 00:42:27,506
And can you choose those Credit
00:42:27,506 -- 00:42:29,108
Union Service organizations?
00:42:29,108 -- 00:42:31,977
Is there any agreement that occupies unions?
00:42:31,977 -- 00:42:32,978
We do we need some?
00:42:32,978 -- 00:42:35,514
Can we employ ones that are already existing?
00:42:35,514 -- 00:42:35,814
What's your
00:42:35,814 -- 00:42:37,750
perspective? Yeah, I don't think so.
00:42:37,750 -- 00:42:42,721
I mean, my earlier remarks spoke to, you know,
00:42:42,955 -- 00:42:45,190
some divisions that are sort of emerging,
00:42:45,190 -- 00:42:46,792
across the sector with regards
00:42:46,792 -- 00:42:47,893
to some of these major issues.
00:42:47,893 -- 00:42:49,261
You know, board governance is one of them.
00:42:49,261 -- 00:42:51,463
It's obviously a key issue,
00:42:51,463 -- 00:42:54,333
that regulators across the country are looking at.
00:42:54,333 -- 00:42:56,869
CCUA has, you know, we, we established partnership
00:42:56,869 -- 00:42:58,370
with ICD to, to
00:42:58,370 -- 00:43:00,005
to bring that rigor of,
00:43:00,005 -- 00:43:04,343
of, of Board Director education to the sector.
00:43:04,343 -- 00:43:06,311
But there's a wide degree of
00:43:06,311 -- 00:43:07,780
or a wide variety of views
00:43:07,780 -- 00:43:09,648
across the sector in terms of, of
00:43:09,648 -- 00:43:11,216
of what that should look like.
00:43:11,216 -- 00:43:12,184
And, you know,
00:43:12,184 -- 00:43:14,820
you also have to deal with the reality of on the ground
00:43:14,820 -- 00:43:16,755
in, you know, small communities.
00:43:16,755 -- 00:43:18,123
It's, it can be difficult
00:43:18,123 -- 00:43:20,192
to get the kind of expertise that you need to have,
00:43:21,627 -- 00:43:22,628
an effective Board.
00:43:22,628 -- 00:43:24,963
So that's certainly a challenge.
00:43:24,963 -- 00:43:26,798
When I look at my role and my team's role,
00:43:26,798 -- 00:43:29,501
I keep saying my role, but my team does all the work,
00:43:29,501 -- 00:43:32,905
so I have to give them all of the credit.
00:43:32,905 -- 00:43:35,107
You know, running a trade association
00:43:35,107 -- 00:43:38,177
in any sector is a challenge, particularly one
00:43:38,177 -- 00:43:43,181
such as ours with such a wide variety of,
00:43:43,649 -- 00:43:46,518
of, of members, a lot of industries out there,
00:43:46,518 -- 00:43:48,887
you know, they'll have a trade association, but
00:43:48,887 -- 00:43:51,924
the members are a lot more similar to one another.
00:43:51,924 -- 00:43:54,192
That's a completely not the case,
00:43:54,192 -- 00:43:56,295
in, in the Credit Union sector.
00:43:56,295 -- 00:43:57,963
So when we're trying to,
00:43:57,963 -- 00:44:01,066
you know, marshal our members on an issue of policy
00:44:01,066 -- 00:44:02,668
or a challenge with a government
00:44:02,668 -- 00:44:04,169
either in Ontario or elsewhere.
00:44:05,304 -- 00:44:06,672
You know, it's important for
00:44:06,672 -- 00:44:08,807
all individual Credit Unions
00:44:08,807 -- 00:44:10,943
to realize that, you know, sometimes for the greater
00:44:10,943 -- 00:44:11,543
good of the sector,
00:44:11,543 -- 00:44:13,412
you got to put a little bit of water in your wine.
00:44:13,412 -- 00:44:14,813
And, and, you know,
00:44:14,813 -- 00:44:17,482
we can't necessarily go lobby a government
00:44:17,482 -- 00:44:20,752
on an issue of importance to 2 or 3 members, even if it,
00:44:20,752 -- 00:44:23,689
you know, feels red hot to those 2 or 3 members.
00:44:23,689 -- 00:44:26,425
We really, like I said earlier, have to
00:44:26,425 -- 00:44:27,793
do the work to identify those issues
00:44:27,793 -- 00:44:28,960
that, that
00:44:28,960 -- 00:44:29,895
unify our members,
00:44:29,895 -- 00:44:30,962
but also from the member's
00:44:30,962 -- 00:44:32,130
point of view, from the Credit Unions
00:44:32,130 -- 00:44:34,332
point of view, that is to say,
00:44:34,332 -- 00:44:35,834
you know, it's important to understand
00:44:35,834 -- 00:44:37,969
that we all got to work together
00:44:37,969 -- 00:44:39,071
on some of these challenges.
00:44:39,071 -- 00:44:41,640
And that means sometimes you're not always going to get
00:44:41,640 -- 00:44:42,674
everything that you want.
00:44:42,674 -- 00:44:45,877
And an interesting example of that recently in Ontario was,
00:44:45,877 -- 00:44:46,311
you know,
00:44:46,311 -- 00:44:48,213
we had some back and forth, Mehrdad, with you
00:44:48,213 -- 00:44:50,916
and the team on EDC, on enhanced data collection.
00:44:50,916 -- 00:44:54,453
That was a heavy lift for a lot of the smaller,
00:44:54,453 -- 00:44:58,957
Credit Unions across the province in 2022 and 2023.
00:45:00,392 -- 00:45:00,926
And, you know,
00:45:00,926 -- 00:45:03,428
we acted as a bridge between your team
00:45:03,428 -- 00:45:04,696
and our members
00:45:04,696 -- 00:45:08,800
to, you know, I think pretty effectively deal with that.
00:45:08,800 -- 00:45:11,837
And we obviously recognize as you Credit Unions,
00:45:11,837 -- 00:45:13,905
here and elsewhere, that data is key.
00:45:13,905 -- 00:45:16,675
You can't measure, you can't regulate.
00:45:16,675 -- 00:45:18,910
You know, what you don't have key data on.
00:45:18,910 -- 00:45:22,113
So we're, we're fully on board with that,
00:45:22,113 -- 00:45:24,216
but, you know, there just has to be flexibility
00:45:24,216 -- 00:45:25,317
from, from the governments
00:45:25,317 -- 00:45:26,384
and the regulators point of view.
00:45:26,384 -- 00:45:28,086
And then from the Credit Unions point of view, again,
00:45:28,086 -- 00:45:29,588
there has to be an acknowledgment
00:45:29,588 -- 00:45:32,157
that, you know, sometimes we got to
00:45:32,157 -- 00:45:33,425
we got to buckle up a little bit
00:45:33,425 -- 00:45:35,660
and, and again, put a bit of water in our wine
00:45:35,660 -- 00:45:39,731
to identify those issues of, of, of, you know, common,
00:45:40,732 -- 00:45:41,132
you know,
00:45:41,132 -- 00:45:43,602
common issues that, that we have to work together for,
00:45:43,602 -- 00:45:45,937
for as a sector together.
00:45:45,937 -- 00:45:47,038
Thanks, Michael.
00:45:47,038 -- 00:45:48,940
So, panel members by now
00:45:48,940 -- 00:45:50,675
know they got to be careful what they say around me.
00:45:50,675 -- 00:45:52,844
So, Chris, I'm going to quote you again, right?
00:45:52,844 -- 00:45:54,312
I think I'm going to quote you.
00:45:54,312 -- 00:45:57,248
You said something. I think it was a couple of weeks ago.
00:45:57,248 -- 00:45:59,551
You said that, “there isn't just a path to efficient merger.”
00:45:59,551 -- 00:46:01,686
So talking about Credit Unions working together
00:46:01,686 -- 00:46:04,990
and gaining that effective scale that's needed.
00:46:04,990 -- 00:46:05,924
So what did you mean by it,
00:46:05,924 -- 00:46:10,628
“there was a just a path to effective mergers?”
00:46:10,628 -- 00:46:12,130
Chris.
00:46:12,130 -- 00:46:14,766
Yeah.
00:46:14,766 -- 00:46:16,668
I think when I,
00:46:16,668 -- 00:46:19,170
I'm, I'm not in the current operations
00:46:19,170 -- 00:46:24,776
like my colleagues here, but when, when I reflect on the
00:46:26,177 -- 00:46:26,978
energy that's
00:46:26,978 -- 00:46:30,448
going in, in different Credit Union constituencies and
00:46:30,448 -- 00:46:32,417
alliances or visions,
00:46:32,417 -- 00:46:33,952
I think we're all
00:46:33,952 -- 00:46:35,854
struggling to break through
00:46:35,854 -- 00:46:39,524
all of the issues that were at the front of the slide,
00:46:39,524 -- 00:46:41,726
for long term planning.
00:46:41,726 -- 00:46:45,096
And so probably for the next few years,
00:46:45,096 -- 00:46:49,300
that cohesion is going to look more like going off
00:46:49,300 -- 00:46:50,435
in different directions
00:46:50,435 -- 00:46:55,440
in order to find what is the strongest path.
00:46:56,341 -- 00:46:57,809
In British Columbia, there's
00:46:57,809 -- 00:47:01,579
there's a natural consolidation that's happening.
00:47:01,579 -- 00:47:06,151
Part of it is retirement and, inability to garner,
00:47:06,151 -- 00:47:08,620
the talent that's necessary.
00:47:08,620 -- 00:47:12,023
But the community presence is not going away.
00:47:12,023 -- 00:47:14,792
And so.
00:47:14,792 -- 00:47:19,097
I've studied different, different transformations.
00:47:19,097 -- 00:47:21,766
Some provinces accelerate.
00:47:21,766 -- 00:47:26,504
In the case of Australia, they actually changed regulations
00:47:26,504 -- 00:47:28,439
from a provincial level
00:47:28,439 -- 00:47:30,808
to a state level to a federal level,
00:47:30,808 -- 00:47:33,845
as many of you may have observed.
00:47:33,845 -- 00:47:35,647
But, but I would conclude
00:47:35,647 -- 00:47:38,650
that the strength is the community governance
00:47:38,650 -- 00:47:40,985
and that if you have the capital
00:47:40,985 -- 00:47:45,957
and hopefully the regulatory framework of operating
00:47:45,957 -- 00:47:48,226
with innovation,
00:47:48,226 -- 00:47:49,927
that we should just be patient
00:47:49,927 -- 00:47:54,165
and recognize that we're going to have a disparate period
00:47:54,165 -- 00:47:57,168
before some breakthroughs are stronger than others.
00:47:58,202 -- 00:47:59,504
Thank you, Chris.
00:47:59,504 -- 00:48:02,507
So, Jacquie the next question is for Boards.
00:48:02,507 -- 00:48:05,643
So you're the perfect person to answer it,
00:48:05,643 -- 00:48:07,879
given that the environment has become more complex,
00:48:07,879 -- 00:48:11,182
a lot more complex than even ten years ago,
00:48:11,182 -- 00:48:15,753
and the role of Board Directors has also become complex
00:48:15,753 -- 00:48:18,056
because of this.
00:48:18,056 -- 00:48:20,525
How does it work in practice regarding Board members
00:48:20,525 -- 00:48:25,530
and their accountability for the Credit Union strategy?
00:48:26,064 -- 00:48:28,766
So strategy is,
00:48:28,766 -- 00:48:29,901
a little bit of a challenge
00:48:29,901 -- 00:48:32,470
when you're in such a disruptive environment
00:48:32,470 -- 00:48:34,172
with so many factors.
00:48:34,172 -- 00:48:37,442
So I, I thought I would tell a little bit of a story,
00:48:37,442 -- 00:48:43,948
about a company that was incredibly successful in 2004.
00:48:45,183 -- 00:48:48,152
The company was called Blockbuster.
00:48:48,152 -- 00:48:50,655
Some of you may remember them.
00:48:50,655 -- 00:48:59,063
It had 84,000 employees and operated 9,000 stores in 2004.
00:49:00,331 -- 00:49:03,301
And they started losing money.
00:49:03,301 -- 00:49:05,703
And so I often wonder
00:49:05,703 -- 00:49:08,105
what the Board of Directors were saying
00:49:08,105 -- 00:49:10,708
that first year, that they lost money.
00:49:10,708 -- 00:49:14,445
So did they say, oh, it's okay,
00:49:14,445 -- 00:49:15,947
we're going to pay the bonuses
00:49:15,947 -- 00:49:19,750
to Senior Management anyway because we're nice?
00:49:19,750 -- 00:49:24,255
Or are they going to say, you know what, it was a Y2K issue
00:49:24,255 -- 00:49:26,991
or the Internet is overrated.
00:49:26,991 -- 00:49:29,560
It's just a blip.
00:49:29,560 -- 00:49:34,198
Ten years later, Blockbuster was bankrupt.
00:49:34,198 -- 00:49:38,703
It took ten years for them to go bankrupt.
00:49:38,703 -- 00:49:40,504
And in that time they weren't
00:49:40,504 -- 00:49:41,939
able as a Board
00:49:41,939 -- 00:49:46,277
to determine a change or a shift in their strategy.
00:49:46,277 -- 00:49:48,279
At the end of the day,
00:49:48,279 -- 00:49:49,714
it went bankrupt
00:49:49,714 -- 00:49:54,919
because they charged one of their owners $40 in late fees.
00:49:56,020 -- 00:50:00,891
And that owner, sorry, that customer, was named
00:50:00,891 -- 00:50:02,460
Reed Hastings.
00:50:02,460 -- 00:50:07,665
And Reed Hastings was so annoyed at being charged late fees
00:50:08,199 -- 00:50:14,372
that he started Netflix, and Netflix was a DVD, a mail DVD,
00:50:15,239 -- 00:50:17,108
subscription at that time.
00:50:17,108 -- 00:50:20,177
And obviously today, Netflix has soared.
00:50:20,177 -- 00:50:22,213
So when you put your mind
00:50:22,213 -- 00:50:24,281
in the mind of that Board,
00:50:24,281 -- 00:50:27,118
management is saying, let's double down.
00:50:27,118 -- 00:50:29,253
Our strategy is good, we're successful.
00:50:29,253 -- 00:50:31,555
We've been successful up to this point.
00:50:32,857 -- 00:50:36,160
As a Board Member, you have to say, and what if
00:50:36,160 -- 00:50:38,262
what if things do change?
00:50:38,262 -- 00:50:44,034
What if technology is going to dramatically change, like AI?
00:50:44,568 -- 00:50:45,936
We can't run away from it.
00:50:45,936 -- 00:50:48,472
We have to understand it
00:50:48,472 -- 00:50:52,977
and understand what's going to happen in, in five years.
00:50:52,977 -- 00:50:53,611
This morning
00:50:53,611 -- 00:50:55,546
we talked about a lot of things
00:50:55,546 -- 00:50:58,549
that have the opportunity to really shift
00:50:58,549 -- 00:51:00,784
our strategy in five years.
00:51:00,784 -- 00:51:05,789
And as Board Members, we have to understand what those,
00:51:07,925 -- 00:51:12,830
forces are and what they can, can prepare us for.
00:51:12,830 -- 00:51:18,068
And I think when we talk about our customers, our owners,
00:51:18,903 -- 00:51:23,908
there is a value proposition that we can provide to them,
00:51:23,941 -- 00:51:27,778
that is really secure. But we have to think about it.
00:51:27,778 -- 00:51:29,613
What does that value proposition
00:51:29,613 -- 00:51:32,916
look like in five years or in ten years?
00:51:32,916 -- 00:51:35,219
And stress test it based on the
00:51:35,219 -- 00:51:37,421
the environment that you operate in.
00:51:38,656 -- 00:51:41,392
In London, where we are headquartered,
00:51:41,392 -- 00:51:44,194
we have competing demands, right now.
00:51:44,194 -- 00:51:48,432
We have the migration of people from the GTA
00:51:48,432 -- 00:51:50,801
looking for homes that are affordable
00:51:50,801 -- 00:51:54,505
and, and a lifestyle that is, is comfortable.
00:51:54,505 -- 00:51:56,306
And they're coming into London
00:51:56,306 -- 00:52:00,477
and the surrounding small towns. At the same time,
00:52:00,477 -- 00:52:02,780
we have huge consolidation
00:52:02,780 -- 00:52:06,350
that has happened in our rural farming communities,
00:52:06,350 -- 00:52:10,788
and it's really challenging to actually get people to work,
00:52:10,788 -- 00:52:12,489
in some of the smaller communities
00:52:12,489 -- 00:52:15,292
because young people have left.
00:52:15,292 -- 00:52:18,362
The farmers are now large
00:52:18,362 -- 00:52:21,265
farms rather than small family farms.
00:52:21,265 -- 00:52:23,734
So you have this dichotomy.
00:52:23,734 -- 00:52:26,437
So when we look at our book
00:52:26,437 -- 00:52:28,605
and we are servicing those communities,
00:52:28,605 -- 00:52:30,507
what does that mean for us?
00:52:30,507 -- 00:52:35,979
Having a branch in a community of 5,000 people, do we stay?
00:52:35,979 -- 00:52:37,981
Do we go? And what does that mean?
00:52:39,116 -- 00:52:40,050
So when I look at
00:52:40,050 -- 00:52:45,055
strategy, I, I thought about a few things.
00:52:45,422 -- 00:52:49,359
We should be looking at if I can read them.
00:52:49,359 -- 00:52:53,397
The first thing I think is, is making sure we have the data.
00:52:53,397 -- 00:52:56,400
We really need to make decisions based on data,
00:52:56,400 -- 00:53:00,737
not based on antidotel information.
00:53:00,737 -- 00:53:04,374
We also have to really look at what business are we in.
00:53:04,374 -- 00:53:05,609
We heard today
00:53:05,609 -- 00:53:08,879
lots of different areas that we can get involved in.
00:53:08,879 -- 00:53:13,150
Lots of community problems that we can try and solve.
00:53:13,150 -- 00:53:14,618
But at the end of the day,
00:53:14,618 -- 00:53:16,853
we have to be disciplined to say
00:53:16,853 -- 00:53:19,990
we're in the financial services business
00:53:19,990 -- 00:53:24,995
and if we do that well, then we are able to invest more.
00:53:25,195 -- 00:53:26,964
If we don't do that well,
00:53:26,964 -- 00:53:29,800
if we don't have enough capital, at the end of the day,
00:53:29,800 -- 00:53:31,835
then we're , no good for anyone.
00:53:33,337 -- 00:53:33,937
And I guess
00:53:33,937 -- 00:53:36,506
also who we serve as well,
00:53:36,506 -- 00:53:39,242
because we can't serve everybody.
00:53:39,242 -- 00:53:42,679
We may need to put, a had the discipline to say,
00:53:42,679 -- 00:53:43,880
this is the customer
00:53:43,880 -- 00:53:45,549
that we're going to serve,
00:53:45,549 -- 00:53:47,384
and they'll be another Credit Union
00:53:47,384 -- 00:53:50,020
who can serve a different customer.
00:53:50,020 -- 00:53:51,021
We do need...
00:53:51,021 -- 00:53:52,189
we have this year,
00:53:52,189 -- 00:53:55,058
actually demarcated a couple of businesses
00:53:55,058 -- 00:53:59,229
that were outside of our risk tolerance. And that's okay.
00:53:59,229 -- 00:54:03,300
We need to have the courage in order to do that.
00:54:03,300 -- 00:54:04,101
So I do...
00:54:04,101 -- 00:54:06,069
I'm going to end today with five cautions
00:54:06,069 -- 00:54:09,005
that I think we need to look at.
00:54:09,005 -- 00:54:10,407
One of them is don't get old
00:54:10,407 -- 00:54:14,478
because you can't read your notes.
00:54:14,478 -- 00:54:17,747
The first one, I think having a brand new CEO
00:54:17,747 -- 00:54:19,816
has highlighted this for me
00:54:19,816 -- 00:54:21,118
is that we really need
00:54:21,118 -- 00:54:24,454
to be cautious of using the past
00:54:24,454 -- 00:54:26,923
as a predictor for the future.
00:54:26,923 -- 00:54:29,626
Our future right now is very different
00:54:29,626 -- 00:54:31,495
than our past has ever been.
00:54:31,495 -- 00:54:36,566
And so we can't really, take one and implant on
00:54:36,566 -- 00:54:37,133
the other.
00:54:38,502 -- 00:54:39,936
And saying, having said that,
00:54:39,936 -- 00:54:42,839
there's always more than one possible outcome.
00:54:42,839 -- 00:54:44,774
We aren't on a trajectory
00:54:44,774 -- 00:54:48,511
where we're all going to be moving in the same direction.
00:54:48,511 -- 00:54:50,747
So we need to plan different scenarios.
00:54:50,747 -- 00:54:53,316
We need to plan different outcomes.
00:54:53,316 -- 00:54:55,018
If you had asked me ten years ago
00:54:55,018 -- 00:54:56,820
when I started on the board
00:54:56,820 -- 00:54:59,289
whether we were going to have a global pandemic,
00:54:59,289 -- 00:55:01,324
which was going to shut everything down
00:55:01,324 -- 00:55:04,628
and interest rates were going to go up so high,
00:55:04,628 -- 00:55:06,730
who would have thought,
00:55:06,730 -- 00:55:08,665
and we need to scenario plan
00:55:08,665 -- 00:55:12,502
so that we can stress test for those.
00:55:12,502 -- 00:55:15,038
Don't underestimate technology
00:55:15,038 -- 00:55:18,008
and the importance of technology to people.
00:55:18,008 -- 00:55:19,809
People like their technology.
00:55:19,809 -- 00:55:23,079
They like making things, their lives easier.
00:55:23,079 -- 00:55:24,848
If you can imagine,
00:55:24,848 -- 00:55:29,853
my grandfather just loved email because it was so seamless.
00:55:30,020 -- 00:55:31,955
Instead of taking six weeks
00:55:31,955 -- 00:55:33,723
to communicate with his friends,
00:55:33,723 -- 00:55:36,159
he could do it instantaneously.
00:55:36,159 -- 00:55:37,994
Today, he would have been the first person
00:55:37,994 -- 00:55:40,363
on video conferencing. He just loved it.
00:55:41,865 -- 00:55:46,403
But don't overestimate shiny things.
00:55:46,403 -- 00:55:47,904
Ten years ago, Bitcoin
00:55:47,904 -- 00:55:49,672
was going to put us all out of business.
00:55:49,672 -- 00:55:53,109
We were all going to be, crazy.
00:55:53,109 -- 00:55:55,945
And it was a shiny thing.
00:55:55,945 -- 00:55:59,649
And the final thing is
00:55:59,649 -- 00:56:03,520
to differentiate between your core fundamentals
00:56:03,520 -- 00:56:05,455
that can't change.
00:56:05,455 -- 00:56:08,124
It's the DNA of who we are
00:56:08,124 -- 00:56:12,762
and those traditions that can change and need to change,
00:56:12,762 -- 00:56:16,900
because it's time to change.
00:56:16,900 -- 00:56:17,567
Thank you, Jacquie.
00:56:17,567 -- 00:56:20,770
So, we've been talking about,
00:56:20,770 -- 00:56:22,872
solutions that the sector needs to come up with
00:56:22,872 -- 00:56:25,708
that needs to be sector led, sector driven.
00:56:25,708 -- 00:56:27,510
What do you think about Boards
00:56:27,510 -- 00:56:29,412
and not just their role and responsibility,
00:56:29,412 -- 00:56:32,582
which we know they have for their Credit Union strategy,
00:56:32,582 -- 00:56:37,554
but the role that they play for the sector strategy?
00:56:37,554 -- 00:56:40,790
I think Boards need to
00:56:40,790 -- 00:56:45,128
get out a little bit more and meet other Board members,
00:56:45,128 -- 00:56:50,099
because that Board-to-Board conversations, you realize that
00:56:50,500 -- 00:56:52,435
we're not different.
00:56:52,435 -- 00:56:55,805
As much as we like to say that we're all nuanced
00:56:55,805 -- 00:56:56,673
and we're all different,
00:56:56,673 -- 00:56:58,908
we're more alike than anything else.
00:56:58,908 -- 00:57:01,344
We're more alike than, than we are different.
00:57:01,344 -- 00:57:06,349
And in those conversations, solutions can come up.
00:57:06,582 -- 00:57:11,587
And we need to stop being quite so defensive of our turf.
00:57:12,055 -- 00:57:16,225
You know, we say we don't compete, but we do compete.
00:57:16,225 -- 00:57:18,261
I don't know if anyone's here from Windsor family,
00:57:18,261 -- 00:57:20,129
but when I saw
00:57:20,129 -- 00:57:23,199
WFU, it came into London, it's like, what the heck?
00:57:23,199 -- 00:57:25,101
This is my town. You can't come in here.
00:57:26,235 -- 00:57:30,740
So, you know, I think it's those kinds of reactions
00:57:30,740 -- 00:57:32,375
we need to get to know each other
00:57:32,375 -- 00:57:36,179
and get to know what the, the business model is.
00:57:36,179 -- 00:57:37,280
Thank you, Jacquie.
00:57:37,280 -- 00:57:39,816
Anybody else want to
00:57:39,816 -- 00:57:40,883
continue along that line,
00:57:40,883 -- 00:57:44,420
or should we move on to the next question?
00:57:44,420 -- 00:57:46,622
All right. We'll move on to the next question.
00:57:46,622 -- 00:57:48,291
I didn't want to get to this question, but,
00:57:48,291 -- 00:57:52,328
this one has to do with regulators, aka FSRA.
00:57:52,328 -- 00:57:53,229
And I promise you,
00:57:53,229 -- 00:57:56,232
we didn't feed the answers to the panel members.
00:57:56,232 -- 00:57:57,834
They're going to say what they want.
00:57:57,834 -- 00:57:59,469
So the question is, how can regulators
00:57:59,469 -- 00:58:02,105
support the Credit Union sector’s evolution?
00:58:02,105 -- 00:58:04,574
And this is to all of you, please.
00:58:04,574 -- 00:58:06,008
Who wants to take that first.
00:58:06,008 -- 00:58:08,044
I'll go. I'll, I'll stick my neck out.
00:58:09,645 -- 00:58:11,481
You know,
00:58:11,481 -- 00:58:14,183
if each one of us
00:58:14,183 -- 00:58:18,321
maintains the proper governance and the proper compliance
00:58:18,321 -- 00:58:20,623
and we're not being staged,
00:58:20,623 -- 00:58:23,226
then the regulator, in my opinion,
00:58:23,226 -- 00:58:26,395
has the capacity to go to the Minister of Finance
00:58:26,395 -- 00:58:26,863
and say,
00:58:26,863 -- 00:58:30,600
protect your regional financial institution network,
00:58:30,600 -- 00:58:34,270
which can be a driver for economic development.
00:58:34,270 -- 00:58:35,438
And in British Columbia
00:58:35,438 -- 00:58:37,773
right now, the Credit Unions deliver that,
00:58:37,773 -- 00:58:40,743
the accelerated housing,
00:58:40,743 -- 00:58:44,113
housing starts in the affordables, housing sector.
00:58:44,113 -- 00:58:45,848
But that's an accountability
00:58:45,848 -- 00:58:48,584
that is ours to enable
00:58:48,584 -- 00:58:49,852
the regulator
00:58:49,852 -- 00:58:54,357
to play the role of not going to the deposit insurance
00:58:54,357 -- 00:58:55,758
relief fund,
00:58:55,758 -- 00:58:59,028
but to provide relief to the province
00:58:59,028 -- 00:59:01,597
in terms of an economic engine,
00:59:01,597 -- 00:59:02,999
which then leaves us
00:59:02,999 -- 00:59:08,004
as Credit Union operators focused on member and community.
00:59:09,271 -- 00:59:13,042
It's a big, it's a big, big challenge to stay
00:59:13,042 -- 00:59:16,545
in that center of adequate liquidity , adequate capital
00:59:16,545 -- 00:59:19,615
and adequate return. But that's my vision.
00:59:22,885 -- 00:59:23,719
I'll go next.
00:59:23,719 -- 00:59:24,453
Oh, sorry, Jacquie.
00:59:24,453 -- 00:59:29,225
Did you raise your hand? Yeah. Okay. Go ahead. Oh, I did not...sure.
00:59:29,225 -- 00:59:31,627
I think one of the things the regulator can do
00:59:31,627 -- 00:59:33,429
is help us to determine
00:59:33,429 -- 00:59:37,199
what best practices are, through regulation.
00:59:37,199 -- 00:59:39,368
So I think it was mentioned this morning
00:59:39,368 -- 00:59:41,103
in the AI
00:59:41,103 -- 00:59:42,638
conversation that,
00:59:42,638 -- 00:59:43,506
you know, it's hard
00:59:43,506 -- 00:59:45,908
for us to know what best practices are
00:59:45,908 -- 00:59:49,078
and to have all that knowledge.
00:59:49,078 -- 00:59:52,548
Whereas if you have the assurance
00:59:52,548 -- 00:59:56,152
that if you're following the regulations, that by default
00:59:56,152 -- 00:59:57,787
you're doing best practices,
00:59:57,787 -- 01:00:00,122
then that's actually kind of helpful.
01:00:00,122 -- 01:00:03,392
So we know that if we meet your standard,
01:00:03,392 -- 01:00:07,863
then we're doing best practices.
01:00:07,863 -- 01:00:12,835
So I have thoughts. A couple of things.
01:00:12,835 -- 01:00:13,569
I would say just
01:00:13,569 -- 01:00:17,006
and this isn't just for, Ontario, but it’s in general,
01:00:17,006 -- 01:00:18,641
you know, be open to different strategies.
01:00:18,641 -- 01:00:19,942
You know, we have,
01:00:19,942 -- 01:00:21,644
modeling at the national level
01:00:21,644 -- 01:00:24,513
that suggests that in 2030, which is,
01:00:24,513 -- 01:00:27,850
you know, only a half a decade from now, believe it or not,
01:00:29,518 -- 01:00:31,220
you know, the sort of 80 or 90%
01:00:31,220 -- 01:00:32,788
confidence interval
01:00:32,788 -- 01:00:36,725
is somewhere between 90 and 110 Credit Unions in Canada.
01:00:36,725 -- 01:00:39,228
So roughly half of the number of institutions we have now.
01:00:39,228 -- 01:00:41,797
So that would suggest for Ontario, it's what,
01:00:41,797 -- 01:00:46,602
you know, 25 or 30, kind of ballpark.
01:00:46,602 -- 01:00:48,003
Obviously, the further out in the future
01:00:48,003 -- 01:00:50,439
you get, the less and less, reliable
01:00:50,439 -- 01:00:52,574
those, those predictions are.
01:00:52,574 -- 01:00:53,275
But, you know,
01:00:53,275 -- 01:00:53,542
it does
01:00:53,542 -- 01:00:56,045
suggest a certain, a pace of continued
01:00:56,045 -- 01:00:58,814
consolidation in this province and elsewhere.
01:00:58,814 -- 01:01:00,649
But it also suggests that you're going to continue
01:01:00,649 -- 01:01:03,519
to have in 2030 and 2040,
01:01:03,519 -- 01:01:08,390
a wide variety of institutions, to regulate,
01:01:08,390 -- 01:01:11,326
big, small and everything in between
01:01:11,326 -- 01:01:13,696
that are all going to have different strategies.
01:01:13,696 -- 01:01:16,832
Some of their strategies may be to eventually,
01:01:16,832 -- 01:01:21,070
consider, pursuing federal regulation.
01:01:21,070 -- 01:01:24,707
Some will, you know, merge with other institutions.
01:01:24,707 -- 01:01:26,642
Some may partner with,
01:01:26,642 -- 01:01:30,079
federally regulated Credit Unions in, in other provinces.
01:01:31,180 -- 01:01:32,915
And we know that there's,
01:01:32,915 -- 01:01:33,348
you know, one
01:01:33,348 -- 01:01:34,149
example of that
01:01:34,149 -- 01:01:35,617
that has started to take place
01:01:35,617 -- 01:01:39,221
between Alberta and Saskatchewan.
01:01:39,221 -- 01:01:41,657
So just be open to,
01:01:41,657 -- 01:01:43,025
you know, continuing to regulate,
01:01:43,025 -- 01:01:44,893
of course, a wide variety of institutions
01:01:44,893 -- 01:01:47,996
and be open to having a flexible approach
01:01:47,996 -- 01:01:50,499
in terms of what their respective,
01:01:50,499 -- 01:01:52,034
strategies are going to be.
01:01:52,034 -- 01:01:54,336
So that's request number one.
01:01:54,336 -- 01:01:58,240
Request number two, please, for the love of God,
01:01:58,240 -- 01:01:59,675
you know, work with Ottawa
01:01:59,675 -- 01:02:02,878
and the federal government, right. Like,
01:02:02,878 -- 01:02:06,682
if you think the banks are, are big and, and scary,
01:02:06,682 -- 01:02:09,618
the federal government is like, it's like a drunk elephant
01:02:09,618 -- 01:02:11,320
sometimes. It just stumbles around
01:02:11,320 -- 01:02:13,655
and it has the capacity to crush us.
01:02:13,655 -- 01:02:19,294
And, you know, by, neglect or ignorance or
01:02:19,328 -- 01:02:20,429
however you want to call it,
01:02:21,396 -- 01:02:24,099
you know, the feds have
01:02:24,099 -- 01:02:25,300
shown themselves
01:02:25,300 -- 01:02:27,502
capable of throwing up
01:02:27,502 -- 01:02:29,605
existential challenges to the Credit Union sector
01:02:29,605 -- 01:02:30,872
just because they don't
01:02:30,872 -- 01:02:32,841
have a direct line of sight into it.
01:02:32,841 -- 01:02:35,243
They think the financial sector in Canada
01:02:35,243 -- 01:02:36,812
is five institutions.
01:02:36,812 -- 01:02:38,180
When there's a crisis like COVID,
01:02:38,180 -- 01:02:42,451
they want to deal with five CEOs and not 200.
01:02:42,451 -- 01:02:45,420
But that has caused major problems for us in Ottawa.
01:02:45,420 -- 01:02:47,956
I can tell you that we're constantly,
01:02:47,956 -- 01:02:49,558
coming up against that reality.
01:02:49,558 -- 01:02:51,727
So please help us,
01:02:51,727 -- 01:02:52,160
you know,
01:02:52,160 -- 01:02:54,963
educate our federal colleagues
01:02:54,963 -- 01:02:58,000
and friends in, in, in the national capital
01:02:58,000 -- 01:02:59,935
that the provincially regulated
01:02:59,935 -- 01:03:00,569
Credit Union
01:03:00,569 -- 01:03:01,570
sector is,
01:03:01,570 -- 01:03:03,071
you know, obviously a key part
01:03:03,071 -- 01:03:05,807
of, of the landscape in Canada.
01:03:05,807 -- 01:03:07,242
All right. Lloyd, please.
01:03:07,242 -- 01:03:08,877
I think,
01:03:08,877 -- 01:03:10,879
again, was said earlier by Jacquie,
01:03:10,879 -- 01:03:14,783
the past isn't always the predictor of the future.
01:03:14,783 -- 01:03:17,319
And from the Credit Union perspective,
01:03:17,319 -- 01:03:18,653
I mean, it continues to evolve.
01:03:18,653 -- 01:03:20,088
And that's really what this whole,
01:03:21,189 -- 01:03:22,791
panel discussion today is around
01:03:22,791 -- 01:03:24,726
how the Credit Union sector is evolving.
01:03:24,726 -- 01:03:29,698
So I think from a regulator point of view, and regulation,
01:03:29,698 -- 01:03:31,366
I always say everyone has a job to do.
01:03:31,366 -- 01:03:32,534
And, and again,
01:03:32,534 -- 01:03:34,202
when it comes to regulation,
01:03:34,202 -- 01:03:35,737
it's an important element
01:03:35,737 -- 01:03:39,107
of what builds the public trust that we have in our sector.
01:03:39,107 -- 01:03:41,276
And I just think as business changes
01:03:41,276 -- 01:03:44,646
as, as the world changes, as technology,
01:03:44,646 -- 01:03:46,748
ultimately is going to change the way
01:03:46,748 -- 01:03:49,184
in which we as consumers live our lives.
01:03:49,184 -- 01:03:51,153
I think, as a regulator,
01:03:51,153 -- 01:03:52,888
it's important that they keep up as well.
01:03:52,888 -- 01:03:54,623
And they understand,
01:03:54,623 -- 01:03:55,524
you know, how the business
01:03:55,524 -- 01:03:57,292
is going to thrive into the future.
01:03:57,292 -- 01:03:59,327
So we really need,
01:03:59,327 -- 01:04:00,862
a strong working relationship
01:04:00,862 -- 01:04:03,598
with our regulator and obviously,
01:04:03,598 -- 01:04:05,066
one that obviously speaks to,
01:04:05,066 -- 01:04:07,035
you know, what's changing in our society today.
01:04:11,439 -- 01:04:16,244
Any last few comments before I go into questions?
01:04:16,244 -- 01:04:16,912
All right. Great.
01:04:16,912 -- 01:04:20,348
So we're going to, we're right on time.
01:04:20,348 -- 01:04:22,651
So we have time for questions.
01:04:22,651 -- 01:04:25,086
Looking at the monitor
01:04:25,086 -- 01:04:27,522
I don't see any popping up yet.
01:04:27,522 -- 01:04:28,356
Let's give it a minute.
01:04:28,356 -- 01:04:30,325
I'm sure some of you have questions.
01:04:30,325 -- 01:04:32,160
Oh my God I can't read that.
01:04:32,160 -- 01:04:34,296
Excuse me I'm going to come over here.
01:04:34,296 -- 01:04:34,729
Oh, this.
01:04:34,729 -- 01:04:37,165
Apparently that's so small.
01:04:37,165 -- 01:04:38,166
Check. Yes.
01:04:38,166 -- 01:04:41,436
Jacquie, what does that say? It says, false.
01:04:41,436 -- 01:04:43,338
Is there an opportunity for the sector to come together
01:04:43,338 -- 01:04:44,873
collectively to tackle significant
01:04:44,873 -- 01:04:49,344
socio economic challenges, such as affordable housing?
01:04:49,344 -- 01:04:50,712
Okay, that's for you guys, not me.
01:04:50,712 -- 01:04:53,281
So please go ahead.
01:04:53,281 -- 01:04:56,618
I read the question.
01:04:56,618 -- 01:04:59,554
The font is this big,
01:04:59,554 -- 01:05:01,890
Well, again, I'll, I'll just maybe,
01:05:01,890 -- 01:05:03,491
I'll start and maybe my colleagues here.
01:05:04,692 -- 01:05:07,295
Again, I gave an example of what,
01:05:07,295 -- 01:05:08,897
was done at FirstOntario.
01:05:08,897 -- 01:05:13,902
And again, what we tried to do was to just demonstrate,
01:05:14,135 -- 01:05:18,873
a model and one that, we were hoping others would pick up.
01:05:18,873 -- 01:05:21,409
Not necessarily Credit Unions, but certainly,
01:05:21,409 -- 01:05:23,144
other, builders and other,
01:05:23,144 -- 01:05:24,145
you know, folks,
01:05:24,145 -- 01:05:25,380
in that trade
01:05:25,380 -- 01:05:26,881
that would realize that there's
01:05:26,881 -- 01:05:30,151
a need for creating housing stock. So,
01:05:30,151 -- 01:05:32,020
again, it is a big problem.
01:05:32,020 -- 01:05:33,154
And we'd like to say that, you know,
01:05:33,154 -- 01:05:34,022
we can't solve it all,
01:05:34,022 -- 01:05:36,724
but we wanted to be part of the solution.
01:05:36,724 -- 01:05:40,862
So could we again use that example
01:05:40,862 -- 01:05:43,898
of what we did and share that and allow other,
01:05:43,898 -- 01:05:45,900
other folks in Ontario to come together?
01:05:45,900 -- 01:05:50,371
I think the answer is yes. That is a possibility.
01:05:50,371 -- 01:05:50,572
Yeah.
01:05:50,572 -- 01:05:53,575
And I think politically, like I said earlier,
01:05:53,575 -- 01:06:00,348
there seems to be a handout from federal agencies
01:06:00,348 -- 01:06:02,283
and they're looking for a partner
01:06:02,283 -- 01:06:06,387
who's capable of understanding the intricacies
01:06:06,387 -- 01:06:08,456
of what it takes to deliver
01:06:08,456 -- 01:06:09,290
non-market
01:06:09,290 -- 01:06:11,793
housing in a time of high interest
01:06:11,793 -- 01:06:14,562
rates and escalating construction costs,
01:06:14,562 -- 01:06:16,965
and often that's also a not for profit builder.
01:06:17,932 -- 01:06:19,934
So, I, I
01:06:19,934 -- 01:06:21,102
think that we have
01:06:21,102 -- 01:06:21,936
the alliance
01:06:21,936 -- 01:06:26,908
and the trust of all the, all the players in the chain.
01:06:27,041 -- 01:06:28,242
I'm not an
01:06:28,242 -- 01:06:30,812
I don't have a national view on this,
01:06:30,812 -- 01:06:35,516
but I know that in every province there's,
01:06:35,516 -- 01:06:38,686
A provincial housing cooperative federation
01:06:38,686 -- 01:06:43,057
and there are strong not for profit housing advocates.
01:06:43,057 -- 01:06:46,928
And I do think that they are naturally aligned.
01:06:46,928 -- 01:06:49,797
Our business losses,
01:06:49,797 -- 01:06:52,200
are not
01:06:52,200 -- 01:06:53,668
in the construction area
01:06:53,668 -- 01:06:57,338
usually because there's some CMHC insurance.
01:06:57,338 -- 01:06:59,674
But I do say it's a unique product
01:06:59,674 -- 01:07:02,710
because often it does need an interest reserve
01:07:02,710 -- 01:07:04,912
to solidify the tenancy.
01:07:04,912 -- 01:07:07,181
And solidify that debt servicing.
01:07:08,649 -- 01:07:11,919
I think there's also an opportunity for something
01:07:11,919 -- 01:07:14,756
a little bit new when it comes to mortgages.
01:07:14,756 -- 01:07:17,792
You know, we're talking about the amortization period,
01:07:17,792 -- 01:07:19,293
extending a little bit.
01:07:19,293 -- 01:07:24,298
But why not set up a rent own kind of environment?
01:07:24,398 -- 01:07:27,468
You can't do it again through your regulated body,
01:07:27,468 -- 01:07:29,837
but you have young people
01:07:29,837 -- 01:07:32,707
who have the money to pay a mortgage or rent.
01:07:32,707 -- 01:07:34,075
They can't pay both,
01:07:34,075 -- 01:07:36,010
so they can't save up their down payment
01:07:36,010 -- 01:07:38,813
because they're in the middle of paying rent.
01:07:38,813 -- 01:07:41,048
I have three of them. They're called kids.
01:07:41,048 -- 01:07:43,017
So, you know, having
01:07:43,017 -- 01:07:45,820
and they're fortunate because they have parents
01:07:45,820 -- 01:07:48,723
who are supporting and able to provide that.
01:07:48,723 -- 01:07:49,891
But what about the young people
01:07:49,891 -- 01:07:51,993
who don't have the ability to do that?
01:07:51,993 -- 01:07:54,028
So I think in that respects,
01:07:54,028 -- 01:07:56,964
being a little bit more creative about mortgage
01:07:56,964 -- 01:08:00,968
products would be, would be, something that'd be interesting.
01:08:00,968 -- 01:08:01,302
All right.
01:08:02,303 -- 01:08:03,404
Sorry if I could go.
01:08:03,404 -- 01:08:06,073
Of course. Quick.
01:08:06,073 -- 01:08:06,774
You know,
01:08:06,774 -- 01:08:08,976
one of the great things about Canada, really,
01:08:08,976 -- 01:08:12,480
and the way that the Federation is meant to work,
01:08:12,480 -- 01:08:14,415
though it doesn't always, of course,
01:08:14,415 -- 01:08:15,683
work perfectly
01:08:15,683 -- 01:08:16,150
is that,
01:08:16,150 -- 01:08:18,853
you know, good ideas from one part of the country can,
01:08:18,853 -- 01:08:21,489
can, can go across the rest of the country.
01:08:21,489 -- 01:08:23,391
So, from where I sit,
01:08:23,391 -- 01:08:26,527
I could see that being a potential answer to this question.
01:08:26,527 -- 01:08:28,462
We can't solve all of the world's problems.
01:08:28,462 -- 01:08:31,832
Obviously, these are very, very complicated issues.
01:08:31,832 -- 01:08:33,734
You know, climate, housing,
01:08:33,734 -- 01:08:36,804
all those giant mega issues that we're all aware of.
01:08:36,804 -- 01:08:38,906
But, you know, I can tell you that this is an example.
01:08:38,906 -- 01:08:40,341
The government of
01:08:40,341 -- 01:08:42,977
New Brunswick at the provincial level,
01:08:42,977 -- 01:08:46,180
reached out proactively to our sector in the province
01:08:46,180 -- 01:08:50,651
to design and deliver affordable housing,
01:08:50,651 -- 01:08:51,952
solutions and financing.
01:08:51,952 -- 01:08:53,687
And without getting into the details,
01:08:53,687 -- 01:08:57,491
you know, it's, it's, it's a model that could potentially,
01:08:57,491 -- 01:08:59,627
be, you know, exported,
01:08:59,627 -- 01:09:02,029
I guess, to other, other parts of the country.
01:09:02,029 -- 01:09:03,998
So, you know, it's a role that we can play.
01:09:03,998 -- 01:09:06,467
And I know that my team works together very closely.
01:09:07,568 -- 01:09:09,370
in, in the provinces, you know, obviously
01:09:09,370 -- 01:09:11,038
they cover their respective jurisdictions,
01:09:11,038 -- 01:09:12,940
whether it's Saskatchewan and New Brunswick or B.C.
01:09:12,940 -- 01:09:14,942
or Ontario.
01:09:14,942 -- 01:09:16,043
But when there is something
01:09:16,043 -- 01:09:17,845
that works in one province, there's no,
01:09:17,845 -- 01:09:20,181
no reason that it shouldn't work in another.
01:09:20,181 -- 01:09:21,115
And, you know, that's a
01:09:21,115 -- 01:09:22,049
that's an important part of the role
01:09:22,049 -- 01:09:23,317
that we play and, you know,
01:09:23,317 -- 01:09:25,452
helping to pitch those ideas,
01:09:25,452 -- 01:09:29,190
across the country to governments and regulators.
01:09:29,190 -- 01:09:29,590
All right.
01:09:29,590 -- 01:09:33,427
We'll try to give some more time to other questions.
01:09:33,427 -- 01:09:35,763
Hopefully the font is bigger this time.
01:09:35,763 -- 01:09:37,631
Okay. Yeah, it's the same size.
01:09:37,631 -- 01:09:40,634
Can somebody please read that? Okay, sure.
01:09:40,634 -- 01:09:41,335
How does
01:09:41,335 -- 01:09:42,536
how does the panel
01:09:42,536 -- 01:09:45,206
perceive the long term future of small
01:09:45,206 -- 01:09:47,942
to mid-sized community Credit Unions,
01:09:47,942 -- 01:09:50,044
giving the likes of technology,
01:09:50,044 -- 01:09:52,980
technological disruptions like AI,
01:09:52,980 -- 01:09:54,214
open banking,
01:09:54,214 -- 01:09:58,085
where larger Credit Unions and banks can afford to invest?
01:09:59,119 -- 01:10:01,088
So I can start this one and tell you
01:10:01,088 -- 01:10:06,060
that larger Credit Unions can't invest on their own either.
01:10:06,460 -- 01:10:08,462
When you talk about large Credit Unions,
01:10:08,462 -- 01:10:11,432
they don't have nearly the money that the banks
01:10:11,432 -- 01:10:13,867
have to invest in these technologies.
01:10:13,867 -- 01:10:18,305
And so the larger Credit Unions are actually cooperating,
01:10:18,305 -- 01:10:21,508
across the country in, in looking at right now,
01:10:21,508 -- 01:10:23,110
not AI in open banking,
01:10:23,110 -- 01:10:25,346
but through the payment modernization.
01:10:25,346 -- 01:10:26,914
And
01:10:26,914 -- 01:10:30,918
so I think it, it will require cooperation.
01:10:30,918 -- 01:10:33,220
And to me, the future of small
01:10:33,220 -- 01:10:35,989
and mid-sized community Credit Unions
01:10:35,989 -- 01:10:37,958
again, requires cooperation.
01:10:37,958 -- 01:10:40,360
We need to have joint services
01:10:40,360 -- 01:10:43,597
and build these technologies together.
01:10:43,597 -- 01:10:44,364
Otherwise
01:10:44,364 -- 01:10:49,369
none of us are going to be able to provide the services.
01:10:51,572 -- 01:10:54,208
Any other perspectives?
01:10:54,208 -- 01:10:55,576
But,
01:10:55,576 -- 01:10:58,512
you know, again, I will, just add to what Jackie said,
01:11:00,747 -- 01:11:01,148
I mean, at
01:11:01,148 -- 01:11:02,049
one point
01:11:02,049 -- 01:11:04,017
in time, many, many decades,
01:11:04,017 -- 01:11:06,453
there was about 1,000 Credit Unions in Ontario.
01:11:06,453 -- 01:11:09,723
And I think I heard this morning there's 58.
01:11:09,723 -- 01:11:12,459
So consolidation has been a part of,
01:11:12,459 -- 01:11:14,528
let's say, this Credit Union system for
01:11:14,528 -- 01:11:17,197
well over 30 years now.
01:11:17,197 -- 01:11:20,467
Is technology, you know, what's driving consolidation?
01:11:20,467 -- 01:11:22,169
Maybe it is.
01:11:22,169 -- 01:11:24,438
But I would say and I said earlier,
01:11:24,438 -- 01:11:25,906
I think the business world and,
01:11:25,906 -- 01:11:26,707
and the,
01:11:26,707 -- 01:11:27,641
the business models
01:11:27,641 -- 01:11:30,277
are changing and Credit Unions need to change with it
01:11:30,277 -- 01:11:32,980
in order for them to not only just survive but thrive.
01:11:32,980 -- 01:11:37,951
So I do feel that, it's going to be harder as,
01:11:39,186 -- 01:11:39,920
for smaller
01:11:39,920 -- 01:11:42,089
mid-sized Credit Unions to continue to invest in
01:11:42,089 -- 01:11:43,790
what is required to serve their members.
01:11:43,790 -- 01:11:45,158
But I think we,
01:11:45,158 -- 01:11:46,560
we heard this morning from
01:11:46,560 -- 01:11:49,329
I think it was Mark White who, who commented that, you know,
01:11:49,329 -- 01:11:52,232
there are certain small Credit Unions that can stay
01:11:52,232 -- 01:11:54,735
and thrive for their members forever.
01:11:54,735 -- 01:11:56,136
It all depends on your membership
01:11:56,136 -- 01:11:58,105
and what they're looking for.
01:11:58,105 -- 01:12:00,073
I think the reference to community Credit Union means,
01:12:00,073 -- 01:12:00,807
you know, it's
01:12:00,807 -- 01:12:02,075
obviously a little bit more challenging,
01:12:02,075 -- 01:12:03,710
I would say, because,
01:12:03,710 -- 01:12:05,112
those members have choices,
01:12:05,112 -- 01:12:06,780
as I said in my comments as well,
01:12:06,780 -- 01:12:09,616
there's so many choices that members have today
01:12:09,616 -- 01:12:11,585
to how they want to do business. So,
01:12:12,686 -- 01:12:15,822
again, cooperation and working together shared services.
01:12:15,822 -- 01:12:17,724
You heard me say that earlier.
01:12:17,724 -- 01:12:19,259
I do feel that's what's required
01:12:19,259 -- 01:12:22,029
for us to sort of, work together and,
01:12:22,029 -- 01:12:24,064
and support the small, medium sized Credit Unions.
01:12:24,064 -- 01:12:25,032
But,
01:12:25,032 -- 01:12:26,900
I would also say that just, you know,
01:12:26,900 -- 01:12:28,235
looking at the history,
01:12:28,235 -- 01:12:29,603
there's been a lot of consolidation.
01:12:29,603 -- 01:12:33,173
And I think it's because, you know, it is difficult as,
01:12:33,173 -- 01:12:33,940
things have changed
01:12:33,940 -- 01:12:36,009
and technology is definitely changing
01:12:36,009 -- 01:12:37,244
how business is being done.
01:12:37,244 -- 01:12:37,544
And that's
01:12:37,544 -- 01:12:42,549
putting a lot of cost pressures on Credit Unions.
01:12:42,849 -- 01:12:44,451
Thank you.
01:12:44,451 -- 01:12:46,620
I don't, let's see if there's another.
01:12:46,620 -- 01:12:51,625
The font got bigger so I can read it.
01:12:53,727 -- 01:12:54,728
That's the same question.
01:12:54,728 -- 01:12:55,128
Yeah.
01:12:55,128 -- 01:13:00,100
Is there another, a third question.
01:13:00,400 -- 01:13:02,669
Not yet.
01:13:02,669 -- 01:13:03,970
There's got to be a third question.
01:13:03,970 -- 01:13:05,438
Come on. I think we answered everything.
01:13:06,940 -- 01:13:08,408
Nobody has any questions.
01:13:08,408 -- 01:13:13,413
You can get up and say it if you like.
01:13:14,447 -- 01:13:15,015
You okay?
01:13:15,015 -- 01:13:18,051
You’ve asked questions. I just go through my...
01:13:18,051 -- 01:13:21,454
Please stand up and ask.
01:13:21,454 -- 01:13:23,857
...My question is how to
01:13:23,857 -- 01:13:24,257
Opinion.
01:13:24,257 -- 01:13:29,262
[unintelligble]...Board members are qualified
01:13:29,396 -- 01:13:42,342
[unintelligble]
01:13:42,342 -- 01:13:45,512
[unintelligble]
01:13:45,512 -- 01:13:49,215
I’m wondering, how do you deal with that?
01:13:49,215 -- 01:13:52,752
Okay, so it is a challenge.
01:13:52,752 -- 01:13:57,190
And we have a similar challenge, at Libro as well,
01:13:57,190 -- 01:13:59,626
because we're trying to track
01:13:59,626 -- 01:14:02,395
who have the expertise and the experience.
01:14:02,395 -- 01:14:05,131
I think one of the things that, we can do
01:14:05,131 -- 01:14:08,835
is to use the training that's provided,
01:14:08,835 -- 01:14:11,204
and I actually met a gentleman
01:14:11,204 -- 01:14:13,807
at a conference who had done their [unintelligble]
01:14:13,807 -- 01:14:17,277
training before they even got on to the Board.
01:14:17,277 -- 01:14:20,547
So I think that would be something that I would encourage
01:14:20,547 -- 01:14:23,950
is, is to have people thinking about it beforehand.
01:14:23,950 -- 01:14:26,920
But the other piece of it is through technology
01:14:26,920 -- 01:14:30,490
and through the video conferencing that we've had.
01:14:30,490 -- 01:14:33,093
You don't actually have to be limited
01:14:33,093 -- 01:14:35,862
to the community in which you operate.
01:14:35,862 -- 01:14:39,332
So we're hoping that, some of the, the,
01:14:39,332 -- 01:14:41,968
some of the stretch can be a little bit broader
01:14:41,968 -- 01:14:44,337
when it comes to getting those, people
01:14:44,337 -- 01:14:45,738
with good governance.
01:14:45,738 -- 01:14:48,908
And a lot of it, unfortunately, is training them up,
01:14:49,876 -- 01:14:54,881
and very quickly as well, which is a bit of a challenge.
01:14:55,748 -- 01:14:57,550
and it's an ongoing issue.
01:14:57,550 -- 01:14:58,551
Definitely.
01:14:58,551 -- 01:15:03,556
The, the main challenge, to be honest, is not the,
01:15:03,857 -- 01:15:06,659
helping them to understand what their role is versus
01:15:06,659 -- 01:15:09,662
what their role isn't. I think is the biggest problem.
01:15:09,662 -- 01:15:11,831
They think, they think they're going to be able
01:15:11,831 -- 01:15:14,934
to come in as customers and,
01:15:14,934 -- 01:15:15,768
you know, change
01:15:15,768 -- 01:15:16,669
service charges
01:15:16,669 -- 01:15:19,105
or, you know, give people loans or,
01:15:19,105 -- 01:15:22,308
you know, they come in with a very operational mindset.
01:15:22,308 -- 01:15:26,646
That's the mindset that's the hardest to get rid of.
01:15:26,646 -- 01:15:26,980
Thank you,
01:15:26,980 -- 01:15:28,548
Jacquie. I see another question that's come up here.
01:15:28,548 -- 01:15:30,016
It's about resources.
01:15:30,016 -- 01:15:31,584
What resources
01:15:31,584 -- 01:15:34,254
would you suggest for Board Directors
01:15:34,254 -- 01:15:35,288
who want to come up to speed
01:15:35,288 -- 01:15:37,123
with the challenges that we've talked about,
01:15:37,123 -- 01:15:39,826
and also about long term strategic planning?
01:15:39,826 -- 01:15:42,395
So we have a short amount of time,
01:15:42,395 -- 01:15:43,763
couple of minutes, maybe we can start that.
01:15:43,763 -- 01:15:45,164
But I suggest,
01:15:45,164 -- 01:15:47,066
if you can contact us at FSRA,
01:15:47,066 -- 01:15:49,135
we can talk to the panel members as well.
01:15:49,135 -- 01:15:52,238
And if we can gather maybe some of those resources,
01:15:52,238 -- 01:15:54,073
there might be some links that we can gather for you,
01:15:54,073 -- 01:15:55,508
and then we can send that to you.
01:15:55,508 -- 01:15:56,609
That might,
01:15:56,609 -- 01:15:57,877
satisfy
01:15:57,877 -- 01:16:00,146
your question here better than just a minute up here.
01:16:00,146 -- 01:16:02,915
But does anybody have any ideas at the moment?
01:16:02,915 -- 01:16:05,318
ICD, CCUA,
01:16:06,519 -- 01:16:11,090
Google.
01:16:11,090 -- 01:16:14,494
What Jacquie said.
01:16:14,494 -- 01:16:16,529
Chris, Lloyd?
01:16:16,529 -- 01:16:17,463
No, I again,
01:16:17,463 -- 01:16:18,531
I had the same kind of thoughts
01:16:18,531 -- 01:16:21,501
around the CCUA as an information source.
01:16:21,501 -- 01:16:22,735
And, obviously,
01:16:22,735 -- 01:16:24,237
I think a lot of Directors now
01:16:24,237 -- 01:16:27,840
are embarking on their ICD certifications.
01:16:27,840 -- 01:16:29,776
I think it's really just designed to sort of support
01:16:29,776 -- 01:16:31,811
you as Directors.
01:16:31,811 -- 01:16:33,579
As, again, the business model for Credit
01:16:33,579 -- 01:16:35,381
Unions is definitely getting more complex.
01:16:35,381 -- 01:16:36,582
So,
01:16:36,582 -- 01:16:39,552
supportive work with CCUA and ICD
01:16:39,552 -- 01:16:42,455
would be excellent for you.
01:16:42,455 -- 01:16:44,824
Right. Thank you.
01:16:44,824 -- 01:16:47,059
All right. We're just exactly on time.
01:16:47,059 -- 01:16:48,728
So we'll put up the last slide.
01:16:48,728 -- 01:16:52,098
And I think it's called, Wrap up.
01:16:52,098 -- 01:16:55,234
Do I need to push something?
01:16:55,234 -- 01:16:57,937
All right. Magic.
01:16:57,937 -- 01:16:58,371
All right.
01:16:58,371 -- 01:17:02,942
So this is called wrap up, but it's not really a wrap up.
01:17:02,942 -- 01:17:07,246
The point of this panel and this session was to
01:17:07,246 -- 01:17:11,717
I can't say, that the discussion and dialog started because,
01:17:11,717 -- 01:17:12,652
you can talk to Chris.
01:17:12,652 -- 01:17:15,755
This has been going on for decades, as it should.
01:17:15,755 -- 01:17:17,890
But there are certain things in the environment
01:17:17,890 -- 01:17:21,661
that are exaggerating and exacerbating the situation.
01:17:21,661 -- 01:17:25,298
So we do need some, as I've said, some sector led
01:17:25,298 -- 01:17:27,433
and sector solutions,
01:17:27,433 -- 01:17:27,934
worked out
01:17:27,934 -- 01:17:31,103
very soon for this sector to be long term viable
01:17:31,103 -- 01:17:33,205
for the foreseeable future.
01:17:33,205 -- 01:17:35,341
so, from FSRA’s perspective,
01:17:35,341 -- 01:17:37,376
we think it's very important, as you've heard,
01:17:37,376 -- 01:17:40,479
for, not just senior management to be involved,
01:17:40,479 -- 01:17:42,114
but for the Boards to be involved as well.
01:17:42,114 -- 01:17:46,319
And as Jackie said, for Boards to talk to other Boards,
01:17:46,319 -- 01:17:47,420
Senior management already do that.
01:17:47,420 -- 01:17:48,187
They talk to each other.
01:17:48,187 -- 01:17:49,989
But for Boards to talk to other Boards,
01:17:49,989 -- 01:17:52,858
because we do need a sector strategy
01:17:52,858 -- 01:17:54,527
and a sector solution going forward.
01:17:55,628 -- 01:17:59,565
And at FSRA, as, as it says here,
01:17:59,565 -- 01:18:03,602
we are very interested in working with you, Credit Unions
01:18:03,602 -- 01:18:04,437
to do what we can,
01:18:04,437 -- 01:18:07,006
given our legislative and mandate constraints,
01:18:07,006 -- 01:18:08,140
because we do those certain things
01:18:08,140 -- 01:18:09,809
we can do and other things we can.
01:18:09,809 -- 01:18:11,811
But given that we can do certain things,
01:18:11,811 -- 01:18:14,847
we would like to work with you on those proposed solutions,
01:18:14,847 -- 01:18:17,049
to implement them, to make them work.
01:18:17,049 -- 01:18:21,720
And so we're very interested in that work.
01:18:21,720 -- 01:18:24,056
I just wanted to thank a few people
01:18:24,056 -- 01:18:26,592
before we head off to reception,
01:18:26,592 -- 01:18:28,527
which I think is just going to be out here.
01:18:28,527 -- 01:18:33,199
So, Jacquie, Chris, Michael and Lloyd, thank you very much.
01:18:33,199 -- 01:18:38,204
That was a fantastic panel.
01:18:39,772 -- 01:18:40,306
As well,
01:18:40,306 -- 01:18:42,441
there were some other people, my FSRA colleagues,
01:18:42,441 -- 01:18:45,578
that were working on this to prepare us for this session.
01:18:46,912 -- 01:18:48,848
Where is Doug Macdonald?
01:18:48,848 -- 01:18:51,784
I saw him. Oh, Doug Macdonald is right there.
01:18:51,784 -- 01:18:54,420
Dan Oprescu is over there.
01:18:54,420 -- 01:18:55,387
David Maxwell.
01:18:55,387 -- 01:18:58,357
He's... at the back of the room.
01:18:58,357 -- 01:19:01,026
David Maxwell back there making sure everything goes well.
01:19:01,026 -- 01:19:02,928
So he's our Head of Regulation.
01:19:02,928 -- 01:19:04,897
Dan is our Head of Supervision,
01:19:04,897 -- 01:19:08,934
and Steve Kokaliaris who is our Director of Approvals.
01:19:08,934 -- 01:19:11,003
They were all very closely involved with panel
01:19:11,003 -- 01:19:12,271
and setting up this session.
01:19:12,271 -- 01:19:16,709
So thank you very much and see you all at reception.
01:19:16,709 -- 01:19:19,478
Thank you.
00:00:04,966 -- 00:00:06,366
Good afternoon, everyone.
00:00:06,366 -- 00:00:08,533
Welcome to the Pension break-up session.
00:00:08,533 -- 00:00:12,166
It's great to see everyone in person today.
00:00:12,166 -- 00:00:15,533
So just a few housekeeping items.
00:00:15,533 -- 00:00:18,000
So, today’s session is taped
00:00:18,000 -- 00:00:21,366
and we also have a French translation.
00:00:21,366 -- 00:00:23,266
So whoever needs
00:00:23,266 -- 00:00:24,400
French translation just raise their hands
00:00:24,400 -- 00:00:26,600
we have headsets available in this room.
00:00:26,600 -- 00:00:28,833
And for those joining us online,
00:00:28,833 -- 00:00:34,133
I was told that you can click on some button
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you can click on your initials.
00:00:35,300 -- 00:00:36,400
I was told,
00:00:36,400 -- 00:00:40,700
and then that you can do your language translation there.
00:00:40,700 -- 00:00:43,966
So we are truly a hybrid kind of platform.
00:00:43,966 -- 00:00:45,566
So to
00:00:45,566 -- 00:00:46,966
to get true spirit to it,
00:00:46,966 -- 00:00:48,500
we actually launching
00:00:48,500 -- 00:00:52,400
and using a platform called Chime to take questions.
00:00:52,400 -- 00:00:54,233
So we want to give the equal experience
00:00:54,233 -- 00:00:57,900
to both people in the room as well as people online as well too.
00:00:57,900 -- 00:01:00,966
So please do submit your questions through Chime.
00:01:00,966 -- 00:01:04,433
We have a question period at the end of the sessions.
00:01:04,433 -- 00:01:08,400
And if you have for some reasons and those in the room trouble
00:01:08,400 -- 00:01:11,666
entering the questions, please raise your hand.
00:01:11,666 -- 00:01:13,233
Somebody will be there to help you.
00:01:14,366 -- 00:01:16,900
So before I actually launch into the session,
00:01:16,900 -- 00:01:18,500
I want to do a little commercial.
00:01:18,500 -- 00:01:21,233
You've heard about the success of Pension Awareness Day.
00:01:21,233 -- 00:01:22,766
I want to take this opportunity
00:01:22,766 -- 00:01:27,633
to thank the entire sector for providing us with that support.
00:01:27,633 -- 00:01:30,433
The collaboration there is exemplary
00:01:30,433 -- 00:01:33,600
and in fact, we actually have a lot of questions now
00:01:33,600 -- 00:01:37,100
about how to get involved even more next year.
00:01:37,100 -- 00:01:39,733
It is our hope that every day from this day on
00:01:39,733 -- 00:01:42,333
would be Pension Awareness Day. That's my hope.
00:01:42,333 -- 00:01:45,100
Officially it is the third
00:01:45,100 -- 00:01:47,766
Thursday of every February of every year.
00:01:47,766 -- 00:01:50,266
And we want to make it a grassroot event
00:01:50,266 -- 00:01:53,300
that everyone will be able to participate in and talk about it
00:01:53,300 -- 00:01:54,333
and they'll take
00:01:54,333 -- 00:01:56,233
complete comfort in that
00:01:56,233 -- 00:02:00,400
we will get there and we actually even have other jurisdictions
00:02:00,400 -- 00:02:03,166
call me and say, “How do we do it?” How do we get on board?”
00:02:03,166 -- 00:02:04,466
So it is a great success
00:02:04,466 -- 00:02:06,366
and kudos to our Public Affairs team
00:02:06,366 -- 00:02:10,766
who have made me look really good. So thank you for that.
00:02:10,766 -- 00:02:17,300
So nice segue to our session today is all about PBR - Pension
00:02:17,300 -- 00:02:22,000
Benefits Regulation. No, it's about principles-based regulations.
00:02:24,866 -- 00:02:27,033
FSRA is a principles-based,
00:02:27,033 -- 00:02:29,366
risk based, outcome focused regulator.
00:02:29,366 -- 00:02:32,500
I'm sure you've heard a lot about that.
00:02:32,500 -- 00:02:36,400
I've been hearing about that since day one of FSRA launch.
00:02:36,400 -- 00:02:37,733
But what exactly is it?
00:02:37,733 -- 00:02:39,166
What does it mean?
00:02:39,166 -- 00:02:42,300
Joanne shared this morning talked about,
00:02:42,300 -- 00:02:44,533
there are some sentiment around,
00:02:44,533 -- 00:02:44,800
you know,
00:02:44,800 -- 00:02:47,300
concerns or maybe misunderstanding
00:02:47,300 -- 00:02:51,467
about exactly how this would be implemented through the sectors.
00:02:51,467 -- 00:02:53,867
I've been with FSCO / FSRA,
00:02:53,867 -- 00:02:57,967
for coming up six years. Believe it or not,
00:02:57,967 -- 00:03:03,367
the two most commonly heard comments are: at one end.
00:03:03,367 -- 00:03:06,967
It is. Well, there's so much ambiguity.
00:03:06,967 -- 00:03:08,867
How can I comply? You have no checklists.
00:03:08,867 -- 00:03:09,967
How can I comply?
00:03:09,967 -- 00:03:12,733
To the other end, as well,
00:03:12,733 -- 00:03:14,100
you guys are principles-based
00:03:14,100 -- 00:03:16,233
and you kind of ignore this, you know?
00:03:16,233 -- 00:03:20,100
So those are the two kind of goal poles that I kind of experience
00:03:20,100 -- 00:03:23,267
during my last few years as a Regulator.
00:03:23,267 -- 00:03:28,867
So our session today is exactly about demystifying what PBR
00:03:28,867 -- 00:03:30,000
means for pensions.
00:03:31,233 -- 00:03:33,400
It’s more than a few catchy phrases.
00:03:33,400 -- 00:03:36,200
I'm hoping that through our panel here
00:03:36,200 -- 00:03:37,267
to tell you a little bit
00:03:37,267 -- 00:03:40,567
of how we apply PBR in our day-to-day work.
00:03:40,567 -- 00:03:43,567
It will demystify for you what PBR actually means.
00:03:43,567 -- 00:03:47,767
So at its core, PBR is about collaboration,
00:03:47,767 -- 00:03:50,067
about shared understanding and commitment.
00:03:50,067 -- 00:03:54,100
It’s about, it's not about, it’s more than just about having rules
00:03:54,100 -- 00:03:58,900
that are principles-based, but it's also not about ignoring law.
00:03:58,900 -- 00:04:02,700
So without further ado, I want to introduce my panel
00:04:02,700 -- 00:04:07,433
who are all my colleagues from FSRA’s Pensions team,
00:04:07,433 -- 00:04:09,367
to my
00:04:09,367 -- 00:04:11,633
right, I mean, actually, but I can’t tell you from left to right,
00:04:11,633 -- 00:04:13,600
it's Reesha Hosein.
00:04:13,600 -- 00:04:18,633
She's the Director of Legal Services and Deputy General Counsel
00:04:18,633 -- 00:04:23,300
to the right of Reesha is James Hoffner, Chief Prudential
00:04:23,300 -- 00:04:25,767
Supervision Officer for large public sector,
00:04:25,767 -- 00:04:27,233
pension plans
00:04:27,233 -- 00:04:28,867
and the far right is Paul
00:04:28,867 -- 00:04:31,100
Martiniello, Director of Prudential Supervision,
00:04:31,100 -- 00:04:32,700
mostly for single-employer pension
00:04:32,700 -- 00:04:35,367
plans and multi-employer pension plans.
00:04:35,367 -- 00:04:37,700
To my left is Claire Woodcock.
00:04:37,700 -- 00:04:40,633
She is the Director of Pension Plan Operations
00:04:40,633 -- 00:04:45,000
and to the far left is Trevor Cartlidge, Deputy Chief Actuary
00:04:45,000 -- 00:04:47,633
and my name is Andrew Fung, acting
00:04:47,633 -- 00:04:50,933
EVP of FSRA and I will moderate the session today.
00:04:51,900 -- 00:04:52,900
So,
00:04:52,900 -- 00:04:58,800
without further ado, let me just start off with perhaps Reesha.
00:04:58,967 -- 00:05:01,033
We have a draft
00:05:01,033 -- 00:05:01,700
fiscal based
00:05:01,700 -- 00:05:07,600
regulation approach guidance that we consulted on in 2022.
00:05:07,700 -- 00:05:11,467
Can you give us a little bit of background about that guidance
00:05:11,467 -- 00:05:13,133
and share at the very high level
00:05:13,133 -- 00:05:18,200
a little bit about the comments that we have received so far?
00:05:18,200 -- 00:05:20,467
So, I think I'm going to start with that.
00:05:20,467 -- 00:05:24,300
Oh, by the way, so nice to see so many familiar faces.
00:05:24,300 -- 00:05:27,933
Thanks so much for joining us today and nice to see new faces,
00:05:27,933 -- 00:05:30,400
it's really great to be able to meet you.
00:05:30,400 -- 00:05:32,000
Thank you for the invitation
00:05:32,000 -- 00:05:34,267
to talk about principles-based regulation.
00:05:34,267 -- 00:05:38,534
So what I'm going to start off with is just a description of why
00:05:38,534 -- 00:05:39,834
principles-based regulation.
00:05:39,834 -- 00:05:42,500
We've been hearing a lot about it today.
00:05:42,500 -- 00:05:44,334
So as many of you know,
00:05:44,334 -- 00:05:46,067
before FSRA was created,
00:05:46,067 -- 00:05:48,034
there was an expert panel
00:05:48,034 -- 00:05:50,600
that was established to look at the mandates
00:05:50,600 -- 00:05:53,034
of both FSCO and DICO.
00:05:53,034 -- 00:05:54,200
And what they concluded
00:05:54,200 -- 00:05:55,534
is, as many of you are familiar
00:05:55,534 -- 00:05:56,800
with, hopefully,
00:05:56,800 -- 00:05:58,800
is that due to the quickly
00:05:58,800 -- 00:06:01,567
changing nature of financial services regulation,
00:06:01,567 -- 00:06:03,700
which we heard a lot about this morning,
00:06:03,700 -- 00:06:06,300
there was a need for an innovative,
00:06:06,300 -- 00:06:10,434
flexible, adaptive and responsive regulator.
00:06:10,434 -- 00:06:14,900
So an essential tool, this was their recommendation,
00:06:14,900 -- 00:06:16,800
in supporting this approach
00:06:16,800 -- 00:06:20,300
is the principles-based approach to regulation.
00:06:20,300 -- 00:06:21,267
By this,
00:06:21,267 -- 00:06:25,567
it means that FSRA will look to high level principles
00:06:25,567 -- 00:06:28,434
to guide our regulatory actions.
00:06:28,434 -- 00:06:30,200
So let me just start with a quick definition,
00:06:30,200 -- 00:06:31,934
and I know I'm going to sound like a total lawyer
00:06:31,934 -- 00:06:34,367
by starting with a definition, but,
00:06:34,367 -- 00:06:37,800
so let's talk about what is principles-based regulation,
00:06:37,800 -- 00:06:39,134
the classic example
00:06:39,134 -- 00:06:42,734
that’s used to demonstrate between a principles-based
00:06:42,734 -- 00:06:45,200
and a prescriptive approach to regulation
00:06:45,200 -- 00:06:48,400
is the highway traffic rule example.
00:06:48,400 -- 00:06:51,567
So in a prescriptive framework, you can go on to the highway
00:06:51,567 -- 00:06:54,134
and there is a clearly posted speed limit
00:06:54,134 -- 00:06:57,767
and you may not travel faster than a 100 kilometers an hour.
00:06:57,767 -- 00:07:01,600
Right? We’re all relatively familiar with all that.
00:07:01,600 -- 00:07:03,800
In a principles-based environment,
00:07:03,800 -- 00:07:07,000
the speed limit would be stated in a different way,
00:07:07,000 -- 00:07:11,500
looking at the outcomes that we are all trying to achieve,
00:07:11,500 -- 00:07:13,734
which is safe travel on a highway.
00:07:13,734 -- 00:07:18,967
So the rule or the requirement on the highway would be
00:07:18,967 -- 00:07:20,134
do not travel
00:07:20,134 -- 00:07:24,567
more than is reason, at a speed that is faster than is reasonable
00:07:24,567 -- 00:07:26,300
and prudent in the circumstances.
00:07:26,300 -- 00:07:30,500
So as many of us, because we are in Toronto, are familiar,
00:07:30,500 -- 00:07:31,900
when you're driving on the highway
00:07:31,900 -- 00:07:35,034
and they're conditions with black ice, you would be traveling
00:07:35,034 -- 00:07:38,800
perhaps 40 or 50 kilometers an hour, depending on the traffic.
00:07:38,800 -- 00:07:43,700
On clear day your car's well-tuned, gas in the tank,
00:07:45,200 -- 00:07:47,034
very little traffic you might,
00:07:47,034 -- 00:07:48,500
and I'm not encouraging you,
00:07:48,500 -- 00:07:50,900
to go a slightly above the speed limit.
00:07:50,900 -- 00:07:52,967
Perhaps you would say that
00:07:52,967 -- 00:07:54,634
120 kilometers an hour
00:07:54,634 -- 00:07:57,034
would be very reasonable in the circumstances.
00:07:57,034 -- 00:07:58,900
So that's the out...
00:07:58,900 -- 00:08:02,000
So what we're trying to focus on as Andrew,
00:08:02,000 -- 00:08:04,534
I think Mark mentioned this morning is focusing
00:08:04,534 -- 00:08:07,534
on the outcomes that we're trying to achieve.
00:08:07,534 -- 00:08:09,200
So
00:08:09,200 -- 00:08:12,500
you may ask, what are those outcomes?
00:08:12,500 -- 00:08:16,700
What we look to as a regulator are our statutory objects.
00:08:16,700 -- 00:08:20,234
You've been hearing a lot about that, but for the pension sector,
00:08:20,234 -- 00:08:24,767
it's the protection of plan, the rights and interests,
00:08:24,767 -- 00:08:26,134
rights and benefits.
00:08:26,134 -- 00:08:26,701
You'll forgive me.
00:08:26,701 -- 00:08:29,534
I should know this off the top of my head of plan beneficiaries
00:08:29,534 -- 00:08:32,434
as well as the good administration of pension plans.
00:08:32,434 -- 00:08:34,434
So these are the two key things
00:08:34,434 -- 00:08:37,401
as well as the other objects for financial services
00:08:37,401 -- 00:08:39,734
that will guide us in the way that we regulate
00:08:39,734 -- 00:08:40,767
the pension sector.
00:08:42,467 -- 00:08:46,734
So I would also say as legal director,
00:08:46,734 -- 00:08:47,434
the PBA,
00:08:47,434 -- 00:08:50,101
as many of you know and some of you have complained
00:08:50,101 -- 00:08:53,167
about, is a very prescriptive statute.
00:08:53,167 -- 00:08:54,567
So what we're trying to do
00:08:54,567 -- 00:08:58,567
and what we are doing in many cases, whether you see it
00:08:58,567 -- 00:09:00,967
clearly in our guidance or behind the scenes
00:09:00,967 -- 00:09:02,234
or even when you're talking
00:09:02,234 -- 00:09:07,101
with a pension officer or Claire or Paul or James
00:09:07,101 -- 00:09:10,134
is looking to an interpretation that supports
00:09:10,134 -- 00:09:12,967
the outcomes that we are trying to achieve.
00:09:12,967 -- 00:09:15,967
And it is a broad, purposive approach
00:09:15,967 -- 00:09:19,034
to regulation, sorry, to statutory interpretation.
00:09:19,034 -- 00:09:21,701
Now this is not a new concept.
00:09:21,701 -- 00:09:24,501
Many of you who went to law school with me
00:09:24,501 -- 00:09:27,067
just a couple of years ago
00:09:27,067 -- 00:09:29,901
would say that a broad purpose of approach
00:09:29,901 -- 00:09:33,001
to statutory interpretation is not new.
00:09:33,001 -- 00:09:34,401
What is new
00:09:34,401 -- 00:09:36,201
is the case law, administrative
00:09:36,201 -- 00:09:39,801
law, case law that talks a bit about what
00:09:39,801 -- 00:09:43,067
that framework for interpretation should be.
00:09:43,067 -- 00:09:45,634
So I would encourage lawyers in the room
00:09:45,634 -- 00:09:47,367
to look at the Vavilov case law,
00:09:47,367 -- 00:09:49,467
and there is a clear link
00:09:49,467 -- 00:09:52,501
to a rational connection to the statutory objects.
00:09:52,501 -- 00:09:54,701
It is not anything goes,
00:09:54,701 -- 00:09:58,001
but we will be guided by our statutory objects.
00:09:58,001 -- 00:09:59,034
So that's
00:09:59,034 -- 00:10:02,701
what we're doing and the outcomes that we're hoping to achieve
00:10:02,701 -- 00:10:05,534
is what I'd like to talk about a little bit next.
00:10:05,534 -- 00:10:10,701
So you heard today also that we're an outcomes focused regulator
00:10:10,701 -- 00:10:12,901
where do we get those outcomes?
00:10:12,901 -- 00:10:15,667
We get those outcomes by identifying
00:10:15,667 -- 00:10:17,967
with our expertise as the regulator.
00:10:17,967 -- 00:10:22,434
What are the problems that we see as we attempt to solve them?
00:10:22,434 -- 00:10:23,967
There's an opportunity
00:10:23,967 -- 00:10:27,901
in many circumstances for you to provide your feedback
00:10:27,901 -- 00:10:30,801
about what you think the desired outcomes should be.
00:10:30,801 -- 00:10:32,434
For an expert regulator
00:10:32,434 -- 00:10:35,134
that would be in guidance,
00:10:35,134 -- 00:10:39,067
the consultation process, or the consultation process with rules
00:10:39,067 -- 00:10:42,434
or even speaking to the pension officer
00:10:42,434 -- 00:10:44,467
that is reviewing your plan amendment
00:10:44,467 -- 00:10:47,134
or dealing with you on a transaction
00:10:47,134 -- 00:10:49,801
or with respect to potentially a member complaint.
00:10:50,834 -- 00:10:53,367
So I think I'm probably running out of time,
00:10:53,367 -- 00:10:56,301
but I'll quickly say the other important thing
00:10:56,301 -- 00:10:59,767
to think about is how we are regulating you.
00:10:59,767 -- 00:11:04,667
And that's what Andrew described as our principles,
00:11:04,667 -- 00:11:08,401
the guidance on principles for the pension sector.
00:11:08,401 -- 00:11:10,934
That's going to be rolled out into a new guidance
00:11:10,934 -- 00:11:14,268
that's likely going to be issued in the spring that talks about
00:11:14,268 -- 00:11:18,201
how we will regulate the sectors and what you can expect.
00:11:18,201 -- 00:11:19,968
You can expect us to be.
00:11:19,968 -- 00:11:22,234
And these are, I'm not going to go through the
00:11:22,234 -- 00:11:23,834
all of the guidance principles,
00:11:23,834 -- 00:11:25,134
but the key concepts
00:11:25,134 -- 00:11:28,034
I think for this audience would be
00:11:28,034 -- 00:11:31,868
that we're going to be risk based, we're going to be transparent,
00:11:31,868 -- 00:11:35,901
we're going to be collaborative as we try to identify
00:11:35,901 -- 00:11:39,834
the best approach to solving the difficult regulatory problems
00:11:39,834 -- 00:11:41,568
that we're faced with as a regulator.
00:11:44,401 -- 00:11:46,201
And that's pretty much it for me.
00:11:46,201 -- 00:11:49,001
Andrew, Thank you, Reesha.
00:11:49,001 -- 00:11:54,001
So this is a very helpful overview to frame our discussions.
00:11:54,001 -- 00:11:58,768
So PBR certainly doesn't mean that we disregard the law,
00:11:58,768 -- 00:12:00,801
but I think it requires the pension plans
00:12:00,801 -- 00:12:04,734
we regulate in administrating its requirements.
00:12:04,734 -- 00:12:06,068
We kind of take it up
00:12:06,068 -- 00:12:10,034
one notch higher by also considering the purpose
00:12:10,034 -- 00:12:12,001
and our objects, quite a deviation
00:12:12,001 -- 00:12:14,434
from the previous administration,
00:12:14,434 -- 00:12:18,034
so ambiguous it might be - think flexibility.
00:12:18,034 -- 00:12:21,268
Those two initials A&F is very dear to me.
00:12:21,268 -- 00:12:24,001
Andrew Fung, ambiguous flexibility.
00:12:24,001 -- 00:12:27,268
So think flexibility when you think about ambiguous.
00:12:27,268 -- 00:12:30,201
I think how plan administrators can develop
00:12:30,201 -- 00:12:31,001
their own ways
00:12:31,001 -- 00:12:33,968
to achieve the desired outcomes,
00:12:33,968 -- 00:12:34,901
you know, are best suited
00:12:34,901 -- 00:12:37,901
to each unique circumstances,
00:12:37,901 -- 00:12:41,168
but also take into consideration the purpose of our act.
00:12:41,168 -- 00:12:43,101
But there will be situations
00:12:43,101 -- 00:12:45,401
where we will impose kind of bright line
00:12:46,701 -- 00:12:49,168
requirements to ensure, for example,
00:12:49,168 -- 00:12:52,568
plan beneficiaries are adequately protected.
00:12:52,568 -- 00:12:54,568
Did I get that right Reesha?
00:12:54,568 -- 00:12:57,634
Absolutely, oops sorry.
00:12:57,634 -- 00:13:00,434
Yes, Andrew, I would agree with that.
00:13:00,434 -- 00:13:03,301
There is this concept that it's not unreasonable
00:13:03,301 -- 00:13:05,701
that when we talk about principles-based regulation,
00:13:05,701 -- 00:13:09,034
that there would be an absence of rules.
00:13:09,034 -- 00:13:11,434
So at a high level, that's correct.
00:13:11,434 -- 00:13:15,501
But I would also highlight that we're both a principles-based
00:13:15,501 -- 00:13:17,734
and outcomes focused regulator,
00:13:17,734 -- 00:13:22,368
and the rules are inherent to support the outcome
00:13:22,368 -- 00:13:24,334
that we're hoping to achieve.
00:13:24,334 -- 00:13:26,534
And also, underlie
00:13:26,534 -- 00:13:29,901
the principles that we are setting to establish.
00:13:29,901 -- 00:13:31,668
So there's another highway example,
00:13:31,668 -- 00:13:34,401
if you would permit me for another moment.
00:13:34,401 -- 00:13:35,968
It's the autobahn.
00:13:35,968 -- 00:13:37,134
My colleague Joan Small
00:13:37,134 -- 00:13:39,001
and I have been working a lot on training.
00:13:39,001 -- 00:13:41,268
We've been training internally with FSRA
00:13:41,268 -- 00:13:43,134
and it's interesting
00:13:43,134 -- 00:13:45,868
that there is this, you can drive as fast
00:13:45,868 -- 00:13:47,601
you want on the German autobahn.
00:13:47,601 -- 00:13:50,601
We're all relatively familiar with that concept, right?
00:13:50,601 -- 00:13:53,968
What we're not necessarily as familiar with is
00:13:53,968 -- 00:13:56,068
there are a list of rules
00:13:56,068 -- 00:13:57,501
or requirements
00:13:57,501 -- 00:13:58,701
that underlie
00:13:58,701 -- 00:14:02,301
that broadly based you can drive as fast as you want.
00:14:02,301 -- 00:14:07,435
Things like your you cannot run out of gas on the autobahn.
00:14:08,601 -- 00:14:10,868
Your car has to be well tuned.
00:14:10,868 -- 00:14:12,801
You have to drive on the road conditions.
00:14:12,801 -- 00:14:15,001
I can't remember all of them. I have to apologize.
00:14:15,001 -- 00:14:18,201
But there's a little list of at least five of them.
00:14:18,201 -- 00:14:20,835
And they are well known
00:14:20,835 -- 00:14:22,201
to all the people, particularly
00:14:22,201 -- 00:14:26,835
the Germans, who are driving on the Autobahn all the time.
00:14:26,835 -- 00:14:30,968
So I'd ask you to consider that that a principles-based
00:14:30,968 -- 00:14:33,535
framework is not inconsistent
00:14:33,535 -- 00:14:37,368
in some cases with having bright line rules,
00:14:37,368 -- 00:14:41,235
because one, sometimes rules are required to support
00:14:41,235 -- 00:14:43,701
the achievement of the principle
00:14:43,701 -- 00:14:47,168
and also in some cases we may decide that
00:14:47,168 -- 00:14:49,835
a bright line rule is what is required
00:14:49,835 -- 00:14:52,601
to support our statutory objects.
00:14:52,601 -- 00:14:54,168
Protection of plan beneficiaries
00:14:54,168 -- 00:14:57,168
and good administration of pension plans. So don't be surprised.
00:14:58,501 -- 00:14:59,935
Thank you, Reesha.
00:14:59,935 -- 00:15:05,435
I now want to turn to some real examples as to how we apply PBR
00:15:05,435 -- 00:15:06,101
in our work.
00:15:06,101 -- 00:15:07,868
So, Paul, can you share with us
00:15:07,868 -- 00:15:09,901
how you have been applying PBR
00:15:09,901 -- 00:15:12,501
in your day-to-day work, specifically with the single-employer
00:15:12,501 -- 00:15:14,968
pension plans and the multi-employer pension plans? Yeah.
00:15:14,968 -- 00:15:16,535
Thanks, Andrew, and good afternoon everyone.
00:15:16,535 -- 00:15:19,135
So I'm going to get my acronyms out of the way right away.
00:15:19,135 -- 00:15:22,068
Single-employer pension plans are SEPPS and multi-employer
00:15:22,068 -- 00:15:24,235
pension plans are MEPPS.
00:15:24,235 -- 00:15:30,135
I've had the pleasure of joining FSRA in late 2019 and
00:15:31,168 -- 00:15:33,201
just as we were
00:15:33,201 -- 00:15:35,235
developing our approaches
00:15:35,235 -- 00:15:37,601
to prudential supervision of MEPPS and SEPPS.
00:15:37,601 -- 00:15:38,468
And so
00:15:38,468 -- 00:15:40,901
we were really able to do that and build it on a
00:15:40,901 -- 00:15:44,635
on a PBR foundation, which we have done,
00:15:44,635 -- 00:15:47,901
and of course to support our FSRA objects and
00:15:50,135 -- 00:15:50,535
you know,
00:15:50,535 -- 00:15:52,401
I would say I'm going to say right off the top,
00:15:52,401 -- 00:15:55,468
the feedback we've received in our travels
00:15:55,468 -- 00:15:58,501
over the last several years has been positive.
00:15:58,501 -- 00:16:02,235
I think the approach has really resonated.
00:16:02,235 -- 00:16:04,468
This collaborative,
00:16:04,468 -- 00:16:06,201
transparent, proactive
00:16:06,201 -- 00:16:07,935
approach has really resonated with the sector.
00:16:07,935 -- 00:16:10,635
And if you think about the FSRA objects themselves
00:16:10,635 -- 00:16:11,901
as a pension administrator,
00:16:11,901 -- 00:16:13,568
that wouldn't be too dissimilar, right?
00:16:13,568 -- 00:16:16,501
In terms of ensuring good pension
00:16:16,501 -- 00:16:17,368
administration
00:16:17,368 -- 00:16:23,268
and ultimately protecting the benefit for the beneficiaries.
00:16:23,435 -- 00:16:25,268
So anyway, I'd love to hear others thoughts
00:16:25,268 -- 00:16:27,968
I have heard from some I know I recognize some faces in the rooms
00:16:27,968 -- 00:16:29,435
and if not in today's forum.
00:16:29,435 -- 00:16:31,535
And please don't
00:16:31,535 -- 00:16:34,801
hesitate to reach out one on one to us at any time.
00:16:34,801 -- 00:16:37,501
To step back a little bit about operationalizing this.
00:16:37,501 -- 00:16:39,301
Starting in 2019.
00:16:39,301 -- 00:16:39,535
You know,
00:16:39,535 -- 00:16:42,368
you can think about people process and technology, right?
00:16:42,368 -- 00:16:43,402
So one of the keys
00:16:43,402 -- 00:16:47,202
to being collaborative and proactive
00:16:47,202 -- 00:16:49,635
is to have a relationship management discipline in place.
00:16:49,635 -- 00:16:50,902
And so we have to build that out.
00:16:50,902 -- 00:16:52,835
We also, as part of Andrew's team,
00:16:53,802 -- 00:16:55,602
built up much broader and deeper
00:16:55,602 -- 00:16:56,535
skill set
00:16:56,535 -- 00:16:58,702
right across all aspects of managing
00:16:58,702 -- 00:17:01,468
and administering a pension plan.
00:17:01,468 -- 00:17:05,035
We added some tools in terms of allowing us to be more dynamic
00:17:05,035 -- 00:17:06,768
and being on top of what's happening
00:17:06,768 -- 00:17:09,202
in the economy and capital markets and
00:17:09,202 -- 00:17:11,735
and looking at credit ratings,
00:17:11,735 -- 00:17:13,935
sponsored risk, things of that sort.
00:17:13,935 -- 00:17:14,635
And, and,
00:17:14,635 -- 00:17:19,368
and we did this as we concurrently had established the TAC -
00:17:19,368 -- 00:17:20,535
Technical Advisory Committee.
00:17:20,535 -- 00:17:21,468
Here I go with another one.
00:17:21,468 -- 00:17:23,668
You heard that Joanne talking about that this morning.
00:17:23,668 -- 00:17:28,668
We have a DB SEPP TAC as well as a MEPP TAC.
00:17:28,668 -- 00:17:33,302
And, and really critical to helping guide us for the MEPPS.
00:17:33,302 -- 00:17:35,402
We've established a road map of the work
00:17:35,402 -- 00:17:39,135
we wanted to do over the next several years, five years
00:17:39,135 -- 00:17:42,535
and with the DB SEPP in particular, there's a
00:17:42,535 -- 00:17:43,435
there was a guidance
00:17:43,435 -- 00:17:46,835
put into place on our supervisory approach for single employer
00:17:46,835 -- 00:17:48,902
pension plans that are actively monitored.
00:17:48,902 -- 00:17:52,402
And this guidance is an excellent example of a of a PBR approach.
00:17:52,402 -- 00:17:55,535
It's a nice succinct seven-page guidance.
00:17:55,535 -- 00:17:56,268
If you haven't read it, I
00:17:56,268 -- 00:17:57,635
highly recommend it
00:17:57,635 -- 00:18:00,602
and it's really important for us and our team
00:18:00,602 -- 00:18:02,202
as a communication tool as well,
00:18:02,202 -- 00:18:05,302
because we basically are in a proactive way
00:18:05,302 -- 00:18:07,902
are taking the information that we have available
00:18:07,902 -- 00:18:10,335
to us through filings, through publicly available sources.
00:18:10,335 -- 00:18:12,102
Some of those tools I just mentioned
00:18:12,102 -- 00:18:14,502
and really establishing a risk profile.
00:18:14,502 -- 00:18:16,135
And if there are single employer
00:18:16,135 -- 00:18:18,335
pension plans that we're concerned about,
00:18:18,335 -- 00:18:21,702
then we want to proactively reach out to the
00:18:21,702 -- 00:18:24,568
fiduciaries to have a detailed conversation
00:18:24,568 -- 00:18:29,902
around some of these concerns. And, and so we
00:18:30,968 -- 00:18:34,202
assess things like sponsor risk, funding risk,
00:18:34,202 -- 00:18:36,002
investment management risk,
00:18:36,002 -- 00:18:37,435
compliance risk
00:18:37,435 -- 00:18:40,102
and these conversations that we have
00:18:40,102 -- 00:18:42,168
and usually they're attended by senior people
00:18:42,168 -- 00:18:44,668
fiduciaries of the plan
00:18:44,668 -- 00:18:46,368
are really,
00:18:46,368 -- 00:18:51,168
really insightful and critical for us to understand better.
00:18:51,168 -- 00:18:53,702
If our assessment of that risk level is accurate
00:18:53,702 -- 00:18:57,835
and to be able to reassess it and, and move forward there.
00:18:57,835 -- 00:18:59,735
So we take that information back.
00:18:59,735 -- 00:19:01,668
Essentially, it forms a feedback loop
00:19:01,668 -- 00:19:05,302
if you want to look at it that way, that we, we
00:19:05,302 -- 00:19:06,902
go back to an internal steering committee
00:19:06,902 -- 00:19:12,302
that we have that then helps us reset our engagement strategy.
00:19:12,302 -- 00:19:13,402
And we're very transparent
00:19:13,402 -- 00:19:15,568
with our, with the sector as we're
00:19:15,568 -- 00:19:17,435
we're going through these discussions as to
00:19:17,435 -- 00:19:20,668
what kinds of things were, what our views are, etc..
00:19:20,668 -- 00:19:23,802
So that's again, part of our commitment to, to
00:19:23,802 -- 00:19:25,002
maintain that transparency.
00:19:26,668 -- 00:19:28,235
It's been an interesting journey.
00:19:28,235 -- 00:19:30,102
We've had plans that
00:19:30,102 -- 00:19:33,269
we've noticed some behavior around fiduciaries
00:19:33,269 -- 00:19:36,635
taking the pension plan members much more into consideration
00:19:36,635 -- 00:19:39,969
when they're making decisions around capital cost
00:19:39,969 -- 00:19:41,935
allocations, for example.
00:19:41,935 -- 00:19:43,569
So in other words, treating the pensioners
00:19:43,569 -- 00:19:46,502
as a as a silent creditor, if you will,
00:19:46,502 -- 00:19:47,802
we've seen
00:19:47,802 -- 00:19:51,069
that certain plans make additional contributions
00:19:51,069 -- 00:19:53,769
above and beyond the minimum
00:19:53,769 -- 00:19:55,935
to their pension plans in advance,
00:19:55,935 -- 00:19:59,302
or maybe as part of making other capital allocations.
00:19:59,302 -- 00:20:00,802
We've seen de-risking activity
00:20:00,802 -- 00:20:04,635
take place in the form of immunizing a portfolio
00:20:04,635 -- 00:20:07,202
a little bit better or even annuitizing.
00:20:07,202 -- 00:20:09,735
And I'll make another comment.
00:20:09,735 -- 00:20:12,102
As you're probably familiar,
00:20:12,102 -- 00:20:14,335
the single employer pension plans in Ontario,
00:20:14,335 -- 00:20:17,269
how the PBGF for the Pension Benefit Guaranty Fund.
00:20:17,269 -- 00:20:19,935
And so the CEO of FSRA
00:20:19,935 -- 00:20:22,702
has a fiduciary responsibility to the PBGF.
00:20:22,702 -- 00:20:26,302
So this work helps the CEO discharge that responsibility as well.
00:20:27,269 -- 00:20:29,302
And on the MEPPS side,
00:20:29,302 -- 00:20:33,702
I mentioned we had a roadmap put into place. We,
00:20:33,702 -- 00:20:37,002
the first thing we did was a thematic review in 2019, 2020,
00:20:37,002 -- 00:20:39,235
where we looked at a third of the sector.
00:20:39,235 -- 00:20:40,602
That was really critical for us
00:20:40,602 -- 00:20:43,402
to get a better understanding of the kinds of
00:20:43,402 -- 00:20:45,535
of challenges, issues
00:20:45,535 -- 00:20:49,069
and also leading practices that exist in the multiemployer
00:20:49,069 -- 00:20:50,369
pension space.
00:20:50,369 -- 00:20:55,802
We then collaboratively again with the TAC, produced
00:20:55,802 -- 00:20:59,735
a leading practice guidance which was published in 2021,
00:20:59,735 -- 00:21:03,202
and those eight leading practices fall into three buckets
00:21:03,202 -- 00:21:06,035
governance, risk management and communications.
00:21:06,035 -- 00:21:09,035
And we in that leading practice guidance,
00:21:09,035 -- 00:21:13,102
we committed to then going forward and benchmarking,
00:21:13,102 -- 00:21:14,635
so having each MEPP in Ontario
00:21:14,635 -- 00:21:16,835
benchmarked themselves against those leading practices.
00:21:16,835 -- 00:21:18,969
And that's been a really fascinating exercise
00:21:18,969 -- 00:21:21,702
that's actually coming to a conclusion now.
00:21:21,702 -- 00:21:24,335
We've also seen some tangible
00:21:24,335 -- 00:21:24,935
improvements
00:21:24,935 -- 00:21:27,835
if you will, in our journey in the last few years in terms
00:21:27,835 -- 00:21:29,302
of fiduciaries
00:21:29,302 -- 00:21:31,635
of multiemployer
00:21:31,635 -- 00:21:32,735
pension plans,
00:21:32,735 -- 00:21:36,102
enhancing their overall governance and risk and communication
00:21:37,502 -- 00:21:39,069
approach, as well as policies
00:21:39,069 -- 00:21:41,069
like in some cases, their policies existed.
00:21:41,069 -- 00:21:43,802
They were, they were enhanced.
00:21:43,802 -- 00:21:45,435
In other cases, they didn't exist at all.
00:21:45,435 -- 00:21:47,469
And they've been either put into place
00:21:47,469 -- 00:21:49,935
or in the process of being put into place.
00:21:49,935 -- 00:21:51,435
And the last comment I make on
00:21:51,435 -- 00:21:52,935
the MEPPS has to do with the fact
00:21:52,935 -- 00:21:55,135
that many of you're probably aware
00:21:55,135 -- 00:21:56,535
there's a target benefit framework
00:21:56,535 -- 00:21:59,002
that the Ministry of Finance has,
00:21:59,002 -- 00:22:01,269
has a proposal out there for a permanent framework.
00:22:01,269 -- 00:22:04,269
And the work we've done has a lot of synergy
00:22:04,269 -- 00:22:07,202
and integration with that work moving forward.
00:22:07,202 -- 00:22:11,302
So those are two examples of the work we do.
00:22:11,302 -- 00:22:15,636
I will mention quickly, Andrew, the examination work because we,
00:22:15,636 -- 00:22:16,136
our team
00:22:16,136 -- 00:22:18,069
also from a prudential supervision
00:22:18,069 -- 00:22:22,369
perspective, handled the examinations of plan administrators,
00:22:22,369 -- 00:22:24,336
specifically MEPPS and SEPPS.
00:22:24,336 -- 00:22:27,536
And we've, we've done a lot of work
00:22:27,536 -- 00:22:29,169
in revamping that process
00:22:29,169 -- 00:22:31,202
such that it becomes a principles-based .
00:22:31,202 -- 00:22:32,969
We've moved away from more of the prescriptive
00:22:32,969 -- 00:22:34,702
checklist approach.
00:22:34,702 -- 00:22:36,702
So we've been piloting that this past year.
00:22:36,702 -- 00:22:39,469
It's been a great exercise. We're now in the process of
00:22:41,036 -- 00:22:42,902
implementing that,
00:22:42,902 -- 00:22:43,802
moving forward
00:22:43,802 -- 00:22:46,769
and there'll be more to come in, in a webinar
00:22:46,769 -- 00:22:49,902
that we're going to be putting out there sometime in April
00:22:49,902 -- 00:22:52,002
or May of this year.
00:22:52,002 -- 00:22:52,669
Thank you, Paul.
00:22:52,669 -- 00:22:53,236
I think, Paul,
00:22:53,236 -- 00:22:56,336
you actually have highlighted for us
00:22:56,336 -- 00:22:58,102
through your work in the MEPP
00:22:58,102 -- 00:23:03,669
how FSRA may leverage a thematic review, might leverage a,
00:23:03,669 -- 00:23:09,036
you know, a set of best practices out there to, to guide us.
00:23:09,036 -- 00:23:11,769
These best practices are by no means
00:23:11,769 -- 00:23:13,902
compliance checklists that you have to do,
00:23:13,902 -- 00:23:17,069
but basically will give us as a regulator
00:23:17,069 -- 00:23:18,769
and the regulated entities,
00:23:18,769 -- 00:23:20,569
perhaps a baseline,
00:23:20,569 -- 00:23:21,702
a reference point
00:23:21,702 -- 00:23:22,969
for us to
00:23:22,969 -- 00:23:26,069
And, you as the regulated entities to evaluate
00:23:26,069 -- 00:23:28,802
how your own approach
00:23:28,802 -- 00:23:29,202
which may
00:23:29,202 -- 00:23:31,102
different from the best practice, will satisfy,
00:23:31,102 -- 00:23:35,202
you know, yourself in terms of achieving your own outcome.
00:23:35,202 -- 00:23:36,836
I think the MEPP work is also,
00:23:36,836 -- 00:23:37,636
you know, through your best
00:23:37,636 -- 00:23:41,036
practice paper, is a great example
00:23:41,036 -- 00:23:45,269
of how collaboration with the sector lead us to good results.
00:23:45,269 -- 00:23:47,036
And the TBP, for example,
00:23:47,036 -- 00:23:49,736
the funding framework for the Target Benefit Plan
00:23:49,736 -- 00:23:51,369
industry wants, know, prescribed
00:23:51,369 -- 00:23:54,902
PFADS, you know, Provisions For Adverse Deviation.
00:23:54,902 -- 00:23:57,002
I'm an actuary by training, by the way,
00:23:57,002 -- 00:23:59,002
but just forget some of the acronyms.
00:23:59,002 -- 00:24:00,702
This is what the industry is asking for.
00:24:00,702 -- 00:24:05,002
And, and we look forward to more collaboration
00:24:05,002 -- 00:24:08,869
because as we implement the regulatory guidance
00:24:08,869 -- 00:24:12,402
in respect to the new target benefit plan approach,
00:24:12,402 -- 00:24:14,236
there will be more conversation.
00:24:14,236 -- 00:24:16,836
There'll be a lot of open dialog
00:24:16,836 -- 00:24:18,602
that is required for the upcoming months.
00:24:18,602 -- 00:24:19,069
So
00:24:19,069 -- 00:24:21,669
and it will involve a lot more judgment
00:24:21,669 -- 00:24:24,969
than prescriptive, prescribed checklists and prescribed rules.
00:24:24,969 -- 00:24:27,736
So thank you for that part. So
00:24:28,702 -- 00:24:31,136
let me turn to James, so
00:24:31,136 -- 00:24:33,136
James is
00:24:33,136 -- 00:24:35,202
instrumental in, in
00:24:35,202 -- 00:24:39,369
leading the work of our large public sector pension plans.
00:24:39,369 -- 00:24:41,036
You heard Mark talk about why
00:24:41,036 -- 00:24:44,069
he's spending so much time on the JSPP work.
00:24:44,069 -- 00:24:44,436
James,
00:24:44,436 -- 00:24:48,369
can you tell us how risk management is factoring into your work
00:24:48,369 -- 00:24:50,802
on the large plans and
00:24:50,802 -- 00:24:51,569
tell us a little bit more
00:24:51,569 -- 00:24:53,069
about why,
00:24:53,069 -- 00:24:53,569
in addition
00:24:53,569 -- 00:24:55,002
to what Mark said this morning,
00:24:55,002 -- 00:24:57,636
we're developing a supervisory framework.
00:24:57,636 -- 00:25:02,036
That, and where we are today. Okay. Thanks, Andrew.
00:25:02,036 -- 00:25:05,436
So we are taking a bit of a different approach to the large plans
00:25:05,436 -- 00:25:06,303
than what
00:25:06,303 -- 00:25:07,069
Paul was describing,
00:25:07,069 -- 00:25:10,636
although there's a commonalities with, with Paul's approach.
00:25:10,636 -- 00:25:15,169
As noted, these plans manage complex investments.
00:25:15,169 -- 00:25:16,269
They are successful
00:25:16,269 -- 00:25:18,469
and I think it's fair to say they are well-regarded
00:25:18,469 -- 00:25:22,169
and they've been successful plans for our sector,
00:25:22,169 -- 00:25:24,936
but they also carry a fair amount of risk.
00:25:24,936 -- 00:25:28,503
And it's worth recalling the IMF report from a few years ago,
00:25:28,503 -- 00:25:32,869
which drew attention to the rise in risk taking out these plans,
00:25:32,869 -- 00:25:38,403
pointing to the increased leverage and increased illiquid assets.
00:25:38,403 -- 00:25:40,236
And from our perspective,
00:25:40,236 -- 00:25:44,036
the large plans are a major part of the pension sector.
00:25:44,036 -- 00:25:49,736
They account for 65% of pension assets and close to 40%
00:25:49,736 -- 00:25:52,069
of pension members. So
00:25:53,236 -- 00:25:54,903
it stands to reason, I think,
00:25:54,903 -- 00:26:00,803
that we need to have a supervisory strategy for these plans.
00:26:01,169 -- 00:26:04,403
If we focused only on a compliance approach
00:26:04,403 -- 00:26:09,036
to the prescriptive components of the PBA
00:26:09,036 -- 00:26:09,469
that won’t
00:26:09,469 -- 00:26:10,669
get us very far
00:26:10,669 -- 00:26:14,569
in terms of our statutory objects of protecting benefits,
00:26:14,569 -- 00:26:16,869
promoting good administration,
00:26:16,869 -- 00:26:21,136
contributing to public confidence, etc..
00:26:21,136 -- 00:26:24,669
Instead, we focus on the standard of care.
00:26:24,669 -- 00:26:26,436
We seek to understand
00:26:26,436 -- 00:26:32,336
and assess how plans are complying with their standard of care.
00:26:32,903 -- 00:26:35,503
In the past two or three years,
00:26:35,503 -- 00:26:37,269
we've been getting to know the plans.
00:26:37,269 -- 00:26:38,869
We've been learning their strategies.
00:26:38,869 -- 00:26:40,969
We've been learning about their risk exposures,
00:26:40,969 -- 00:26:42,969
their management techniques.
00:26:42,969 -- 00:26:46,236
We've also been building relationships
00:26:46,236 -- 00:26:47,469
and having good discussions
00:26:47,469 -- 00:26:53,369
with the plans about what supervision can mean for their sector.
00:26:53,503 -- 00:26:55,669
We're at a point in time now
00:26:55,669 -- 00:26:58,069
where it's appropriate for us to put our activities,
00:26:58,069 -- 00:27:02,536
to put pen to paper. These, are our activities.
00:27:02,536 -- 00:27:06,069
So you'll notice in the proposed statement of priorities
00:27:06,069 -- 00:27:07,903
that one of the priorities for the upcoming
00:27:07,903 -- 00:27:10,103
fiscal year to issue a guidance.
00:27:10,103 -- 00:27:13,669
So assuming those priorities are ultimately approved,
00:27:13,669 -- 00:27:15,369
that's something for you to look forward to.
00:27:16,969 -- 00:27:19,869
In the meantime, I want to share three ideas
00:27:19,869 -- 00:27:21,469
that illustrate how we think
00:27:21,469 -- 00:27:26,236
about the supervision of the large plans.
00:27:26,236 -- 00:27:29,836
First, we're focused on governance and risk management.
00:27:29,836 -- 00:27:31,903
Pension plans aren't banks,
00:27:31,903 -- 00:27:33,369
they're not commercial enterprises
00:27:33,369 -- 00:27:36,536
that are going to go out of business.
00:27:36,536 -- 00:27:39,769
So we're not going to take a Basel like solvency approach
00:27:39,769 -- 00:27:42,269
to supervising these entities.
00:27:42,269 -- 00:27:48,170
Our lane is about their governance and risk management practices,
00:27:52,236 -- 00:27:53,836
and there are established approaches
00:27:53,836 -- 00:27:55,336
to assessing these practices
00:27:55,336 -- 00:27:57,970
that other prudential regulators have developed
00:27:57,970 -- 00:28:00,603
that we can learn from, borrow and adapt
00:28:00,603 -- 00:28:03,636
as appropriate for the pension context.
00:28:03,636 -- 00:28:07,170
Second idea I want to raise is the principle of awareness.
00:28:07,170 -- 00:28:10,270
We are aware that plan administrators
00:28:10,270 -- 00:28:13,436
bear the responsibility of plan administration.
00:28:13,436 -- 00:28:15,870
Our role is not to set investment strategy.
00:28:15,870 -- 00:28:18,536
It's not to set risk appetite.
00:28:18,536 -- 00:28:21,670
Our role is to assess whether the governance
00:28:21,670 -- 00:28:23,270
and risk management activities
00:28:23,270 -- 00:28:25,536
are appropriate and effective
00:28:25,536 -- 00:28:26,703
and meet the standard of care
00:28:26,703 -- 00:28:29,570
for those investments and risk appetites.
00:28:30,770 -- 00:28:31,903
I'd like to take a moment to
00:28:31,903 -- 00:28:36,770
talk about the Aimco loss during the pandemic.
00:28:36,770 -- 00:28:37,936
So what happened here is that
00:28:37,936 -- 00:28:41,070
Aimco had a volatility trading strategy
00:28:41,070 -- 00:28:42,436
in 2018,
00:28:42,436 -- 00:28:47,403
it expanded the strategy to become both riskier and larger.
00:28:47,403 -- 00:28:48,970
But the problem was at the time
00:28:48,970 -- 00:28:52,270
the risk function had a legacy system
00:28:52,270 -- 00:28:55,836
that could not properly model the tail risk.
00:28:55,836 -- 00:28:57,836
With this investment.
00:28:57,836 -- 00:29:00,836
And this was the one at the time
00:29:00,836 -- 00:29:03,536
when the risk function was able to update its systems,
00:29:03,536 -- 00:29:04,336
it was too late.
00:29:04,336 -- 00:29:05,870
The pandemic happened,
00:29:05,870 -- 00:29:07,536
markets moved
00:29:07,536 -- 00:29:11,103
and Aimco lost over $2 billion before it could exit
00:29:11,103 -- 00:29:12,670
that strategy.
00:29:12,670 -- 00:29:16,503
So this is an example of a governance and risk management failure
00:29:16,503 -- 00:29:19,836
that could well have been avoided.
00:29:19,836 -- 00:29:22,970
The third idea I want to leave with you is one of expertise.
00:29:23,970 -- 00:29:28,570
Each of these plans employ smart, hardworking people.
00:29:28,570 -- 00:29:31,970
Our job is to access and leverage that expertise.
00:29:31,970 -- 00:29:35,070
So take the Aimco example.
00:29:35,070 -- 00:29:37,270
My team has some smart people on it,
00:29:37,270 -- 00:29:39,236
but if we were reviewing that, that
00:29:39,236 -- 00:29:40,236
investment strategy,
00:29:40,236 -- 00:29:43,670
I don't know if it would have been obvious to us
00:29:43,670 -- 00:29:46,436
that the model would have been deficient,
00:29:46,436 -- 00:29:49,903
but I'm not sure that, that is critical to our success.
00:29:49,903 -- 00:29:53,503
When we asked pension plans that demonstrate how they are
00:29:53,503 -- 00:29:54,803
meeting their standard of care
00:29:54,803 -- 00:29:57,903
and their risk management practices, we can ask them,
00:29:57,903 -- 00:30:01,370
do you have any gaps? Do you have any concerns?
00:30:01,370 -- 00:30:03,036
When's the last time you have had
00:30:03,036 -- 00:30:05,570
an external review of your models?
00:30:05,570 -- 00:30:08,470
Are there things that you're changing or want to change?
00:30:08,470 -- 00:30:10,170
Why do you want to change them?
00:30:10,170 -- 00:30:12,603
Among the various metrics or techniques.
00:30:12,603 -- 00:30:14,170
What, what do you rely on most?
00:30:15,536 -- 00:30:17,503
It's by asking questions like that
00:30:17,503 -- 00:30:19,070
and using our independence
00:30:19,070 -- 00:30:20,303
as a regulator
00:30:20,303 -- 00:30:22,603
and our view of the overall sector
00:30:22,603 -- 00:30:25,703
that we can have an informed view and engage with the plans.
00:30:25,703 -- 00:30:28,736
And that's ultimately how we see playing a role in the ecosystem
00:30:28,736 -- 00:30:30,070
that's constructive
00:30:30,070 -- 00:30:32,203
and that's how we can also demonstrate to our board
00:30:32,203 -- 00:30:35,037
that we're carrying out our statutory objects.
00:30:35,037 -- 00:30:38,303
So, Andrew, I'll stop there and turn it back.
00:30:38,303 -- 00:30:40,237
Thank you.
00:30:40,237 -- 00:30:43,503
Thank you. Hello.
00:30:43,503 -- 00:30:44,670
Thank you, James.
00:30:44,670 -- 00:30:48,737
So I think you actually have demonstrated that how
00:30:48,737 -- 00:30:51,803
we actually have interpreted the pension plans
00:30:51,803 -- 00:30:54,737
fiduciary duty, more contextually
00:30:54,737 -- 00:30:57,470
to determine that the requirements of large plans
00:30:57,470 -- 00:31:01,470
to have robust risk management practices.
00:31:01,470 -- 00:31:02,837
I think FSRA’s desire
00:31:02,837 -- 00:31:05,403
to ensure that risk management practices in place
00:31:05,403 -- 00:31:09,137
falls squarely within our statutory objective.
00:31:09,137 -- 00:31:11,170
I just want to repeat that we fully appreciate
00:31:11,170 -- 00:31:14,837
that these are very sophisticated plans.
00:31:14,837 -- 00:31:20,637
They actually have in place very robust strategy and whatnot.
00:31:20,637 -- 00:31:23,203
I just want to reiterate, what we are doing here
00:31:23,203 -- 00:31:25,803
is not to second guess any of the investment decisions.
00:31:25,803 -- 00:31:27,903
We don't have that expertise.
00:31:27,903 -- 00:31:31,370
We actually have been engaging the large plans over the last
00:31:31,370 -- 00:31:32,270
few years
00:31:32,270 -- 00:31:34,403
to actually have regular phone calls with them
00:31:34,403 -- 00:31:37,503
to make sure that we are on top of what they are doing.
00:31:37,503 -- 00:31:40,137
So it's really nothing more than that.
00:31:40,137 -- 00:31:42,970
We want to start understanding their practices.
00:31:42,970 -- 00:31:44,037
Joanne,
00:31:44,037 -- 00:31:47,403
our board chair, mentioned this morning we want to collect data.
00:31:47,403 -- 00:31:49,603
Our going in position is that these plans
00:31:49,603 -- 00:31:51,537
know what they're doing.
00:31:51,537 -- 00:31:54,103
We are there to verify that,
00:31:54,103 -- 00:31:55,970
you know, in discharging our duty
00:31:55,970 -- 00:31:58,603
to verify what they have done is in fact
00:31:59,737 -- 00:32:01,570
right and
00:32:01,570 -- 00:32:02,603
is really, is
00:32:02,603 -- 00:32:05,737
really, is really try to understand a little bit more
00:32:05,737 -- 00:32:07,137
how they structure themselves,
00:32:07,137 -- 00:32:10,137
how they structure a team as not to second guess their investment
00:32:10,137 -- 00:32:13,303
decisions whatsoever.
00:32:13,303 -- 00:32:17,470
So let me now turn a little bit more to
00:32:17,470 -- 00:32:20,870
to how our day-to-day work on the operations side.
00:32:20,870 -- 00:32:25,370
So can I turn to Claire and Trevor to perhaps,
00:32:25,370 -- 00:32:25,603
you know,
00:32:25,603 -- 00:32:30,203
let us know how you've been applying PBR in your day to day work,
00:32:30,203 -- 00:32:31,270
whether it is
00:32:31,270 -- 00:32:34,337
intake from an inquiry or a filings
00:32:34,337 -- 00:32:35,903
from a plan administrators
00:32:35,903 -- 00:32:37,270
and how, Trevor,
00:32:37,270 -- 00:32:38,870
you've been taking that principles
00:32:38,870 -- 00:32:44,503
in, in, in assessing, for example, the actuarial robustness
00:32:44,503 -- 00:32:47,170
you know of the plans.
00:32:47,170 -- 00:32:48,103
Thanks, Andrew.
00:32:48,103 -- 00:32:49,737
I think there's three main areas
00:32:49,737 -- 00:32:52,403
in which the operations team is trying to incorporate
00:32:52,403 -- 00:32:55,537
a PBR approach into our everyday work.
00:32:55,537 -- 00:32:57,737
Firstly, by taking a risk-based approach
00:32:57,737 -- 00:33:00,370
when performing our regular compliance reviews
00:33:00,370 -- 00:33:01,803
and related checklists
00:33:01,803 -- 00:33:05,237
so that not every tick box is given equal weighting,
00:33:05,237 -- 00:33:06,837
consistent with our guiding object
00:33:06,837 -- 00:33:08,970
to promote good plan administration.
00:33:08,970 -- 00:33:10,303
I think it's always important
00:33:10,303 -- 00:33:13,670
to point out deficiencies to plan administrators
00:33:13,670 -- 00:33:16,803
so that future applications have a stronger likelihood
00:33:16,803 -- 00:33:18,803
of being fully compliant.
00:33:18,803 -- 00:33:21,370
However, depending on the nature of the deficiency,
00:33:21,370 -- 00:33:23,970
FSRA may choose to overlook a requirement.
00:33:23,970 -- 00:33:26,670
If we view that there's little to no harm.
00:33:26,670 -- 00:33:27,504
For example,
00:33:27,504 -- 00:33:29,570
the notice requirements on asset transfers
00:33:29,570 -- 00:33:32,204
and conversions are quite prescriptive.
00:33:32,204 -- 00:33:36,204
Some of the information, if missing, may not impact transparency
00:33:36,204 -- 00:33:38,637
or overall consent levels if required.
00:33:39,870 -- 00:33:42,470
However, some information may be critical
00:33:42,470 -- 00:33:44,937
to a member's decision making process.
00:33:44,937 -- 00:33:47,470
For example, any information regarding benefits
00:33:47,470 -- 00:33:50,004
or entitlements or contributions.
00:33:50,004 -- 00:33:53,870
And if that's missing, we may require a supplemental notice to be
00:33:53,870 -- 00:33:55,370
mailed out.
00:33:55,370 -- 00:33:56,504
The secondary I'd like to
00:33:56,504 -- 00:34:00,704
highlight is how FSRA is trying to become more proactive
00:34:00,704 -- 00:34:02,004
than reactive.
00:34:02,004 -- 00:34:02,570
In the past,
00:34:02,570 -- 00:34:06,237
we've been very focused on information filings, the submissions
00:34:06,237 -- 00:34:08,804
been made to made to us, and less so
00:34:08,804 -- 00:34:12,804
on information that should have been filed with us but hasn't.
00:34:12,804 -- 00:34:16,104
Information that isn't filed us could be indicative of a problem
00:34:16,104 -- 00:34:19,104
in plan administration, plan governance,
00:34:19,104 -- 00:34:22,070
a corporate restructuring, or at the worst end
00:34:22,070 -- 00:34:24,770
an employer insolvency.
00:34:24,770 -- 00:34:26,404
In the summer of 2022,
00:34:26,404 -- 00:34:30,470
FSRA recommenced this process for going after outstanding filings
00:34:30,470 -- 00:34:33,770
and we reached out to over 250 plan administrators
00:34:33,770 -- 00:34:36,037
to find out why their findings were late.
00:34:36,037 -- 00:34:37,537
And the overwhelming reason
00:34:37,537 -- 00:34:40,470
why information was being delayed in the filing
00:34:40,470 -- 00:34:44,004
was because people were unaware of key filing deadlines
00:34:44,004 -- 00:34:47,837
or were not set up on the pension services portal correctly.
00:34:47,837 -- 00:34:49,804
As a result of that observation,
00:34:49,804 -- 00:34:52,470
we developed two at-a-glance documents
00:34:52,470 -- 00:34:55,537
that set out the requirements for DC plan administrators
00:34:55,537 -- 00:34:57,837
and mailed them out to all plans
00:34:57,837 -- 00:35:01,537
as well as mail them out to large insurance companies.
00:35:01,537 -- 00:35:05,270
The second thing we did was, created a short video to, to
00:35:06,337 -- 00:35:07,670
outline to plan administrators
00:35:07,670 -- 00:35:09,170
how they can update their information
00:35:09,170 -- 00:35:11,337
on the pension services portal.
00:35:11,337 -- 00:35:13,170
The third area I'd like to highlight
00:35:13,170 -- 00:35:15,870
is how we're trying to be more collaborative.
00:35:15,870 -- 00:35:18,737
We recognize that plan administration isn't easy
00:35:18,737 -- 00:35:21,870
and we're open to listening and providing feedback.
00:35:21,870 -- 00:35:23,270
Where you run into trouble,
00:35:23,270 -- 00:35:26,804
but not necessarily providing you with the exact answer.
00:35:26,804 -- 00:35:28,304
Administrative errors happen
00:35:28,304 -- 00:35:30,470
all the time as we all make mistakes.
00:35:30,470 -- 00:35:33,470
We’re open to having a dialog of what might be reasonable
00:35:33,470 -- 00:35:36,504
and appropriate in the situation to fix it.
00:35:36,504 -- 00:35:38,204
And we're open to also making sure
00:35:38,204 -- 00:35:40,504
that these errors don't happen again.
00:35:40,504 -- 00:35:41,537
Trevor?
00:35:41,537 -- 00:35:45,037
Well, alright,
00:35:45,037 -- 00:35:46,470
thanks Claire that was shocking.
00:35:46,470 -- 00:35:50,004
I'd like to thank Andrew for leaving me to the end
00:35:50,004 -- 00:35:51,937
and it's great to see everybody in person. I agree.
00:35:51,937 -- 00:35:55,070
I want to echo my fellow panelists. It's really nice to.
00:35:55,070 -- 00:35:56,504
I know too many people here,
00:35:56,504 -- 00:35:59,637
which means I've been working in this industry for too long.
00:35:59,637 -- 00:36:03,170
I've been at FSRA for almost a year now, and I'm really,
00:36:03,170 -- 00:36:06,370
I've had the opportunity just see PBR in action.
00:36:06,370 -- 00:36:07,837
So what I thought I'd do, again
00:36:07,837 -- 00:36:12,404
as the deputy chief actuary, and yes, I have a badge,
00:36:12,404 -- 00:36:14,637
as deputy chief actuary,
00:36:15,671 -- 00:36:18,071
I have an opportunity to engage with plans
00:36:18,071 -- 00:36:19,704
and really have some conversations.
00:36:19,704 -- 00:36:21,271
So I want to give you an example of something
00:36:21,271 -- 00:36:23,504
we actually did within the last few months.
00:36:23,504 -- 00:36:24,871
Now, hold your hats.
00:36:24,871 -- 00:36:27,671
We had a single employer pension plan
00:36:27,671 -- 00:36:31,637
that was transferring into a large JSPP.
00:36:31,637 -- 00:36:32,704
I know.
00:36:32,704 -- 00:36:36,337
Who would have ever thought such a crazy thing would happen?
00:36:36,337 -- 00:36:37,971
And following the transfer,
00:36:37,971 -- 00:36:39,771
there was only surplus assets
00:36:39,771 -- 00:36:42,704
remaining in the single employer pension plan.
00:36:42,704 -- 00:36:44,737
So the question was, well exactly, and shockingly,
00:36:44,737 -- 00:36:46,271
the employer wanted to share the surplus.
00:36:46,271 -- 00:36:48,271
How are we going to get this surplus assets out?
00:36:48,271 -- 00:36:49,837
What are the best ways?
00:36:49,837 -- 00:36:54,171
Well, unfortunately, after a transfer, the plan isn't wound up.
00:36:54,171 -- 00:36:55,904
So if you look, under the Pension Benefits Act,
00:36:55,904 -- 00:36:58,137
which I know we all do every night,
00:36:58,137 -- 00:36:59,837
you can see the only way to get surplus
00:36:59,837 -- 00:37:01,804
is really through winding up the plan
00:37:01,804 -- 00:37:05,237
or through a surplus application, through an ongoing plan.
00:37:06,204 -- 00:37:08,237
Well, we could have required
00:37:08,237 -- 00:37:10,304
the administrator to do a formal wind up,
00:37:10,304 -- 00:37:12,304
but that would have been engaging actuaries.
00:37:12,304 -- 00:37:14,304
And no one likes actuaries
00:37:14,304 -- 00:37:17,204
to produce a report with a bunch of zeros in it.
00:37:17,204 -- 00:37:20,237
And that would have been a lot of work and unnecessary work.
00:37:20,237 -- 00:37:21,404
So we worked with them.
00:37:21,404 -- 00:37:23,071
We consulted with them exactly
00:37:23,071 -- 00:37:24,937
the PBR approach we've been talking about.
00:37:24,937 -- 00:37:26,671
We had conversations with them
00:37:26,671 -- 00:37:28,737
as to what is the most appropriate,
00:37:28,737 -- 00:37:30,871
what's the quickest way, how can we do this
00:37:30,871 -- 00:37:33,537
so that everybody, you can get what they want,
00:37:33,537 -- 00:37:35,737
which in this case was a surplus of money out
00:37:35,737 -- 00:37:37,737
in the easiest case possible
00:37:37,737 -- 00:37:42,004
while still working with the Pension Benefits Act and regs.
00:37:42,004 -- 00:37:43,237
So that's what we did.
00:37:43,237 -- 00:37:46,971
So we actually went through the ongoing surplus application.
00:37:46,971 -- 00:37:48,171
It worked out well
00:37:48,171 -- 00:37:49,404
and then once all the money is out,
00:37:49,404 -- 00:37:51,971
they can apply for a simplified wind up.
00:37:51,971 -- 00:37:53,937
So I think that's really shows a great example
00:37:53,937 -- 00:37:56,071
of when a plan sponsor approached us.
00:37:56,071 -- 00:37:58,837
We came up with a collaborative approach
00:37:58,837 -- 00:38:01,271
on really how to make this work
00:38:01,271 -- 00:38:05,471
within the Act as well as really trying to be outcomes focused
00:38:05,471 -- 00:38:06,804
because what was the outcome we wanted?
00:38:06,804 -- 00:38:09,037
Let's get the surplus and they were able to.
00:38:09,037 -- 00:38:11,904
So good news all around. Andrew,
00:38:13,271 -- 00:38:13,804
thank you.
00:38:13,804 -- 00:38:16,271
Thank you, everyone.
00:38:16,271 -- 00:38:20,337
I want to pose questions to the panel.
00:38:20,337 -- 00:38:21,804
So you guys have been talking about
00:38:21,804 -- 00:38:24,404
how you apply PBR in your day-to-day work.
00:38:24,404 -- 00:38:27,471
You actually have shared with us some of the success stories,
00:38:27,471 -- 00:38:29,037
but can you also share with us
00:38:29,037 -- 00:38:32,671
some of the challenges that you've faced
00:38:32,671 -- 00:38:37,571
during the last few years as we were implementing the PBR?
00:38:37,571 -- 00:38:39,037
Who wants to start?
00:38:39,037 -- 00:38:42,971
I'll go first. Okay. First is the best.
00:38:42,971 -- 00:38:45,037
I think that...You're going to get Trevor to speak.
00:38:45,037 -- 00:38:45,437
Yeah, I will speak after,
00:38:45,437 -- 00:38:50,071
because actually we have two sides of the same coin, I think.
00:38:50,071 -- 00:38:53,538
And if I thought of Travis first, I would have taken it.
00:38:53,538 -- 00:38:56,104
I think in operations, I think the biggest challenge
00:38:56,104 -- 00:38:59,138
would be to make sure we ensure consistency
00:38:59,138 -- 00:39:00,871
when we're making PBR decisions
00:39:00,871 -- 00:39:04,371
that may not fully align with a plain reading of the PBA.
00:39:04,371 -- 00:39:06,338
Over the course of the last year,
00:39:06,338 -- 00:39:07,338
FSRA has solidified
00:39:07,338 -- 00:39:07,971
its thinking
00:39:07,971 -- 00:39:11,738
towards plan amendments after reviewing the PBA regulations
00:39:11,738 -- 00:39:13,404
as well as our objects.
00:39:13,404 -- 00:39:15,504
Our general expectation is that amendments
00:39:15,504 -- 00:39:18,171
should be filed before they're effective
00:39:18,171 -- 00:39:20,338
and that, but sometimes that won't happen
00:39:20,338 -- 00:39:22,871
and FSRA will need to take a PBR approach to determine
00:39:22,871 -- 00:39:24,604
whether that retroactive adverse
00:39:24,604 -- 00:39:26,971
amendment can be registered or not.
00:39:26,971 -- 00:39:28,238
In our proposed guidance,
00:39:28,238 -- 00:39:30,171
we actually encourage plan administrators
00:39:30,171 -- 00:39:31,538
who file amendments late
00:39:31,538 -- 00:39:33,304
to actually make a submission to us
00:39:33,304 -- 00:39:37,871
using our values of transparency, reasonableness and equity
00:39:37,871 -- 00:39:41,338
as to why the, why the amendment should be registered as is.
00:39:41,338 -- 00:39:42,038
And I think,
00:39:43,204 -- 00:39:44,971
you know, in some cases you could show that there's
00:39:44,971 -- 00:39:47,504
no negative impact on plan beneficiaries
00:39:47,504 -- 00:39:49,271
and we would just go ahead and register it
00:39:49,271 -- 00:39:51,471
in some cases, maybe not.
00:39:51,471 -- 00:39:52,071
Trevor?
00:39:52,071 -- 00:39:55,171
Yeah, the thing we're also very concerned about and taking a PBR
00:39:55,171 -- 00:39:57,871
approach is precedent setting and having,
00:39:57,871 -- 00:39:59,438
you know, consulting firms.
00:39:59,438 -- 00:40:01,804
Actuaries say, well, you applied it in this scenario.
00:40:01,804 -- 00:40:05,471
That means it applies in every possible scenario
00:40:05,471 -- 00:40:07,938
that we can think of, and that's not what our approach is.
00:40:07,938 -- 00:40:09,171
We're trying to take,
00:40:09,171 -- 00:40:10,138
again, an approach
00:40:10,138 -- 00:40:10,771
where we look
00:40:10,771 -- 00:40:12,471
at the individual circumstances
00:40:12,471 -- 00:40:14,638
of the plan and the situation that they're in,
00:40:14,638 -- 00:40:17,504
and we're going to apply a PBR approach to that
00:40:17,504 -- 00:40:20,638
and that does not necessarily expand
00:40:20,638 -- 00:40:24,071
to other plans who are in similar situations.
00:40:24,071 -- 00:40:24,871
So what we're again,
00:40:24,871 -- 00:40:27,338
why we're having these conversations while we're saying this,
00:40:27,338 -- 00:40:29,971
so that we're hoping to engage in more conversations,
00:40:29,971 -- 00:40:30,204
you know,
00:40:30,204 -- 00:40:31,971
with other actuaries, with plan sponsors
00:40:31,971 -- 00:40:33,771
so that we can make sure to know what applies
00:40:33,771 -- 00:40:35,304
and what doesn't, because we're really,
00:40:35,304 -- 00:40:36,571
you know, concerned with scope creep.
00:40:37,671 -- 00:40:39,638
Trevor just wants more lunches with people.
00:40:39,638 -- 00:40:44,638
I just, I like to eat.
00:40:44,638 -- 00:40:46,704
I would say, Andrew, that
00:40:46,704 -- 00:40:50,104
when we launched, there was certainly some trepidation, right?
00:40:50,104 -- 00:40:52,638
Like, what do you
00:40:52,638 -- 00:40:55,104
what's this conversation going to look like?
00:40:55,104 -- 00:40:56,938
And
00:40:56,938 -- 00:41:00,738
so I think the main you know, there's, there's,
00:41:00,738 -- 00:41:02,338
this is a journey right?
00:41:02,338 -- 00:41:04,371
I don't think we've used that term today, at least
00:41:04,371 -- 00:41:06,671
I don't recall hearing it. But any that's really critical, right?
00:41:06,671 -- 00:41:07,904
Like PBR,
00:41:07,904 -- 00:41:09,771
we said it from inception,
00:41:09,771 -- 00:41:12,471
but in in some cases, like I said earlier,
00:41:12,471 -- 00:41:14,204
I was blessed with the fact that I was able
00:41:14,204 -- 00:41:16,304
to start from scratch in some of the work we do.
00:41:16,304 -- 00:41:17,304
So a little bit,
00:41:17,304 -- 00:41:20,004
you know, easier to, to launch into versus others
00:41:20,004 -- 00:41:23,738
we’re transitioning we should talk about some of the guidance.
00:41:23,738 -- 00:41:25,671
So it's a journey, and a journey,
00:41:25,671 -- 00:41:27,371
and that requires trust building.
00:41:27,371 -- 00:41:29,671
And I think and I,
00:41:29,671 -- 00:41:30,871
I know from my own experience,
00:41:30,871 -- 00:41:32,204
but again, I would love to hear from others
00:41:32,204 -- 00:41:34,038
who who've been involved that
00:41:34,038 -- 00:41:35,971
that level of trust has improved,
00:41:35,971 -- 00:41:38,771
had increased, excuse me, fairly rapidly
00:41:38,771 -- 00:41:41,505
once we got into the discussions and just by the way,
00:41:41,505 -- 00:41:42,638
that supervisory approach
00:41:42,638 -- 00:41:44,105
I mentioned earlier that we published
00:41:44,105 -- 00:41:48,671
we published it on March 16th, Monday, March 16th of 2020.
00:41:48,671 -- 00:41:49,605
I think everybody in the room
00:41:49,605 -- 00:41:53,005
probably remembers what happened March 13th, the Friday before.
00:41:53,005 -- 00:41:57,405
Very fortuitous time to be publishing an approach such as that.
00:41:57,405 -- 00:41:59,205
And but on the flip side,
00:41:59,205 -- 00:42:01,971
it really challenged us and pushed us to, to, to
00:42:01,971 -- 00:42:03,438
work through this.
00:42:03,438 -- 00:42:03,905
So, so
00:42:03,905 -- 00:42:07,238
I guess the challenge is really the opposite of collaboration
00:42:07,238 -- 00:42:09,738
is not collaborating and not having that trust.
00:42:11,071 -- 00:42:11,371
You know,
00:42:11,371 -- 00:42:12,838
we're really
00:42:12,838 -- 00:42:15,238
trying to avoid the sense of setting people up
00:42:15,238 -- 00:42:17,271
for an I gotcha type moment.
00:42:17,271 -- 00:42:23,171
I had very fortuitously a conversation with a with a lawyer from
00:42:23,238 -- 00:42:24,138
in the insurance side.
00:42:24,138 -- 00:42:25,671
So I know she's not in the room here
00:42:25,671 -- 00:42:28,538
because she's told me she's going to another session.
00:42:28,538 -- 00:42:32,938
But it was exactly about this topic, about trying to understand,
00:42:32,938 -- 00:42:36,205
you know, like that trepidation as to
00:42:36,205 -- 00:42:37,905
in guiding her own clients
00:42:37,905 -- 00:42:39,805
as to whether or not they should speak to FSRA
00:42:39,805 -- 00:42:43,405
and never mind doing it proactively, like just when we reach out.
00:42:43,405 -- 00:42:45,838
So that that would be the biggest challenge.
00:42:45,838 -- 00:42:49,305
And I think, you know, moving forward to the,
00:42:49,305 -- 00:42:50,838
we talk about guidance, the guidance,
00:42:50,838 -- 00:42:52,871
you can't understate the importance of the guidance
00:42:54,171 -- 00:42:54,338
there
00:42:54,338 -- 00:42:56,371
are other guidances out there that we've, we've established
00:42:56,371 -- 00:43:00,305
like the roles and responsibilities that we use quite a bit.
00:43:00,305 -- 00:43:04,438
And as time goes on and we gain experience and, you know,
00:43:04,438 -- 00:43:10,338
those guidance will also be enhanced and improved in my opinion,
00:43:11,638 -- 00:43:14,505
I'd say, say two things are in terms of challenges.
00:43:14,505 -- 00:43:16,505
The first is pacing.
00:43:16,505 -- 00:43:18,438
We're, we're a bit unhealthy in that
00:43:18,438 -- 00:43:21,605
we think about the large plans every single day.
00:43:21,605 -- 00:43:23,905
That doesn't mean they need to hear from us every single day.
00:43:23,905 -- 00:43:26,638
So as you know, as we're,
00:43:26,638 -- 00:43:27,771
you know, for a puppy, but,
00:43:27,771 -- 00:43:31,571
you know, as we are growing and developing into a future state,
00:43:31,571 -- 00:43:35,571
I think we have to be efficient in terms of the resources that we,
00:43:35,571 -- 00:43:37,971
we have and also the resources that the plans have.
00:43:39,005 -- 00:43:40,405
But at the same time, I mean,
00:43:40,405 -- 00:43:43,805
we are a fully functioning up and running supervisor.
00:43:43,805 -- 00:43:46,538
So if something happens in the sector,
00:43:46,538 -- 00:43:50,738
we're ready to handle that and will, the resources we need
00:43:50,738 -- 00:43:52,371
for that.
00:43:52,371 -- 00:43:55,471
The second thing I'd say in terms of the challenge is tone.
00:43:55,471 -- 00:43:59,438
And I think Paul's team does a pretty good job at this.
00:43:59,438 -- 00:44:01,738
You know we're not we're not cops on the beat
00:44:01,738 -- 00:44:03,971
looking to issue tickets,
00:44:03,971 -- 00:44:05,571
although as a regulator, there
00:44:05,571 -- 00:44:08,905
is, there's ultimately an enforcement component.
00:44:08,905 -- 00:44:12,338
On the other hand, we're not necessarily friends either.
00:44:12,338 -- 00:44:14,371
You know, we need to be objective and critical.
00:44:14,371 -- 00:44:18,638
So we need to find the right kind of tone
00:44:18,638 -- 00:44:20,605
to establish our authority as the regulator,
00:44:20,605 -- 00:44:21,638
but at the same time
00:44:21,638 -- 00:44:25,471
to create a kind of a collaborative, cooperative
00:44:25,471 -- 00:44:29,638
kind of critical space for discussion on the key issues.
00:44:29,638 -- 00:44:31,805
And I think that's a bit of a challenge.
00:44:31,805 -- 00:44:33,172
Not that we're not doing a good job.
00:44:33,172 -- 00:44:34,205
I think we are doing that.
00:44:34,205 -- 00:44:37,305
But, but it is a, it's a fine line that we need to, to
00:44:37,305 -- 00:44:37,872
walk there.
00:44:39,872 -- 00:44:42,372
Anything for you Reesha?
00:44:42,372 -- 00:44:43,405
Okay, good.
00:44:43,405 -- 00:44:46,072
So I still recall the days,
00:44:46,072 -- 00:44:47,338
you know, 2020
00:44:47,338 -- 00:44:49,072
was when we first issued the guidance
00:44:49,072 -- 00:44:51,172
on actively monitored pension plans.
00:44:51,172 -- 00:44:55,072
We have our fair dose of pushback and look at,
00:44:55,072 -- 00:44:55,272
you know,
00:44:55,272 -- 00:44:55,872
four years
00:44:55,872 -- 00:45:00,005
now is all part of our DNA in terms of how we manage
00:45:00,005 -- 00:45:02,672
and how we supervise the single employer pension plans.
00:45:02,672 -- 00:45:03,372
So, so I'm
00:45:03,372 -- 00:45:04,772
very hopeful that, you know,
00:45:04,772 -- 00:45:06,505
we will achieve the same thing for, you know,
00:45:06,505 -- 00:45:09,405
all the other plans across the sector.
00:45:09,405 -- 00:45:11,472
One more question for the panel.
00:45:11,472 -- 00:45:13,672
So you heard a little bit about PBR.
00:45:13,672 -- 00:45:17,972
You heard a little bit about what we, we what it really means.
00:45:17,972 -- 00:45:20,805
But what does it mean when the sector
00:45:20,805 -- 00:45:22,972
is going to interact with us in the future?
00:45:22,972 -- 00:45:26,605
How is that experience going to be, look like
00:45:26,605 -- 00:45:29,138
we were doing away with compliance checklists.
00:45:29,138 -- 00:45:31,705
There's no more checklists or less of those.
00:45:31,705 -- 00:45:34,538
So, so, what, what would be the experience with
00:45:35,572 -- 00:45:39,538
FSRA going forward?
00:45:39,538 -- 00:45:41,805
How about I go first, Andrew?
00:45:41,805 -- 00:45:45,872
So, some of you know, I am a parent of a teenager right now.
00:45:45,872 -- 00:45:49,538
It's a very painful experience.
00:45:49,538 -- 00:45:52,372
So, when, so bear with me for a second.
00:45:52,372 -- 00:45:56,272
When my son was little, I'd sit him down,
00:45:56,272 -- 00:45:58,072
do your homework, right.
00:45:58,072 -- 00:45:59,272
This is the expectation.
00:45:59,272 -- 00:46:00,772
These are the 2 hours
00:46:00,772 -- 00:46:05,572
that I'm allotting to force you to do your reading and your math.
00:46:05,572 -- 00:46:07,405
We did this for years.
00:46:07,405 -- 00:46:09,405
Now that he's a teenager,
00:46:09,405 -- 00:46:11,938
I have a different way of approaching him.
00:46:11,938 -- 00:46:13,172
My expectation,
00:46:13,172 -- 00:46:17,072
I will tell him and I'll tell you honestly, he doesn't listen,
00:46:17,072 -- 00:46:21,205
is that he does his homework, that he attends school.
00:46:21,205 -- 00:46:23,072
I don't force him to do it.
00:46:23,072 -- 00:46:25,238
I expect that he does do it
00:46:25,238 -- 00:46:28,238
because he understands that that is the outcome
00:46:28,238 -- 00:46:31,138
that we're hoping to achieve, that he will graduate high school,
00:46:31,138 -- 00:46:33,438
that he will pass all his classes.
00:46:33,438 -- 00:46:34,605
So,
00:46:34,605 -- 00:46:36,572
when you're approaching FSRA,
00:46:36,572 -- 00:46:37,138
you've got,
00:46:37,138 -- 00:46:40,438
and I tend to see, to be quite frank,
00:46:40,438 -- 00:46:44,505
the more complex, difficult, ambiguous problems.
00:46:44,505 -- 00:46:48,205
So this is my suggestion and actually my request to you
00:46:48,205 -- 00:46:49,572
when you're faced
00:46:49,572 -- 00:46:53,172
with one of those complex, difficult questions
00:46:53,172 -- 00:46:56,272
that you are interacting with us on,
00:46:56,272 -- 00:46:57,305
think about
00:46:57,305 -- 00:47:00,138
what are the outcomes that we've articulated
00:47:00,138 -- 00:47:02,372
that we are hoping to achieve.
00:47:02,372 -- 00:47:04,472
They are in our statutory objects.
00:47:04,472 -- 00:47:08,238
They are protect plan beneficiaries
00:47:08,238 -- 00:47:11,138
and support the good administration of pension plans.
00:47:11,138 -- 00:47:15,172
With that framework, look and think about the particular problem
00:47:15,172 -- 00:47:16,839
that you are faced with
00:47:16,839 -- 00:47:18,072
and let me know
00:47:18,072 -- 00:47:21,672
because I'm going to me or one of the members of my team
00:47:21,672 -- 00:47:24,439
are going to be reviewing your submissions.
00:47:24,439 -- 00:47:26,439
Tell us why
00:47:26,439 -- 00:47:32,339
we should permit whatever it is that you are asking us to permit.
00:47:32,405 -- 00:47:34,005
Like what is the basis,
00:47:34,005 -- 00:47:37,539
not just because it's a good outcome in your opinion,
00:47:37,539 -- 00:47:39,905
but that it's a generally good outcome
00:47:39,905 -- 00:47:42,739
for plan beneficiaries,
00:47:42,739 -- 00:47:46,305
that it supports the good administration of pension plans
00:47:46,305 -- 00:47:49,872
that it supports to the extent that we can,
00:47:49,872 -- 00:47:53,039
supports innovation, flexibility,
00:47:53,039 -- 00:47:55,472
better protection for plan beneficiaries.
00:47:56,505 -- 00:47:58,505
I can't guarantee you,
00:47:58,505 -- 00:48:02,372
that I'm necessarily going to agree or, we will,
00:48:02,372 -- 00:48:06,339
the royal we, will agree with your interpretation.
00:48:06,339 -- 00:48:08,872
But there are a variety of tools
00:48:08,872 -- 00:48:10,972
that we may use in the circumstances.
00:48:10,972 -- 00:48:14,105
As Trevor has identified with this surplus example,
00:48:14,105 -- 00:48:16,439
to support the outcome that you're hoping to achieve.
00:48:16,439 -- 00:48:18,539
We're trying not to shackle you.
00:48:18,539 -- 00:48:22,372
We're trying to empower you to find solutions that work.
00:48:22,372 -- 00:48:25,705
One of the things I hear a lot about the pension sector
00:48:25,705 -- 00:48:28,605
is that it's very unique and it's true.
00:48:28,605 -- 00:48:31,972
We have small, single employer
00:48:31,972 -- 00:48:35,639
defined contribution pension plans to large
00:48:35,639 -- 00:48:39,639
public sector, multibillion dollar pension plans.
00:48:39,639 -- 00:48:42,072
So one size isn't going to fit all.
00:48:42,072 -- 00:48:45,805
So when you're dealing with one of those complex problems,
00:48:45,805 -- 00:48:49,505
tell me why should we as the regulator,
00:48:49,505 -- 00:48:55,105
be exercising our discretion or Mark's discretion to support the
00:48:55,105 -- 00:48:57,305
the outcome that you're hoping to achieve?
00:48:57,305 -- 00:48:59,539
So think of it a little bit differently. Don't, I
00:49:01,672 -- 00:49:02,905
would encourage you
00:49:02,905 -- 00:49:08,805
to think of it as what is your administrators fiduciary duty?
00:49:09,105 -- 00:49:10,872
Are you satisfying that duty
00:49:10,872 -- 00:49:14,205
when you come to us with that problem?
00:49:14,205 -- 00:49:18,939
And tell us how you did and again, how what it is
00:49:18,939 -- 00:49:21,605
that you're hoping to achieve supports
00:49:21,605 -- 00:49:22,205
your plan
00:49:22,205 -- 00:49:28,105
and is consistent with our statutory objects and the PBA.
00:49:28,139 -- 00:49:31,805
If I could add to that, I just say it's important
00:49:31,805 -- 00:49:34,872
that you come to us with solutions as well. We're not here.
00:49:34,872 -- 00:49:36,439
I think Claire said it earlier,
00:49:36,439 -- 00:49:38,839
we're not here to give you the answers.
00:49:38,839 -- 00:49:40,172
If there's a complex problem
00:49:40,172 -- 00:49:42,505
and you've got a potential solution for it
00:49:42,505 -- 00:49:45,772
and you want to, you know, “workshop” or discuss it with us,
00:49:45,772 -- 00:49:47,039
hey, we're open to do that,
00:49:47,039 -- 00:49:50,239
but what we're not here to do is tell you the answer,
00:49:50,239 -- 00:49:53,839
especially in a complex situation that may not fit directly
00:49:53,839 -- 00:49:57,905
within the Act and regs. So again, it's a bit of a give and take.
00:49:57,905 -- 00:49:59,672
You know, Andrew asked, What are we looking for?
00:49:59,672 -- 00:50:01,539
Well, again, we're looking for collaboration.
00:50:01,539 -- 00:50:02,939
We're looking to have a conversation.
00:50:02,939 -- 00:50:05,472
We may not always agree with you.
00:50:05,472 -- 00:50:07,072
There's been instances in the last six months
00:50:07,072 -- 00:50:07,972
that I've been working here,
00:50:07,972 -- 00:50:09,906
I've been working with different consulting firms
00:50:09,906 -- 00:50:11,639
where they've come to us to say, we want to do this.
00:50:11,639 -- 00:50:12,739
And we're like,
00:50:12,739 -- 00:50:14,672
Yeah, I know you want to,
00:50:14,672 -- 00:50:17,872
but unfortunately I don't think you can, right?
00:50:17,872 -- 00:50:19,272
And then we said, Can you go back,
00:50:19,272 -- 00:50:21,606
think some more, and give us another possible solution
00:50:21,606 -- 00:50:22,906
where they've come back to us.
00:50:22,906 -- 00:50:24,372
That may happen.
00:50:24,372 -- 00:50:25,572
But the key point I want to make
00:50:25,572 -- 00:50:26,339
is that we're not here
00:50:26,339 -- 00:50:28,572
to actually give solutions to you, but we're here to,
00:50:28,572 -- 00:50:29,872
you know, work with you. on it.
00:50:34,339 -- 00:50:35,406
Am I gonna go first?
00:50:35,406 -- 00:50:37,706
I would say patience.
00:50:37,706 -- 00:50:40,739
I think I think in the past,
00:50:40,739 -- 00:50:43,372
FSRA has been very much a case by case,
00:50:43,372 -- 00:50:46,606
kind of like looking at individual problems.
00:50:46,606 -- 00:50:48,772
And I think PBR
00:50:48,772 -- 00:50:50,506
kind of like requires, it
00:50:50,506 -- 00:50:52,372
necessitates a holistic approach to problem
00:50:52,372 -- 00:50:56,072
solving and problems take, solutions take time to develop.
00:50:56,072 -- 00:50:57,772
So I think it's just really being patient
00:50:57,772 -- 00:50:59,872
with us as we kind of think through
00:50:59,872 -- 00:51:01,439
what PBR looks like in a,
00:51:01,439 -- 00:51:06,606
in a very prescriptive piece of legislation.
00:51:06,606 -- 00:51:10,906
I think we're kind of speaking to a theme here
00:51:10,906 -- 00:51:12,872
in terms of what supervision looks like.
00:51:12,872 -- 00:51:16,339
I, the buzz word that I had was highly analytical.
00:51:16,339 -- 00:51:16,706
You know,
00:51:16,706 -- 00:51:19,972
I think I see this revision as a historical kind of activity.
00:51:19,972 -- 00:51:21,606
And by that
00:51:21,606 -- 00:51:23,606
what I mean is we really need to understand
00:51:23,606 -- 00:51:25,739
the facts, the policies, procedures
00:51:26,839 -- 00:51:29,872
and the context of each plan, and it’s only by having
00:51:29,872 -- 00:51:31,539
that understanding
00:51:31,539 -- 00:51:33,172
can we, you know, be in a position
00:51:33,172 -- 00:51:36,372
to have a principles-based response.
00:51:36,372 -- 00:51:38,606
So that means looking at documents, that look,
00:51:38,606 -- 00:51:41,606
that means looking at internal reports,
00:51:41,606 -- 00:51:45,472
talking to people, you know, asking questions
00:51:45,472 -- 00:51:48,406
and really digging into the issue.
00:51:48,406 -- 00:51:52,072
I think when it comes to, you know, developing a view,
00:51:52,072 -- 00:51:55,639
there will be some issues which are clear and obvious,
00:51:55,639 -- 00:51:58,206
and then there'll be other issues where, where
00:51:58,206 -- 00:51:59,572
that's not the case.
00:51:59,572 -- 00:52:02,839
And in those situations, it's important for us to be
00:52:02,839 -- 00:52:06,206
very clear and transparent about our, our premises
00:52:06,206 -- 00:52:08,772
and our reasons for coming to a particular view.
00:52:08,772 -- 00:52:11,772
So I think it's, a it's a highly analytical process.
00:52:11,772 -- 00:52:13,406
I mean, this feeds off the things
00:52:13,406 -- 00:52:14,606
we've talked about earlier around ambiguity,
00:52:16,539 -- 00:52:17,672
but I think that's the,
00:52:17,672 -- 00:52:22,372
that's the reality of principles-based regulation. Thanks.
00:52:22,372 -- 00:52:25,639
And from my perspective, I just,
00:52:25,639 -- 00:52:28,972
so I mentioned early on, on the single employer side
00:52:28,972 -- 00:52:34,039
how we implemented our new approach during a tumultuous time.
00:52:34,039 -- 00:52:35,272
So the analogy is,
00:52:35,272 -- 00:52:37,839
you know, flying the plane as you're as you're building it.
00:52:37,839 -- 00:52:39,239
And, and we were also learning
00:52:39,239 -- 00:52:41,472
how to fly it and going through turbulence
00:52:41,472 -- 00:52:42,872
that's now steady state.
00:52:42,872 -- 00:52:44,139
I don't even want to use that word
00:52:44,139 -- 00:52:47,506
because actually we've got a team now built,
00:52:47,506 -- 00:52:49,506
and we're really focusing on it, on our own.
00:52:49,506 -- 00:52:51,006
I’ll call it internal governance
00:52:51,006 -- 00:52:53,139
or how do we continually improve on our approach.
00:52:53,139 -- 00:52:55,073
So that's why I'm really anxious
00:52:55,073 -- 00:52:58,039
to get feedback and encourage that again.
00:52:58,039 -- 00:52:59,539
And on the multiemployer side,
00:52:59,539 -- 00:53:01,539
really exciting times in my opinion,
00:53:01,539 -- 00:53:03,806
I feel really blessed to be
00:53:03,806 -- 00:53:05,273
having a front row seat to a time
00:53:05,273 -- 00:53:07,773
where, where we have this permanent
00:53:07,773 -- 00:53:11,339
framework being moved across the finish line,
00:53:11,339 -- 00:53:15,439
right as we ourselves are wrapping up the several years of work
00:53:15,439 -- 00:53:18,139
we've been doing, very collaborative with the sector that are,
00:53:18,139 -- 00:53:19,739
as I said earlier, are very integrated.
00:53:19,739 -- 00:53:21,873
So that's going to be an exciting
00:53:23,173 -- 00:53:24,906
time coming up over the next year.
00:53:24,906 -- 00:53:27,039
And then lastly, the examinations approach.
00:53:27,039 -- 00:53:29,373
I didn't get much into it.
00:53:29,373 -- 00:53:30,339
Happy to go into it
00:53:30,339 -- 00:53:32,039
more and very much looking forward
00:53:32,039 -- 00:53:34,939
to getting feedback from those in the room
00:53:34,939 -- 00:53:36,306
or anybody who's, who's
00:53:36,306 -- 00:53:38,839
part of our future state examination process
00:53:38,839 -- 00:53:39,306
to make sure
00:53:39,306 -- 00:53:45,206
we are truly being principles-based , as, as we'd like to be.
00:53:45,306 -- 00:53:47,839
Thank you.
00:53:47,839 -- 00:53:49,839
Thank you, everyone.
00:53:49,839 -- 00:53:52,373
Hello? Yeah, thank you, everyone.
00:53:52,373 -- 00:53:58,273
So we've spoken for good 50 minutes and it's time to open
00:53:58,773 -- 00:54:01,373
the floor, to questions to the floor.
00:54:01,373 -- 00:54:04,806
So if you have any questions.
00:54:04,806 -- 00:54:08,739
Sorry. What? Oh, good.
00:54:08,739 -- 00:54:13,039
okay. So I'm sorry. Next question.
00:54:13,039 -- 00:54:17,306
So please submit your questions through, through the app.
00:54:17,306 -- 00:54:19,939
So the first question is, is FSRA
00:54:19,939 -- 00:54:22,739
overextending its interpretation
00:54:22,739 -- 00:54:27,006
of the authority of the PBA Pension Benefits Act?
00:54:27,006 -- 00:54:28,939
I think that's probably...I think that's you.
00:54:31,673 -- 00:54:33,673
No,
00:54:33,673 -- 00:54:36,273
next question. Yeah.
00:54:36,273 -- 00:54:41,206
So no, I would not be sitting here
00:54:41,206 -- 00:54:45,173
saying that so confidently if I didn't believe it to be true.
00:54:45,173 -- 00:54:47,806
It's not just a glib answer,
00:54:47,806 -- 00:54:51,439
I would say, and this is a little bit behind the scenes.
00:54:51,439 -- 00:54:55,639
We are quite rigorous in our interpretations.
00:54:55,639 -- 00:54:59,973
When there is a particularly controversial interpretation,
00:54:59,973 -- 00:55:02,039
we go outside
00:55:02,039 -- 00:55:03,073
to make sure
00:55:03,073 -- 00:55:06,806
that our interpretation isn't just supporting
00:55:06,806 -- 00:55:11,306
the outcome that we want or we desire. Right?
00:55:11,306 -- 00:55:14,873
So it's careful, it's rigorous.
00:55:14,873 -- 00:55:19,973
But I would say this, and there's disagreement on this, in
00:55:19,973 -- 00:55:22,839
some relatively recent guidance.
00:55:22,839 -- 00:55:27,439
You're not going to agree with us necessarily,
00:55:27,439 -- 00:55:29,839
but I would say our interpretation
00:55:29,839 -- 00:55:32,639
fits within the scope of the PBA.
00:55:32,639 -- 00:55:36,473
It fits consistently with our statutory objects
00:55:36,473 -- 00:55:39,240
and it is supported by case law.
00:55:39,240 -- 00:55:40,973
You may not like the outcome
00:55:40,973 -- 00:55:46,406
that we are hoping to achieve or the interpretation that we take,
00:55:46,406 -- 00:55:49,773
but I wouldn't say that we're overextending.
00:55:49,773 -- 00:55:52,706
It probably is a surprise to many of you,
00:55:52,706 -- 00:55:54,673
some of the positions that we're taking,
00:55:55,673 -- 00:55:58,006
some of you may not agree with them,
00:55:58,006 -- 00:56:01,740
but I would say they're rigorous and careful and they're vetted.
00:56:01,740 -- 00:56:07,506
I mean, I would say without going
00:56:07,506 -- 00:56:08,873
too much behind the scenes,
00:56:08,873 -- 00:56:09,240
that there's
00:56:09,240 -- 00:56:12,973
a very long process before we come up with guidance
00:56:12,973 -- 00:56:13,506
that starts
00:56:13,506 -- 00:56:16,706
with the identification of a regulatory problem
00:56:16,706 -- 00:56:20,240
that we did that Claire spoke to in the plan amendment guidance,
00:56:20,240 -- 00:56:23,773
what are the outcomes that we hope to achieve?
00:56:23,773 -- 00:56:30,173
Consultations with a variety of stakeholders, multiple times.
00:56:31,140 -- 00:56:35,506
So if there is an overextension of our authority,
00:56:35,506 -- 00:56:37,640
that truly was the case of,
00:56:37,640 -- 00:56:39,106
up and overextension
00:56:39,106 -- 00:56:40,640
then I think it would come to light
00:56:40,640 -- 00:56:45,040
well before the guidance was actually published
00:56:45,040 -- 00:56:47,840
and certainly before it is public.
00:56:47,840 -- 00:56:50,773
But that doesn't mean that everybody's going to agree with me.
00:56:50,773 -- 00:56:53,573
But I will say I will stand behind our interpretations.
00:56:54,973 -- 00:56:58,540
Thank you Reesha, I think also is,
00:56:58,540 -- 00:57:01,706
sometimes is, the environment.
00:57:01,706 -- 00:57:03,906
The sector is evolving as well, too,
00:57:03,906 -- 00:57:05,306
so we have no choice
00:57:05,306 -- 00:57:06,840
but to interpret it, you know,
00:57:06,840 -- 00:57:07,940
and we have to apply
00:57:07,940 -- 00:57:09,540
a principles-based approach
00:57:09,540 -- 00:57:11,673
to interpreting the act, you know, again,
00:57:11,673 -- 00:57:13,940
laying over it, you know, the our object.
00:57:13,940 -- 00:57:14,473
I again,
00:57:14,473 -- 00:57:19,106
I turn to the target benefit blend plan funding framework is one
00:57:19,106 -- 00:57:21,606
where you don't have prescribed PFAD.
00:57:21,606 -- 00:57:22,940
And so what are we going to do?
00:57:22,940 -- 00:57:25,173
We have going to use a lot of judgment,
00:57:25,173 -- 00:57:26,873
applying the principles-base
00:57:26,873 -- 00:57:29,273
in terms of how we're going to be administrating,
00:57:29,273 -- 00:57:32,073
the act and the regulations thereunder.
00:57:32,073 -- 00:57:36,306
So next question.
00:57:36,306 -- 00:57:37,940
I'm sorry, I have to read. It's a long one.
00:57:37,940 -- 00:57:41,006
So there is a perspective that the large public sector
00:57:41,006 -- 00:57:44,206
pension plans are too big to fail.
00:57:44,206 -- 00:57:47,173
Can you tell us about what you see are
00:57:47,173 -- 00:57:49,740
benefits of supervisory framework
00:57:49,740 -- 00:57:52,840
that is planned for release in 24-25?
00:57:52,840 -- 00:57:56,940
And what are you hearing about it from the sector,
00:57:56,940 -- 00:58:00,306
how it's being received? I think this belongs to you, James.
00:58:02,740 -- 00:58:03,773
It's an interesting question.
00:58:03,773 -- 00:58:08,540
I think, you know, large public sector plans too big to fail.
00:58:08,540 -- 00:58:11,073
You know, that's sort of bringing a banking kind of analogy
00:58:11,073 -- 00:58:14,006
or banking idea over into the pension context.
00:58:14,006 -- 00:58:16,506
But we know that
00:58:16,506 -- 00:58:17,673
the Bank of Canada
00:58:17,673 -- 00:58:20,107
in the last, in the pandemic established
00:58:20,107 -- 00:58:23,507
a liquidity facility for a number of the large plans.
00:58:23,507 -- 00:58:26,373
So to the extent that the bank, pension
00:58:26,373 -- 00:58:29,673
needed that facility to avoid default,
00:58:29,673 -- 00:58:32,373
I guess you could say they're too big to fail.
00:58:32,373 -- 00:58:34,740
You know, in terms about, you know,
00:58:34,740 -- 00:58:36,607
you know, whether governments would permit reduction
00:58:36,607 -- 00:58:40,573
in benefits, that's a, that's an entirely separate discussion.
00:58:40,573 -- 00:58:40,773
You know,
00:58:40,773 -- 00:58:42,740
the benefits of the supervisory framework,
00:58:42,740 -- 00:58:44,273
I think, you know, partly it's, it's
00:58:44,273 -- 00:58:46,873
just being transparent to the sector
00:58:46,873 -- 00:58:50,473
as to the principles by which we are,
00:58:50,473 -- 00:58:53,573
you know, undertaking our supervisory activities.
00:58:53,573 -- 00:58:57,040
So there's transparency and predictability and there's a basis
00:58:57,040 -- 00:59:00,740
to have discussion on those principles.
00:59:00,740 -- 00:59:03,107
And I see the question has disappeared.
00:59:03,107 -- 00:59:05,873
Which was the second part of the question?
00:59:05,873 -- 00:59:08,840
What do you see as the benefit of the supervisory guidance?
00:59:08,840 -- 00:59:10,207
Yeah, I think the benefit is again,
00:59:10,207 -- 00:59:13,007
just being transparent about how we do that.
00:59:13,007 -- 00:59:14,340
And the key thing about,
00:59:16,007 -- 00:59:16,640
you know, our
00:59:16,640 -- 00:59:19,207
prudential supervision, I think the too big to fail
00:59:19,207 -- 00:59:21,240
brings in this concept of, you know, our
00:59:21,240 -- 00:59:22,840
you know, are these plans systemic?
00:59:22,840 -- 00:59:25,007
Do we have to worry about systemic issues?
00:59:25,007 -- 00:59:26,873
And I think our, our view is that,
00:59:26,873 -- 00:59:27,240
you know, as
00:59:27,240 -- 00:59:30,007
prudential regulators, if we keep the plans
00:59:30,007 -- 00:59:34,040
or if the plans are able to govern and manage their own risks,
00:59:34,040 -- 00:59:35,340
hopefully they don't get to a spot
00:59:35,340 -- 00:59:37,107
where there's any systemic implications.
00:59:37,107 -- 00:59:40,373
So that's how I sort of rationalize that.
00:59:40,373 -- 00:59:43,873
So some of you know that I've been in industry for a while.
00:59:43,873 -- 00:59:46,040
I'm coming up 38, 39 years.
00:59:46,040 -- 00:59:47,673
So I've been around
00:59:47,673 -- 00:59:50,440
and my career spanned not just consulting, but
00:59:50,440 -- 00:59:53,973
a stint with a large plan. So too big to fail.
00:59:53,973 -- 00:59:57,707
Not in a sense that it will be insolvent in that sense,
00:59:57,707 -- 01:00:00,273
but there will be hiccups.
01:00:00,273 -- 01:00:02,607
You know, along the way, I joined a large plan.
01:00:02,607 -- 01:00:05,607
I started signing the large plans in 2002
01:00:05,607 -- 01:00:07,740
and I joined the plan in 2008.
01:00:07,740 -- 01:00:09,073
Bad time to, you know,
01:00:09,073 -- 01:00:12,307
effectively associate with the large plans.
01:00:12,307 -- 01:00:13,807
My fate that is.
01:00:13,807 -- 01:00:16,940
But, there will be hiccups along the way, right.
01:00:16,940 -- 01:00:20,540
And the road to recovery will generally be very long.
01:00:20,540 -- 01:00:22,340
And so what do you do in between?
01:00:22,340 -- 01:00:25,273
Well, you can either, as I think Mark mentioned this morning,
01:00:25,273 -- 01:00:28,007
you can either increase contributions or cut benefits.
01:00:28,007 -- 01:00:29,840
But when you look at some of the large plans,
01:00:29,840 -- 01:00:32,107
the contribution rates are 20%
01:00:32,107 -- 01:00:34,940
plus employee employer side combined.
01:00:34,940 -- 01:00:37,940
And so there's really not a lot of room to go.
01:00:37,940 -- 01:00:38,440
So again,
01:00:38,440 -- 01:00:40,407
we're not there to question,
01:00:40,407 -- 01:00:42,073
but we are there to kind of monitor
01:00:42,073 -- 01:00:45,240
and make sure that the right protocols in place,
01:00:45,240 -- 01:00:49,173
we're not there to try to replace the board, to be the fiduciary,
01:00:49,173 -- 01:00:52,773
but you know, what we're doing will hopefully help, you know,
01:00:52,773 -- 01:00:53,640
spotlight there.
01:00:55,173 -- 01:00:59,607
So, we still have some question time.
01:00:59,607 -- 01:01:02,440
So if Restated plan text
01:01:02,440 -- 01:01:05,773
are filed retroactive to the amendment date
01:01:05,773 -- 01:01:08,874
with no material impact on members
01:01:08,874 -- 01:01:11,707
would it be agreeable with FSRA? Thanks.
01:01:11,707 -- 01:01:13,574
And this is in light of your comments
01:01:13,574 -- 01:01:15,640
to file amendments prospectively.
01:01:15,640 -- 01:01:16,940
So for those,
01:01:16,940 -- 01:01:18,207
I hope everyone is aware
01:01:18,207 -- 01:01:22,207
that we actually had a consultation just finished, second, second
01:01:22,207 -- 01:01:24,440
consultation just concluded on the plan
01:01:24,440 -- 01:01:27,507
amendment guidance, specifically with retroactive amendments.
01:01:27,507 -- 01:01:31,140
There's been, attracting a lot of comments. I’ll let Claire?
01:01:31,140 -- 01:01:33,907
You speak to it first? Sure, I'll speak to it first.
01:01:33,907 -- 01:01:36,440
I mean, a material impact on members.
01:01:36,440 -- 01:01:37,340
I'm not sure what that means.
01:01:37,340 -- 01:01:40,707
I mean, I think I'll take a bit of a back step.
01:01:40,707 -- 01:01:40,974
I mean,
01:01:40,974 -- 01:01:43,007
I think in the operations team,
01:01:43,007 -- 01:01:44,974
we see like six types of amendments,
01:01:44,974 -- 01:01:48,540
six types, of types of amendments being filed with us.
01:01:48,540 -- 01:01:51,374
Housekeeping. We don't care about those ones.
01:01:51,374 -- 01:01:53,407
Benefit improvements, all good.
01:01:54,907 -- 01:01:56,007
What else?
01:01:56,007 -- 01:01:58,974
Legislative required, legislative visible.
01:01:58,974 -- 01:02:01,574
And we see collective bargaining amendments
01:02:01,574 -- 01:02:04,107
that are filed late with us and they're collectively bargained.
01:02:04,107 -- 01:02:05,907
So we're not going to interfere with that practice.
01:02:05,907 -- 01:02:09,440
And it's really those retroactive adverse.
01:02:09,440 -- 01:02:12,474
We're going to have to think through
01:02:12,474 -- 01:02:15,540
I mean, the way one example I was going to say in my speaking
01:02:15,540 -- 01:02:19,074
remarks was FSRA reviews
01:02:19,074 -- 01:02:22,207
an increased DC member contributions as being adversed.
01:02:22,207 -- 01:02:23,840
If filed late.
01:02:23,840 -- 01:02:25,474
Let's say it's filed a year late.
01:02:25,474 -- 01:02:29,374
Well, would we go back and require those contributions to be,
01:02:29,374 -- 01:02:31,107
you know, given back to the members?
01:02:31,107 -- 01:02:32,607
That seems like an odd thing for us
01:02:32,607 -- 01:02:35,974
to do of giving them back pension or retirement money.
01:02:35,974 -- 01:02:40,407
This was in a pension plan. So I think it really depends. Reesha?
01:02:42,840 -- 01:02:44,907
It's hard to
01:02:44,907 -- 01:02:46,640
answer the question, to be honest,
01:02:46,640 -- 01:02:49,340
because it's going to be very case specific.
01:02:49,340 -- 01:02:51,740
So how about this? I'd flip it
01:02:51,740 -- 01:02:57,140
if you're filing a restated plan text and it is retroactive,
01:02:57,140 -- 01:03:02,207
why don't you make a submission as to why we should file it
01:03:02,207 -- 01:03:03,607
in light of the guidance
01:03:03,607 -- 01:03:04,840
which outlines
01:03:04,840 -- 01:03:06,574
what are the things that we're going to think about.
01:03:06,574 -- 01:03:09,907
So I think the principles were transparency,
01:03:09,907 -- 01:03:12,674
transparency, reasonableness and equity. Equity.
01:03:12,674 -- 01:03:17,640
So did you notify members that there was
01:03:17,640 -- 01:03:22,074
a file plan text?
01:03:22,074 -- 01:03:23,240
Do they know?
01:03:23,240 -- 01:03:25,207
Were they notified of any of the changes
01:03:25,207 -- 01:03:29,440
which are in this case non-material?
01:03:29,440 -- 01:03:34,640
What are the non-material changes that may impact members?
01:03:34,640 -- 01:03:36,574
Can you outline those for us?
01:03:36,574 -- 01:03:37,574
Are they equitable?
01:03:37,574 -- 01:03:40,307
So, you know, if you answer
01:03:40,307 -- 01:03:42,707
like if it's transparent,
01:03:42,707 -- 01:03:46,407
equitable, not really taking anything away, the chances are good.
01:03:46,407 -- 01:03:47,807
But make a submission
01:03:47,807 -- 01:03:51,107
call up and talk to your pension officer and Claire
01:03:51,107 -- 01:03:52,307
and chat about it and
01:03:53,374 -- 01:03:55,707
we'll talk about it.
01:03:55,707 -- 01:03:57,107
I think that's quite,
01:03:57,107 -- 01:03:59,941
quite a learning in terms of drafting guidance
01:03:59,941 -- 01:04:00,974
that are principal-based,
01:04:00,974 -- 01:04:03,841
because as I mentioned before previously
01:04:03,841 -- 01:04:05,774
a previous regime,
01:04:05,774 -- 01:04:09,707
would have very prescribed details as to how you comply
01:04:09,707 -- 01:04:10,907
and not complying.
01:04:10,907 -- 01:04:13,374
We'll never be able to write a guidance
01:04:13,374 -- 01:04:16,674
that will be exhaustive enough to cover all situations.
01:04:16,674 -- 01:04:20,407
We tried to clarify it through our guidance by giving examples
01:04:20,407 -- 01:04:22,541
and yet some of the comments we receive is, well,
01:04:22,541 -- 01:04:24,441
your example is it's not exhaustive enough.
01:04:24,441 -- 01:04:27,474
Well, does that equal prescription?
01:04:27,474 -- 01:04:28,807
I'm not, I'm not, you know,
01:04:28,807 -- 01:04:30,941
I think all comments are welcome here,
01:04:30,941 -- 01:04:33,141
but I think people need to be aware
01:04:33,141 -- 01:04:37,574
that this will be part of the principles-based regulations.
01:04:37,574 -- 01:04:39,807
So, so I'll leave it at that.
01:04:39,807 -- 01:04:42,941
The other thing, too, is that, you know,
01:04:44,907 -- 01:04:46,807
there are different views out there.
01:04:46,807 -- 01:04:52,707
Certainly some people who wrote to us feel that we actually have
01:04:52,874 -- 01:04:57,274
overextended our ability to, or authority to interpreted the PBA.
01:04:57,274 -- 01:05:00,007
But there's also a whole different side
01:05:00,007 -- 01:05:03,141
where they're very supportive of what we're doing.
01:05:03,141 -- 01:05:04,674
So there's always two sides to it.
01:05:04,674 -- 01:05:06,541
But we, we haven't concluded that we’ll
01:05:06,541 -- 01:05:08,241
also continue to dialog with the sector.
01:05:08,241 -- 01:05:12,507
So Reesha, you’re good
01:05:12,507 -- 01:05:13,607
with that?
01:05:13,607 -- 01:05:18,541
Enough time for a few more questions.
01:05:18,541 -- 01:05:20,307
Okay. What is the future?
01:05:20,307 -- 01:05:23,541
I'm not editing it. I'm just trying to, to read it.
01:05:23,541 -- 01:05:26,807
What is the future of single employer DB plans?
01:05:26,807 -- 01:05:31,841
Will PBR mean more work for single employer pension plans?
01:05:31,841 -- 01:05:33,641
Who wants to answer it?
01:05:33,641 -- 01:05:36,007
I can answer it, but you can too.
01:05:36,007 -- 01:05:37,274
It might be teamwork here,
01:05:37,274 -- 01:05:38,241
but because I mean,
01:05:38,241 -- 01:05:39,774
there are two very different questions, right?
01:05:39,774 -- 01:05:44,774
What is the future of, of SEPPS or single employer DB plans?
01:05:44,774 -- 01:05:46,007
That's
01:05:46,007 -- 01:05:47,307
that's a big broad question
01:05:47,307 -- 01:05:49,341
which I think a lot of people have an opinion on.
01:05:49,341 -- 01:05:52,507
I mean, they've clearly been on the decline
01:05:52,507 -- 01:05:54,141
and I don't think that's any big secret.
01:05:54,141 -- 01:05:56,841
They've been that, that's been the case for a long time.
01:05:56,841 -- 01:06:01,107
And then now we've got the Pension Protection Act on the table.
01:06:01,107 -- 01:06:03,541
So I mean we're all trying to figure out
01:06:03,541 -- 01:06:04,907
what the implication of that is.
01:06:06,574 -- 01:06:08,841
In terms of the PBR, though,
01:06:08,841 -- 01:06:10,507
the second part of the question,
01:06:10,507 -- 01:06:11,741
or really the second question,
01:06:11,741 -- 01:06:13,341
which is will PBR mean more work
01:06:13,341 -- 01:06:15,741
for single employer pension plans?
01:06:15,741 -- 01:06:18,741
I think my short answer would be no.
01:06:18,741 -- 01:06:21,441
I'd love to know more, about the context behind this question,
01:06:21,441 -- 01:06:23,207
it's in an anonymous question,
01:06:23,207 -- 01:06:25,007
but please reach out to me directly
01:06:25,007 -- 01:06:26,841
if you want to give me some more
01:06:26,841 -- 01:06:30,207
as to what that, what's, what's behind that thinking?
01:06:30,207 -- 01:06:32,041
Maybe just about the examination process.
01:06:32,041 -- 01:06:33,841
As one example, though,
01:06:33,841 -- 01:06:36,341
we definitely are very, very much aware
01:06:36,341 -- 01:06:38,174
and as we are with our single employer approach.
01:06:38,174 -- 01:06:42,774
And, then the future state MEPP approach is about burden, right?
01:06:42,774 -- 01:06:43,474
And, and
01:06:43,474 -- 01:06:44,874
then you know what you might think
01:06:44,874 -- 01:06:47,341
or maybe the questions stemming from this data collection
01:06:47,341 -- 01:06:49,674
and the engagements and the time involved in.
01:06:49,674 -- 01:06:52,408
Yeah, certainly that that could be considered work.
01:06:52,408 -- 01:06:54,041
But I would suggest that
01:06:54,041 -- 01:06:57,808
the outcomes of our work and the takeaways
01:06:57,808 -- 01:07:01,074
is much more value add to the, to the fiduciary
01:07:01,074 -- 01:07:02,374
and understanding,
01:07:02,374 -- 01:07:02,608
you know,
01:07:02,608 -- 01:07:03,608
what is going
01:07:03,608 -- 01:07:06,241
well and maybe where there's opportunities for improvement
01:07:06,241 -- 01:07:09,541
and the examination process is going to very much move away
01:07:09,541 -- 01:07:09,974
from that
01:07:09,974 -- 01:07:13,641
where we select plans much more on a on a dynamic
01:07:13,641 -- 01:07:15,941
basis, it's risk based.
01:07:15,941 -- 01:07:18,574
And in the one word we haven't used,
01:07:18,574 -- 01:07:21,341
or at least I don't recall hearing, is proportionality, right?
01:07:21,341 -- 01:07:23,708
Is the amount of effort that we're going to put into
01:07:24,741 -- 01:07:26,841
our engagements and then the examinations
01:07:26,841 -- 01:07:29,708
is going to be proportional to the to the level of risk.
01:07:29,708 -- 01:07:33,708
So ideally, the work will actually shrink if it's less risky.
01:07:33,708 -- 01:07:35,774
So, so let me add my perspective.
01:07:35,774 -- 01:07:39,108
I'm a pension geek all through and through.
01:07:39,108 -- 01:07:45,574
I certainly would like the the future of single employer DB plans
01:07:45,574 -- 01:07:51,874
to continue to continue to flourish may not be the right word.
01:07:51,874 -- 01:07:54,041
At least stop the bleeding.
01:07:54,041 -- 01:07:56,574
I think it's again picking, pegging,
01:07:56,574 -- 01:07:58,974
picking, picking up from the Pension Awareness Day.
01:07:58,974 -- 01:07:59,941
I think
01:07:59,941 -- 01:08:01,441
retirement security is going to be more
01:08:01,441 -- 01:08:02,808
and more important going forward,
01:08:02,808 -- 01:08:03,774
You know, with people
01:08:03,774 -- 01:08:06,641
living longer and longer with an aging population, we,
01:08:06,641 -- 01:08:09,141
we will collectively find a way
01:08:09,141 -- 01:08:11,708
to make sure that there would be more pension coverage,
01:08:11,708 -- 01:08:13,508
whether it's through a single employer pension plan
01:08:13,508 -- 01:08:16,541
or through a multiemployer pension plan or large plans.
01:08:16,541 -- 01:08:19,108
Will PBR mean more work to single employer pension plans?
01:08:19,108 -- 01:08:20,608
It might.
01:08:20,608 -- 01:08:22,374
You know, it's kind of funny
01:08:22,374 -- 01:08:25,274
because I certainly was on the other side.
01:08:25,274 -- 01:08:28,474
I certainly had my fair share of complaints to then regime.
01:08:28,474 -- 01:08:29,441
It's sort of like, okay,
01:08:29,441 -- 01:08:32,308
well so prescribe you're, you're
01:08:32,308 -- 01:08:33,408
increasing burden you're
01:08:33,408 -- 01:08:36,274
driving the last nail to the coffin we’ll
01:08:36,274 -- 01:08:37,841
now make it a little bit more flexible
01:08:37,841 -- 01:08:40,708
and hopefully, you know as small as that
01:08:40,708 -- 01:08:41,941
it might mean more work,
01:08:41,941 -- 01:08:47,341
but value add work to make it work and to make it flexible.
01:08:47,341 -- 01:08:48,141
And I would say
01:08:48,141 -- 01:08:51,608
there's a possibility in a mature
01:08:51,608 -- 01:08:54,274
framework for PBR that's actually less work.
01:08:54,274 -- 01:08:56,841
That's what I'd hope, right, less burden.
01:08:56,841 -- 01:08:59,174
So let's talk about well-managed plans
01:08:59,174 -- 01:09:01,308
that beneficiaries are protected.
01:09:01,308 -- 01:09:04,441
And if you have a problem, you call up the regulator
01:09:04,441 -- 01:09:07,341
and we try to develop
01:09:07,341 -- 01:09:11,741
a solution that doesn't require you to do unnecessary work.
01:09:11,741 -- 01:09:14,841
So there are examples of that that come up.
01:09:14,841 -- 01:09:17,808
Trevor's example on the surplus, there could have been, you,
01:09:17,808 -- 01:09:20,974
we could have said you need to go through a formal surplus
01:09:20,974 -- 01:09:22,308
sharing regime.
01:09:22,308 -- 01:09:25,908
You need to submit a surplus sharing application
01:09:25,908 -- 01:09:30,141
or an opinion on historical entitlement. We didn't do that, right.
01:09:30,141 -- 01:09:32,575
We found a solution that worked. So
01:09:34,175 -- 01:09:36,141
the other thought I have
01:09:36,141 -- 01:09:39,141
is that we certainly are in a transition, right?
01:09:39,141 -- 01:09:40,641
We're all trying to figure out
01:09:40,641 -- 01:09:43,408
what are the shared outcomes that we should be achieving
01:09:43,408 -- 01:09:44,375
and how to do that.
01:09:44,375 -- 01:09:46,175
So it'll take time.
01:09:46,175 -- 01:09:48,708
And I think, Claire, I would I appreciate that.
01:09:48,708 -- 01:09:50,808
Let's be patient with each other.
01:09:50,808 -- 01:09:54,075
We're not trying to actually increase the burden.
01:09:54,075 -- 01:09:55,075
I think, as Andrew said, we're
01:09:55,075 -- 01:09:58,375
trying to increase flexibility, support innovation
01:09:58,375 -- 01:10:01,941
while trying to achieve our statutory objects.
01:10:01,941 -- 01:10:05,275
So I think it could be good.
01:10:05,275 -- 01:10:06,308
It may not be good
01:10:06,308 -- 01:10:10,041
always, particularly in the more complex circumstances or easier,
01:10:10,041 -- 01:10:12,741
but the idea is
01:10:12,741 -- 01:10:16,608
hopefully more effective
01:10:16,608 -- 01:10:21,341
supervision that focuses on the real problems that matter.
01:10:21,341 -- 01:10:22,208
Thank you.
01:10:22,208 -- 01:10:24,275
Do I have time for one more question with you? Right. Okay.
01:10:24,275 -- 01:10:28,008
Thank you. So this question is for you, Trevor.
01:10:28,008 -- 01:10:30,775
So as an actuary dealing with numbers,
01:10:30,775 -- 01:10:33,108
seems like it's always black and white.
01:10:33,108 -- 01:10:35,208
How do you balance the rigor
01:10:35,208 -- 01:10:36,475
of working with numbers,
01:10:36,475 -- 01:10:38,608
with the flexibility of PBR in your work?
01:10:39,675 -- 01:10:45,441
People know that actuaries are not that black and white.
01:10:45,441 -- 01:10:47,108
I always joke that I'm not good at numbers.
01:10:47,108 -- 01:10:49,541
That's why I became an actuary.
01:10:49,541 -- 01:10:52,408
First of all, thank you for naming me in the question
01:10:52,408 -- 01:10:54,675
as opposed to the other one which anybody could have answered.
01:10:54,675 -- 01:10:55,975
But again,
01:10:55,975 -- 01:10:56,941
I think that's something we're dealing
01:10:56,941 -- 01:10:59,775
with as the regulator right now, is that, again,
01:10:59,775 -- 01:11:02,175
the answer isn't necessarily like, again,
01:11:02,175 -- 01:11:03,475
liabilities are liabilities,
01:11:03,475 -- 01:11:05,008
but the way we get there may be different
01:11:05,008 -- 01:11:06,275
and what we're actually going to do with them
01:11:06,275 -- 01:11:07,641
and how we approach them.
01:11:07,641 -- 01:11:09,308
What we're really looking at is,
01:11:09,308 -- 01:11:12,108
again, different circumstances and special situations
01:11:12,108 -- 01:11:15,075
that the Act and regs may not specifically apply to
01:11:15,075 -- 01:11:16,575
or if you as a plan sponsor.
01:11:16,575 -- 01:11:18,108
If you're working with a plan sponsor,
01:11:18,108 -- 01:11:19,941
there's a situation that's,
01:11:19,941 -- 01:11:20,175
you know,
01:11:20,175 -- 01:11:22,675
a little ambiguous within the Act or you want more guidance.
01:11:22,675 -- 01:11:25,508
That's the PBR, approach, especially within the actuarial team
01:11:25,508 -- 01:11:26,008
that we're looking
01:11:26,008 -- 01:11:27,608
to have conversations about
01:11:27,608 -- 01:11:28,675
or if there's a difficulty,
01:11:28,675 -- 01:11:31,308
if there's something within the Act and regs that you can't,
01:11:31,308 -- 01:11:32,541
you know, that
01:11:32,541 -- 01:11:33,941
that goes, it’s contrary to
01:11:33,941 -- 01:11:36,475
what you want to do with the ultimate goal of the plan sponsor.
01:11:36,475 -- 01:11:38,241
How can we work with that?
01:11:38,241 -- 01:11:40,908
We're not looking to change the numbers.
01:11:40,908 -- 01:11:42,341
Numbers are what the numbers are.
01:11:42,341 -- 01:11:45,008
That's why it's great to be an actuary.
01:11:45,008 -- 01:11:46,508
But at the same time,
01:11:46,508 -- 01:11:48,608
we want to be collaborative and work with you on it.
01:11:50,208 -- 01:11:51,708
It's great.
01:11:51,708 -- 01:11:55,008
So, do we have more questions or should I?
01:11:55,008 -- 01:11:55,475
One more.
01:11:55,475 -- 01:11:56,341
Okay, last one.
01:11:56,341 -- 01:12:02,075
And before I close.
01:12:02,075 -- 01:12:05,141
If you have a concern about the risk management
01:12:05,141 -- 01:12:09,608
governance issues, the JSPP or large public sector pension plans,
01:12:09,608 -- 01:12:13,808
what will you do about it, James? What will you do about it?
01:12:13,808 -- 01:12:18,542
Personally James, what will you personally do about it?
01:12:18,542 -- 01:12:22,075
I'll sit on it for a few weeks and
01:12:22,075 -- 01:12:24,408
think about how to broach the subject with Andrew
01:12:24,408 -- 01:12:26,508
and then further up the food chain.
01:12:26,508 -- 01:12:32,408
So this is a good question, so it speaks to a few things
01:12:33,642 -- 01:12:36,442
because, you know, so what we can do as a prudential regulator
01:12:36,442 -- 01:12:39,975
and also as a process. So,
01:12:39,975 -- 01:12:42,042
you know, if we have a concern, I think, well,
01:12:42,042 -- 01:12:42,908
you know, we would
01:12:42,908 -- 01:12:45,542
first of all have to identify that there's a concern
01:12:45,542 -- 01:12:47,642
and then there's a bit of a progression involved.
01:12:47,642 -- 01:12:50,042
That is, you know, we'll have to think internally.
01:12:50,042 -- 01:12:52,342
Okay, is this, is this really a concern?
01:12:52,342 -- 01:12:54,142
We have internal expertise.
01:12:54,142 -- 01:12:56,108
We have senior advisors that assist us.
01:12:56,108 -- 01:12:57,375
We have other people that,
01:12:58,342 -- 01:13:01,208
you know, within our organization that are fairly experts.
01:13:01,208 -- 01:13:04,642
So they've been internal discussion about, you know, are,
01:13:04,642 -- 01:13:06,575
you know, is this a real issue?
01:13:06,575 -- 01:13:09,142
Second is then we have conversations
01:13:09,142 -- 01:13:10,575
with the plan, plan management.
01:13:10,575 -- 01:13:13,608
Okay, are we are understanding this right.
01:13:13,608 -- 01:13:15,308
You know, how do you see the issue?
01:13:15,308 -- 01:13:16,842
And then ultimately,
01:13:16,842 -- 01:13:17,008
you know,
01:13:17,008 -- 01:13:18,142
we would look to the management
01:13:18,142 -- 01:13:21,142
to see if there's a way to remedy that,
01:13:21,142 -- 01:13:23,375
depending on the severity and the process.
01:13:23,375 -- 01:13:24,975
I think what we could see
01:13:24,975 -- 01:13:26,208
is then
01:13:26,208 -- 01:13:28,942
a situation where we would make our views known,
01:13:28,942 -- 01:13:31,742
assuming that we're correct, that there is an issue we could
01:13:31,742 -- 01:13:32,675
we would have a process
01:13:32,675 -- 01:13:36,908
where we could make our views known to the, the plan, likely
01:13:36,908 -- 01:13:39,075
through, through correspondence
01:13:39,075 -- 01:13:41,942
that would be accessible by the board as well as management.
01:13:41,942 -- 01:13:44,842
And we'd look to the plan, to
01:13:44,842 -- 01:13:48,375
either rectify that issue or give us satisfactory explanation
01:13:48,375 -- 01:13:49,842
as to why
01:13:49,842 -- 01:13:55,042
no action is taken. That kind of a process, ultimately
01:13:55,042 -- 01:13:56,908
is one of transparency
01:13:56,908 -- 01:14:00,708
and it allows the plan visibility in to concerns,
01:14:00,708 -- 01:14:04,408
but also allows the fiduciaries of those plans.
01:14:04,408 -- 01:14:06,542
I’m thinking here specifically the board
01:14:06,542 -- 01:14:08,908
and the executive management,
01:14:08,908 -- 01:14:11,542
they also have visibility and they can,
01:14:11,542 -- 01:14:12,742
you know, with that information,
01:14:12,742 -- 01:14:17,142
they can then decide what their fiduciary duty is and respond
01:14:17,142 -- 01:14:17,942
to that issue.
01:14:19,042 -- 01:14:21,442
So that's how I see what we will do about it.
01:14:21,442 -- 01:14:21,675
You know,
01:14:21,675 -- 01:14:23,508
I think there's you know, ultimately
01:14:23,508 -- 01:14:25,542
we have to rely on the plans
01:14:25,542 -- 01:14:29,475
as plan administrators to exercise their fiduciary duty
01:14:29,475 -- 01:14:32,708
and depending on the situation, we'll see where things go.
01:14:32,708 -- 01:14:35,608
And in a way that's not different from how we've been handling
01:14:35,608 -- 01:14:38,242
single employee pension plans and multiemployer pension plans.
01:14:38,242 -- 01:14:40,042
We have a dialog to understand
01:14:40,042 -- 01:14:42,275
where the gap is, where our perspective,
01:14:42,275 -- 01:14:43,875
have a mutual understanding,
01:14:43,875 -- 01:14:46,042
and then, and then and take it from there
01:14:46,042 -- 01:14:50,242
in terms of coming up with a remedial solutions.
01:14:50,242 -- 01:14:51,342
So time is up.
01:14:51,342 -- 01:14:55,742
I want to conclude by giving you
01:14:55,742 -- 01:14:58,975
I guess, summarizing what I believe to be
01:14:58,975 -- 01:15:01,942
principals-based regulations, hearing
01:15:01,942 -- 01:15:05,142
from my fellow panelists, I'm a simple guy.
01:15:05,142 -- 01:15:08,842
I like to leave you with three thoughts, just three things.
01:15:08,842 -- 01:15:12,542
First, PBR is a cultural change.
01:15:13,509 -- 01:15:15,942
It's a change management
01:15:15,942 -- 01:15:18,109
on a part of the regulator,
01:15:18,109 -- 01:15:21,342
but it's a two way street, also a change to the sector.
01:15:21,342 -- 01:15:22,109
We changed.
01:15:22,109 -- 01:15:25,175
We're doing away with prescribed rules, we're doing away
01:15:25,175 -- 01:15:28,542
with prescription lists and all that stuff.
01:15:28,542 -- 01:15:31,942
But it's also a culture change on the part of the sector.
01:15:31,942 -- 01:15:32,909
We need
01:15:32,909 -- 01:15:35,642
a certain level of open mindedness
01:15:35,642 -- 01:15:40,009
to be able to make PBR a success going forward.
01:15:40,009 -- 01:15:42,409
So that's point number one.
01:15:42,409 -- 01:15:46,275
Point number two is good faith and trust.
01:15:46,275 -- 01:15:49,075
As I mentioned before, our going in position,
01:15:49,075 -- 01:15:50,875
when we look at the pension plan,
01:15:50,875 -- 01:15:51,942
whether single employer,
01:15:51,942 -- 01:15:53,742
multiemployer or LPSPP,
01:15:53,742 -- 01:15:54,675
is that
01:15:54,675 -- 01:15:58,009
the going assumption is that you know what you're doing,
01:15:58,009 -- 01:16:00,709
you know what fiduciary duty is.
01:16:00,709 -- 01:16:03,309
We're not there to catch you. We're not there to catch thieves.
01:16:04,342 -- 01:16:08,009
We are there to collect data to verify
01:16:08,009 -- 01:16:10,175
that you are doing what you're doing.
01:16:10,175 -- 01:16:12,742
Show us as opposed to just tell us what you do.
01:16:12,742 -- 01:16:18,342
It is a verifying exercise to exercise and discharge our duty.
01:16:18,342 -- 01:16:23,175
A third one is collaboration, and cooperation is a key thing.
01:16:23,175 -- 01:16:26,175
You've heard the example through the single employer-pension
01:16:26,175 -- 01:16:28,009
plan, the multi-employer pension plans,
01:16:28,009 -- 01:16:33,009
and I'm hoping to see that from the large plans as well to
01:16:33,009 -- 01:16:37,909
PBR might feel that is two step forward, one step backwards.
01:16:37,909 -- 01:16:40,875
That's growing pain, unique time to adjust.
01:16:40,875 -- 01:16:41,975
Well, where is the list, right?
01:16:41,975 -- 01:16:45,542
That first question that came, where's the list? There's no list.
01:16:45,542 -- 01:16:46,742
Okay.
01:16:46,742 -- 01:16:49,042
People might think that this is,
01:16:49,042 -- 01:16:52,409
I was once in the conference about a year ago
01:16:52,409 -- 01:16:54,709
and I was on the
01:16:54,709 -- 01:16:55,642
panel list like this,
01:16:55,642 -- 01:16:59,842
and they said, well, this is a rise in regulatory activism.
01:16:59,842 -- 01:17:02,042
And I said, well, that's a good thing.
01:17:02,042 -- 01:17:02,875
That's a good thing
01:17:02,875 -- 01:17:06,409
because rise in regulatory activism means that we care.
01:17:06,409 -- 01:17:09,909
It doesn't mean that we got it right the first time. We care.
01:17:09,909 -- 01:17:12,142
We have the courage to try,
01:17:12,142 -- 01:17:13,642
and if it's wrong,
01:17:13,642 -- 01:17:17,175
we rely on the feedback loop to course correct immediately.
01:17:17,175 -- 01:17:18,775
So that's the all the three points
01:17:18,775 -- 01:17:21,142
that I want to leave the sector with.
01:17:21,142 -- 01:17:25,209
Again, I want, let me repeat ,as a culture change two way street
01:17:25,209 -- 01:17:29,375
faith and commitment. Trust is critical.
01:17:29,375 -- 01:17:31,842
And collaboration and continued communication.
01:17:31,842 -- 01:17:36,375
So I want to thank everyone for participating. Great questions.
01:17:36,375 -- 01:17:39,042
I want to thank my colleagues and the panel
01:17:39,042 -- 01:17:42,975
to share their experience with us. We will be around.
01:17:42,975 -- 01:17:44,509
I hope to see some of you
01:17:44,509 -- 01:17:49,309
staying behind, you know, for our refreshment bar, open bar
01:17:49,309 -- 01:17:50,342
or something like that. But
01:17:52,309 -- 01:17:54,009
so thank you very much, everyone.
00:00:04,270 -- 00:00:07,273
Good afternoon, everybody.
00:00:09,442 -- 00:00:11,444
Welcome to the FSRA
00:00:11,444 -- 00:00:14,514
2024 Auto Panel discussion.
00:00:14,881 -- 00:00:18,418
Today we're going to be talking about auto insurance rating and underwriting
00:00:18,418 -- 00:00:22,722
supervision and the new guidance that will be released later this year.
00:00:22,756 -- 00:00:26,493
So, I'm looking forward to a really lively discussion with everybody.
00:00:26,493 -- 00:00:29,262
Before we get into the panel conversation.
00:00:29,262 -- 00:00:31,865
Just a few kind of housekeeping things.
00:00:31,865 -- 00:00:36,402
The session, of course, is being recorded as were all of the other FSRA sessions.
00:00:36,402 -- 00:00:39,172
If you need a simultaneous French, French
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translation that is available, so put your hand up.
00:00:42,208 -- 00:00:44,811
And there are some instructions on the slide as well, for those of you
00:00:44,811 -- 00:00:48,515
that are virtual that might want to receive French translation
00:00:48,515 -- 00:00:51,417
through the web portal.
00:00:51,417 -- 00:00:52,819
So please go ahead and do that.
00:00:52,819 -- 00:00:53,920
If you want to ask a question, please
00:00:53,920 -- 00:00:57,390
submit it online through the, the conference channel.
00:00:57,824 -- 00:01:00,727
You can also raise your hand and write down your question
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and then it will pop up on the screen for me
00:01:02,495 -- 00:01:04,998
and we can answer it during the Q&A session.
00:01:05,932 -- 00:01:06,733
So that's it.
00:01:06,733 -- 00:01:08,067
We'll get started.
00:01:08,067 -- 00:01:10,904
There will be, we're going to go through a panel discussion, of course,
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and then there will be some time for audience Q&A at the end as well.
00:01:14,774 -- 00:01:16,976
If we don't have time to get through all the questions, don't worry.
00:01:16,976 -- 00:01:19,979
We will answer every single question that comes to us.
00:01:19,979 -- 00:01:23,716
Some of them will be responded to via a Q&A
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after the panel discussion sometime later this week.
00:01:27,787 -- 00:01:29,155
So we'll get started.
00:01:29,155 -- 00:01:32,125
I want to take a few minutes just to introduce our panelists.
00:01:32,125 -- 00:01:33,993
I'll start with myself just very briefly.
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My name is Michelle Dodokin,
00:01:35,161 -- 00:01:38,531
and I'm the new Head of Auto Insurance Supervision with FSRA.
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This is my seventh week, so it's still really new,
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but I am not new to the industry.
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I have 15 years experience in property and casualty insurance,
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and I've worked for some of the largest P&C companies in Canada.
00:01:51,644 -- 00:01:55,915
So bringing a lot of experience, very, very excited about the transformation
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that's happening at FSRA and really excited to talk to you today
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about principles based regulation and the new supervisory guidance.
00:02:03,856 -- 00:02:06,192
I'm going to start with Roosevelt.
00:02:06,192 -- 00:02:11,297
Roosevelt is a Principal and Consulting Actuary with Pinnacle Actuary Resources.
00:02:11,297 -- 00:02:14,066
He's an expert in predictive analytics applications
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for all insurance functions, rate making and product development,
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strategic reviews, competitive, competitive analysis and litigation support.
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Roosevelt is recognized as an industry expert in the analysis of unfair
00:02:26,045 -- 00:02:30,950
discrimination and bias in rating, really important topic for today.
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Roosevelt is on the leading edge of research on this issue
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and also provides services to clients in this area, including testing
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insurance company processes and providing training.
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Roosevelt is past president of the Casualty Actuarial Society.
00:02:44,997 -- 00:02:47,833
Has served as Vice President of Marketing Communications
00:02:47,833 -- 00:02:50,836
and is the Board Chair, of CAS.
00:02:51,437 -- 00:02:55,308
Roosevelt is also a board member on the International Association of Black
00:02:55,308 -- 00:03:00,479
Actuaries Foundation and is an Emeritus Trustee of the Actuarial Foundation.
00:03:01,547 -- 00:03:03,316
Turning to Michelle Huang,
00:03:03,316 -- 00:03:06,786
Michelle Huang is a seasoned leader in advanced analytics and corporate
00:03:06,786 -- 00:03:10,790
risk management in her 18 year career in banking and insurance.
00:03:10,790 -- 00:03:13,292
She's taken various modeling and risk management
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roles from market risk to vice president of Capital Modeling,
00:03:16,862 -- 00:03:19,799
collateral analytics and model validation
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to head of model risk management.
00:03:22,535 -- 00:03:26,105
She's currently senior director of model validation at Discover
00:03:26,105 -- 00:03:30,176
Financial Services, overseeing validation and risk management of
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AI and ML models used for consumer credit underwriting,
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portfolio risk management, marketing, fraud detection and collection.
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Michelle has a Ph.D.
00:03:40,686 -- 00:03:44,156
in Mechanical and Aerospace Engineering and a Masters of Science
00:03:44,156 -- 00:03:47,159
in Statistics from Rutgers University.
00:03:48,361 -- 00:03:49,261
On my far
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left, we have Liz Bellefleur-MacCaul.
00:03:52,665 -- 00:03:56,402
Liz is a Senior Actuarial Analyst at Definity.
00:03:56,402 -- 00:03:59,538
Liz is primary responsibility is the development of predictive models
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and analytics solutions, both for traditional pricing
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use cases and non-pricing business needs.
00:04:05,578 -- 00:04:09,215
Since its inception, Liz has been an active and inaugural member of Definity’s
00:04:09,215 -- 00:04:13,452
cross-functional working group for addressing the impact of social bias
00:04:13,452 -- 00:04:16,789
and fairness in predictive modeling and analytics.
00:04:17,289 -- 00:04:20,593
Liz is also Vice Chair of the Women's Empowerment Group and as a champion
00:04:20,593 -- 00:04:24,463
of inclusion, diversity, equity and accessibility in the workplace.
00:04:24,930 -- 00:04:28,000
This year she'll be stepping out of that role to advance Definity’s
00:04:28,000 -- 00:04:31,237
work around disability and accessibility.
00:04:31,570 -- 00:04:35,608
As a community member herself, Liz envisions a workplace where disability is
00:04:35,608 -- 00:04:39,912
embraced as an integral part of diversity, such that employees of all abilities
00:04:39,912 -- 00:04:43,482
can bring their authentic selves to work and to thrive.
00:04:44,683 -- 00:04:47,553
So thank you for joining us today.
00:04:47,553 -- 00:04:48,787
I thought maybe
00:04:48,787 -- 00:04:50,689
this is a panel discussion, but I thought maybe a good place to start
00:04:50,689 -- 00:04:55,694
would be to give an overview on FSRA’s auto rate and underwriting strategy.
00:04:55,761 -- 00:04:58,564
And then a bit of a primer on principles based regulation
00:04:58,564 -- 00:05:01,834
and then a summary of our supervisory guidance.
00:05:02,434 -- 00:05:06,071
So starting with our overall strategy, there are three pillars to the strategy.
00:05:06,438 -- 00:05:10,743
The first, no surprises here, is a fair rating and underwriting.
00:05:10,743 -- 00:05:14,680
So this is the basis for which, how we evaluate
00:05:14,680 -- 00:05:17,683
whether rates are considered just and reasonable.
00:05:17,683 -- 00:05:18,917
And we'll be talking a lot
00:05:18,917 -- 00:05:23,055
about, about that because that's the basis of our supervisory guidance.
00:05:23,055 -- 00:05:26,692
The second one is about promoting market health and efficient regulation.
00:05:26,692 -- 00:05:32,031
So this is about more competition, more innovation, more choices for consumers.
00:05:32,031 -- 00:05:35,834
And the third pillar is informed decision making.
00:05:35,834 -- 00:05:39,204
So this is a topic, of course, that is not new to the industry,
00:05:39,204 -- 00:05:43,042
helping consumers better understand what they're covered for,
00:05:43,042 -- 00:05:47,813
how their premium is calculated, what their choices are in terms of pricing
00:05:47,813 -- 00:05:50,182
and other aspects that they might want to consider in terms
00:05:50,182 -- 00:05:51,417
of the value proposition.
00:05:53,685 -- 00:05:56,688
So Joanne, this morning did a very, did
00:05:56,688 -- 00:06:00,559
an excellent job actually of explaining principles based regulation
00:06:00,559 -- 00:06:04,730
and how that's different from a rules based regulatory model.
00:06:04,730 -- 00:06:06,365
Maybe we can delve a little bit deeper
00:06:06,365 -- 00:06:08,801
in terms of what that means for auto insurance.
00:06:08,801 -- 00:06:12,070
So in a rules based model, of course,
00:06:12,271 -- 00:06:15,274
it's a very, it's a much more prescriptive environment.
00:06:15,407 -- 00:06:16,408
We know what that's all about.
00:06:16,408 -- 00:06:18,477
It's the environment that we've been operating in.
00:06:18,477 -- 00:06:22,748
But the challenges associated with that are just more lag in the system.
00:06:22,748 -- 00:06:24,983
Change tends to happen slowly.
00:06:24,983 -- 00:06:27,853
There are a lot of constraints and it really inhibits innovation
00:06:27,853 -- 00:06:31,023
that some of the things that we're trying to promote with our new strategy.
00:06:32,090 -- 00:06:35,694
Generally speaking, for auto insurance companies,
00:06:35,694 -- 00:06:39,131
that also means that rates lag the trends as well.
00:06:39,131 -- 00:06:42,501
So you're always kind of behind and trying to catch up with rates
00:06:42,501 -- 00:06:46,705
because, because it takes a long time to move rates through.
00:06:46,705 -- 00:06:49,875
And, and there's an onerous regulatory process.
00:06:49,875 -- 00:06:52,544
So we've been making some of those changes within FSRA
00:06:52,544 -- 00:06:53,812
over the last couple of years.
00:06:53,812 -- 00:06:57,249
And the supervisory guidance is a really big step
00:06:57,249 -- 00:07:00,385
in terms of moving forward to principles based regulation.
00:07:00,385 -- 00:07:04,056
And so it makes sense for us to spend a lot of time both in this session
00:07:04,056 -- 00:07:07,392
and I think in the coming months, really understanding what that means
00:07:07,392 -- 00:07:11,663
in terms of how FSRA will work together with the industry in the future.
00:07:12,564 -- 00:07:13,832
So within the context of
00:07:13,832 -- 00:07:17,135
principles based regulation, the focus is on outcomes.
00:07:17,135 -- 00:07:19,971
So not so much on rules, but on outcomes.
00:07:19,971 -- 00:07:21,573
But it doesn't mean that there are no rules.
00:07:21,573 -- 00:07:26,511
There are still rules, but the rules are aligned to the desired outcomes,
00:07:26,511 -- 00:07:30,816
and there's more flexibility around how they are applied and the rules are in line
00:07:30,816 -- 00:07:34,152
with achieving those desired outcomes.
00:07:34,319 -- 00:07:36,955
So within that flexibility, we're hoping again,
00:07:36,955 -- 00:07:40,859
that's going to stimulate more competition in the industry and new business
00:07:40,859 -- 00:07:45,630
models, new product ideas, and really start to reduce that
00:07:45,630 -- 00:07:48,233
regulatory lag that I was talking about before with rates
00:07:48,233 -- 00:07:51,236
and trends.
00:07:51,436 -- 00:07:53,105
So here is an example
00:07:53,105 -- 00:07:56,741
of, real life example, of principles based regulation.
00:07:56,741 -- 00:08:00,145
The autobahn is one example that comes up often.
00:08:00,145 -- 00:08:00,812
And so I thought
00:08:00,812 -- 00:08:03,982
maybe we could look at this and look at the difference between a rules
00:08:03,982 -- 00:08:07,519
based regulatory model and a principles based regulatory model.
00:08:07,819 -- 00:08:12,457
So in a rules based model, we say, okay, the speed limit is 100 kilometers an hour
00:08:12,624 -- 00:08:16,728
and a principles based model we say, okay, our principle is safe driving
00:08:16,728 -- 00:08:20,665
and our desired outcomes are fewer accidents, injuries and fatalities.
00:08:20,665 -- 00:08:23,068
And what's important about that also is
00:08:23,068 -- 00:08:25,770
that the outcome is all, is measurable.
00:08:25,770 -- 00:08:27,539
And so we know what the principle is.
00:08:27,539 -- 00:08:30,208
We can all agree that it's really important and the outcome
00:08:30,208 -- 00:08:33,545
is easy for us to measure in terms of whether or not it's been achieved.
00:08:34,012 -- 00:08:36,314
But even in this context, where there are fewer
00:08:36,314 -- 00:08:39,150
prescriptive rules, there are still rules.
00:08:39,217 -- 00:08:41,486
There are guidelines on the autobahn.
00:08:41,486 -- 00:08:46,925
So there's an, out of, an advisory speed of 130 kilometers an hour.
00:08:46,925 -- 00:08:50,362
And then, of course, you need to use your judgment around road conditions.
00:08:50,362 -- 00:08:53,732
You know, if there's bad weather, if there's heavy traffic, you need to decide, you know,
00:08:53,732 -- 00:08:58,770
what's an appropriate speed, even though there isn't an enforceable speed limit.
00:08:58,770 -- 00:09:01,206
And in most parts of the autobahn.
00:09:01,906 -- 00:09:03,141
There are also rules.
00:09:03,141 -- 00:09:05,777
Some of them are enforceable with fines as well.
00:09:05,777 -- 00:09:07,445
So the roads are monitored.
00:09:07,445 -- 00:09:08,513
Stay right.
00:09:08,513 -- 00:09:11,683
Stay to the right, keep safe distance, distance from other drivers.
00:09:11,683 -- 00:09:15,286
So no tailgating, no passing zones, things like that.
00:09:15,353 -- 00:09:18,390
So you can be pulled over and you can be fined for some of those things.
00:09:18,390 -- 00:09:20,258
And then there are circumstance rules.
00:09:20,258 -- 00:09:24,763
So in scenarios where there's construction on the road, for example,
00:09:24,763 -- 00:09:30,135
there might be posted speed limits and then again those are enforceable.
00:09:30,135 -- 00:09:33,872
So we can see here how there is more flexibility in the principles
00:09:33,872 -- 00:09:37,709
based model, but there are still rules that create structure.
00:09:37,709 -- 00:09:40,612
So it's almost like guardrails to ensure
00:09:40,612 -- 00:09:44,282
that everyone stays on track to reach the desired outcomes.
00:09:46,384 -- 00:09:49,220
So this is a bit of a sneak peek
00:09:49,220 -- 00:09:52,791
into our auto rating and underwriting supervisory guidance.
00:09:52,791 -- 00:09:56,027
This is still in draft, I think, which which most of you know.
00:09:56,027 -- 00:09:57,762
So we're going to have some good discussions around this today.
00:09:57,762 -- 00:10:01,132
But keeping in mind that it's still very much in development.
00:10:01,566 -- 00:10:05,069
This will be released for consultation in the fall to the industry.
00:10:05,069 -- 00:10:07,539
So we'll be looking forward to your feedback.
00:10:07,539 -- 00:10:11,109
But that doesn't mean that we shouldn't have any discussions between now and then.
00:10:11,109 -- 00:10:14,245
This is a bit of an introduction and it opens the conversation
00:10:14,245 -- 00:10:17,248
and we'll keep talking about that as time goes on.
00:10:18,683 -- 00:10:21,252
So there are four chapters in the new supervisory guidance.
00:10:21,252 -- 00:10:23,421
The first one is fairness.
00:10:23,421 -- 00:10:27,258
We've, it's not our only principle for rating and underwriting,
00:10:27,258 -- 00:10:30,828
but it is a really critical one and we want to make sure that we get it right.
00:10:30,828 -- 00:10:33,565
We've dedicated a whole chapter to that.
00:10:33,565 -- 00:10:37,368
It's not surprisingly also really difficult for the industry
00:10:37,368 -- 00:10:41,072
to agree on a common definition of fairness.
00:10:41,072 -- 00:10:42,307
It's really challenging.
00:10:42,307 -- 00:10:45,209
You could look at this from a number of different angles.
00:10:45,209 -- 00:10:49,280
Our approach has been to focus, not surprisingly, on principles,
00:10:49,280 -- 00:10:53,751
and some of those principles are unfair bias, discrimination, proxy
00:10:53,751 -- 00:10:56,821
discrimination, rating accuracy, things like
00:10:56,821 -- 00:11:00,358
that as being really core elements to fairness.
00:11:00,358 -- 00:11:04,962
And again, how we evaluate whether rates are just and reasonable.
00:11:05,997 -- 00:11:07,799
The second pillar
00:11:07,799 -- 00:11:11,302
is what we call operations, governance and control.
00:11:11,302 -- 00:11:14,906
So this would be akin to, you know, what you would think about
00:11:14,906 -- 00:11:18,910
is your operational risk management processes within your organization.
00:11:18,910 -- 00:11:22,547
These will be very familiar to insurers.
00:11:22,547 -- 00:11:25,983
A statement of risk appetite with thresholds and limits.
00:11:25,983 -- 00:11:27,585
We all know about that.
00:11:27,585 -- 00:11:31,089
Three lines of defense and risk management clearly defined roles
00:11:31,089 -- 00:11:32,557
and accountability.
00:11:32,557 -- 00:11:37,695
So governance, strong data governance and model risk management.
00:11:37,695 -- 00:11:41,866
So these are really, really key capabilities that exist
00:11:41,866 -- 00:11:46,003
within most mid-sized to large size organizations.
00:11:46,003 -- 00:11:49,974
It could be that there's some strengthening that's needed in
00:11:49,974 -- 00:11:51,209
some of these areas.
00:11:51,209 -- 00:11:54,879
And so as we build out the the supervisory
00:11:54,879 -- 00:11:58,983
guidance, we'll provide more detail in terms of what our expectations are.
00:11:58,983 -- 00:12:02,420
But I think the key takeaway here is that most organizations
00:12:02,420 -- 00:12:04,121
already have these capabilities.
00:12:04,121 -- 00:12:07,792
So it's really just about tightening them and making sure that there's a really
00:12:07,792 -- 00:12:09,193
strong base to work from.
00:12:10,394 -- 00:12:10,862
The third
00:12:10,862 -- 00:12:14,832
chapter is our assessment guidance.
00:12:15,233 -- 00:12:17,969
So as many of you would know,
00:12:17,969 -- 00:12:22,206
in and that we've shared previously, within the supervisory guidance,
00:12:22,206 -- 00:12:25,810
there will be an opportunity for companies to become accredited.
00:12:26,043 -- 00:12:28,779
And when a company becomes accredited, that gives them
00:12:28,779 -- 00:12:32,750
the opportunity to enjoy more streamlined
00:12:32,750 -- 00:12:37,121
filing requirements, just a faster speed to market, things like that.
00:12:37,288 -- 00:12:41,993
So chapter three outlines the process
00:12:41,993 -- 00:12:45,596
for achieving accreditation, which is the assessment.
00:12:46,230 -- 00:12:49,600
So we'll be looking at fairness practices,
00:12:49,600 -- 00:12:51,635
certainly within your organization.
00:12:51,635 -- 00:12:55,006
And many companies are already working on that as well as some of those
00:12:55,006 -- 00:12:57,508
ORM capabilities that are related to
00:12:57,508 -- 00:13:00,511
rating and underwriting.
00:13:00,845 -- 00:13:02,480
Not every company needs
00:13:02,480 -- 00:13:05,616
to pursue accreditation and you get to choose the timing as well.
00:13:05,616 -- 00:13:09,053
So organizations will decide, when they're ready
00:13:09,053 -- 00:13:11,922
to undergo an assessment with FSRA and decide
00:13:11,922 -- 00:13:15,326
whether or not they feel that that's right for them.
00:13:15,559 -- 00:13:19,463
I would expect that most medium to large size organizations
00:13:19,463 -- 00:13:22,500
will pursue accreditation when they feel that they're ready.
00:13:22,633 -- 00:13:25,669
It could be that small organizations choose not to.
00:13:25,669 -- 00:13:29,206
It could be organizations that file very infrequently.
00:13:29,206 -- 00:13:34,512
But our hope certainly is that most of the industry pursues accreditation
00:13:34,512 -- 00:13:37,548
and can start to enjoy some of the benefits of that,
00:13:37,548 -- 00:13:41,018
of additional flexibility and innovation and things like that.
00:13:42,186 -- 00:13:42,920
The final chapter in
00:13:42,920 -- 00:13:46,724
the guidance is the new, new filing guidance.
00:13:46,724 -- 00:13:50,594
So the intention is to replace our existing standard filing guidance
00:13:50,594 -- 00:13:55,332
and our major filing guidance and consolidate that in chapter four.
00:13:55,499 -- 00:13:57,735
So the chapter four filing guidance
00:13:57,735 -- 00:14:03,173
will include the filing requirements for organizations that are accredited
00:14:03,173 -- 00:14:06,610
and also non-accredited organizations.
00:14:10,848 -- 00:14:14,118
So as I mentioned before, many companies are already on this journey.
00:14:14,118 -- 00:14:17,788
We did some work in the fall, sent out some surveys to the industry
00:14:17,788 -- 00:14:21,725
to try to understand where they're at in terms of their ORM
00:14:21,892 -- 00:14:25,262
capabilities and where they're at in terms of their fairness journeys.
00:14:25,262 -- 00:14:27,765
And what we found was that more than two
00:14:27,765 -- 00:14:31,135
thirds of organizations are already on this path.
00:14:31,135 -- 00:14:34,204
Numbers, in fact, even a little bit, a little bit higher than that.
00:14:34,204 -- 00:14:35,973
But there are some
00:14:35,973 -- 00:14:39,176
some gaps just through conversation that we're starting to uncover.
00:14:39,176 -- 00:14:44,114
So I would say those areas are things like model risk management,
00:14:45,215 -- 00:14:48,719
data governance, three lines of defense, and ensuring
00:14:48,719 -- 00:14:52,690
that you have technical capabilities built into second line
00:14:52,690 -- 00:14:55,259
so that they can provide support to first line.
00:14:55,259 -- 00:14:57,995
So those are some of the areas that we'll dig into a little bit deeper.
00:14:57,995 -- 00:15:00,330
And our panelists will have a perspective on that,
00:15:00,330 -- 00:15:03,500
that I think is really, will be really important to share today.
00:15:04,935 -- 00:15:05,936
And again, as I mentioned
00:15:05,936 -- 00:15:09,940
before, insurers are in control of the timeline
00:15:09,940 -- 00:15:12,910
just in some of the conversations I've had with, with the industry
00:15:12,910 -- 00:15:17,081
since I've been at FSRA, there are some misconceptions about
00:15:17,081 -- 00:15:22,252
how the assessment process will work or whether it will be required.
00:15:22,252 -- 00:15:25,322
And so I just wanted to make sure that we got some of those messages out
00:15:25,322 -- 00:15:28,325
and made sure that that was clear.
00:15:30,160 -- 00:15:32,830
I'm not going to spend a lot of time on this slide, but certainly
00:15:32,830 -- 00:15:37,234
there's been a tremendous amount of work that has gotten us to this point
00:15:37,234 -- 00:15:40,604
research, consultations with various different
00:15:40,604 -- 00:15:44,074
stakeholders and all of that feedback and all of that research has helped
00:15:44,074 -- 00:15:49,146
to inform the supervisory guidance that is currently being drafted now.
00:15:49,146 -- 00:15:52,716
So if you have any questions about that, we can, happy to chat with you about it.
00:15:53,951 -- 00:15:55,152
So here's what we're going.
00:15:55,152 -- 00:15:58,589
You know, lots of actions to date for sure.
00:15:58,589 -- 00:16:02,626
The supervisory guidance is currently being drafted by our team.
00:16:02,626 -- 00:16:05,495
We're sharing that with the technical advisory committees,
00:16:05,495 -- 00:16:08,498
which on the technical advisory committees, we have representatives
00:16:08,498 -- 00:16:13,470
from across the industry that are already beginning to provide feedback.
00:16:13,837 -- 00:16:16,974
That guidance will be released to the industry
00:16:16,974 -- 00:16:19,409
in August/September of this year.
00:16:19,409 -- 00:16:22,212
It will be finalized in March of next year
00:16:22,212 -- 00:16:26,049
and then will be in effect towards the end of 2025.
00:16:27,517 -- 00:16:30,754
If there are insurers out there that are, already know
00:16:30,754 -- 00:16:34,191
that they're interested in pursuing accreditation, we'd like to hear from you.
00:16:34,191 -- 00:16:37,794
We're looking for organizations that would like to be part of a pilot
00:16:37,794 -- 00:16:40,497
as we start rolling out the supervisory guidance.
00:16:40,497 -- 00:16:44,368
So at a separate time, reach out to us and let us know
00:16:44,368 -- 00:16:46,236
and then we can start planning for that.
00:16:48,538 -- 00:16:49,139
Okay.
00:16:49,139 -- 00:16:53,710
So what we're talking about today, obviously really understanding the
00:16:53,710 -- 00:16:57,914
benefits of principles based regulation as it relates to auto insurance,
00:16:58,048 -- 00:17:00,650
how to deeply embed some of those
00:17:00,650 -- 00:17:03,386
ORM practices into the organization.
00:17:03,386 -- 00:17:07,290
What we're finding is that these practices are really well
00:17:07,290 -- 00:17:12,262
known in the pricing and actuarial areas and in risk management.
00:17:12,262 -- 00:17:14,264
But sort of beyond that, there,
00:17:14,264 -- 00:17:18,368
you know, there's, there's less knowledge, less awareness.
00:17:18,468 -- 00:17:22,205
You know, they're not necessarily built in to decision making.
00:17:22,205 -- 00:17:25,208
So those are things that are going to be really important for the future
00:17:25,208 -- 00:17:28,812
mitigation of bias and discrimination
00:17:28,812 -- 00:17:31,515
in rating and underwriting models.
00:17:31,515 -- 00:17:34,317
Again, not a new topic, but a lot more focus
00:17:34,317 -- 00:17:37,854
and a lot more discussion about how to do this properly,
00:17:37,854 -- 00:17:41,958
how to make sure that those processes are embedded
00:17:41,958 -- 00:17:45,996
in your decision making and how to evaluate,
00:17:45,996 -- 00:17:50,400
how to evaluate your models and underwriting policies.
00:17:50,400 -- 00:17:52,602
And then the last point is just about
00:17:52,602 -- 00:17:56,006
working together as an industry to lead through the change.
00:17:56,006 -- 00:17:59,776
Mark and Joanne stressed this morning that within the context of a principles
00:17:59,776 -- 00:18:03,413
based model, there is a lot of ongoing discussion
00:18:03,413 -- 00:18:07,651
between the regulator and the, and the regulated industry.
00:18:08,018 -- 00:18:10,754
There's more data sharing, there's more conversation,
00:18:10,754 -- 00:18:14,457
there's a responsibility on the part of the regulator to understand
00:18:14,457 -- 00:18:16,826
the business context and the business strategy
00:18:16,826 -- 00:18:19,462
to be able to properly apply some of the principles
00:18:19,462 -- 00:18:23,199
that will be important to our decision making in the future.
00:18:25,135 -- 00:18:25,835
So I’ll pause
00:18:25,835 -- 00:18:29,139
there, and we will move to our panel discussion.
00:18:29,139 -- 00:18:32,142
I'm going to keep the slide up on the screen so
00:18:32,642 -- 00:18:34,577
so you can address our panelists by
00:18:34,577 -- 00:18:37,580
and, by name, which I think is important.
00:18:37,881 -- 00:18:40,884
And just one moment here.
00:18:41,751 -- 00:18:42,152
Okay.
00:18:42,152 -- 00:18:46,556
So my first question is going to be for Roosevelt.
00:18:46,556 -- 00:18:50,326
Roosevelt, can you talk to us about how principles based
00:18:50,860 -- 00:18:54,297
regulation enhances consumer protection?
00:18:54,297 -- 00:18:54,731
Sure.
00:18:54,731 -- 00:18:56,599
Thank you, Michelle.
00:18:56,599 -- 00:18:57,834
And I apologize upfront.
00:18:57,834 -- 00:19:00,503
I don't know what I'm dealing with, but
00:19:00,503 -- 00:19:03,907
my voice is kind of going in and out, so hopefully you can hear me okay.
00:19:04,441 -- 00:19:08,178
And I appreciate the opportunity to be here with you today.
00:19:08,178 -- 00:19:11,514
I actually got a chance to speak last year at the FSRA exchange,
00:19:11,514 -- 00:19:14,851
and I must not have done too badly since you invited me back.
00:19:14,851 -- 00:19:17,120
So, so thank you for that.
00:19:17,120 -- 00:19:20,223
So, I think a number of points
00:19:20,223 -- 00:19:23,326
highlighted in the slides that, that Michelle went through,
00:19:23,326 -- 00:19:26,529
really sort of zeroed the focus in on
00:19:26,529 -- 00:19:29,265
on consumer protection.
00:19:29,265 -- 00:19:32,702
But I think it's called out really specifically
00:19:32,702 -- 00:19:37,207
in one of the FSRA regulation guidelines.
00:19:37,207 -- 00:19:41,144
And, it's simply stated, a customer centric principle.
00:19:41,144 -- 00:19:44,714
And the idea is that the customer is,
00:19:44,714 -- 00:19:48,751
is at the center of the outcomes that you're trying to achieve.
00:19:48,751 -- 00:19:52,755
And so if you look at a lot of the things that are described,
00:19:52,755 -- 00:19:56,559
improving consumer outcomes,
00:19:56,626 -- 00:19:59,629
encouraging innovation,
00:19:59,729 -- 00:20:01,597
encouraging benefits for customers,
00:20:01,597 -- 00:20:06,736
a lot of that will lead towards customer, customer protection.
00:20:06,736 -- 00:20:09,305
And so
00:20:09,305 -- 00:20:10,840
fair treatment for
00:20:10,840 -- 00:20:14,477
customers, delivering value to the customers, fostering
00:20:14,477 -- 00:20:19,615
informed decision making in a rules based environment.
00:20:19,615 -- 00:20:22,151
But it's oftentimes
00:20:22,151 -- 00:20:25,121
the, the will of the,
00:20:25,121 -- 00:20:29,892
the lawmakers, the will of the regulators to, to try and establish rules
00:20:29,892 -- 00:20:34,063
that those who established them, rightly so, believe that,
00:20:34,063 -- 00:20:37,467
that will lead to that appropriate consumer outcome.
00:20:37,467 -- 00:20:42,305
But, but oftentimes you don't leave in those rules
00:20:42,305 -- 00:20:46,175
to flexibility to be able to adjust when perhaps those rules
00:20:46,175 -- 00:20:49,579
don't exactly have the outcome that that you that you so desire.
00:20:49,579 -- 00:20:53,749
And so the idea of the principles based guideline
00:20:53,749 -- 00:20:58,454
is that you've got companies and you've got regulation working together
00:20:58,454 -- 00:21:02,325
to focus on that true, the true customer outcome.
00:21:02,325 -- 00:21:07,497
And when you when you're able to do that, that allows both, again,
00:21:07,497 -- 00:21:10,833
the companies and regulators the flexibility to test
00:21:10,833 -- 00:21:14,670
whether those outcomes are happening and if they're not or if there are
00:21:14,670 -- 00:21:17,139
adjustments that need to be made, you can do that within the principles
00:21:17,139 -- 00:21:17,974
based environment.
00:21:19,475 -- 00:21:21,010
Roosevelt, is it really important
00:21:21,010 -- 00:21:23,479
for those outcomes to be measurable?
00:21:23,479 -- 00:21:28,918
I think having measurable outcomes is important.
00:21:28,918 -- 00:21:31,988
I also think it's important to recognize that not
00:21:31,988 -- 00:21:34,557
everything is going to be measurable as well.
00:21:34,557 -- 00:21:39,095
There are things that that that we’ll, we'll be able to test.
00:21:39,095 -- 00:21:43,599
In terms of fairness, which I know Liz is going to talk about here in a bit.
00:21:43,599 -- 00:21:46,969
There are things like fairness that we will be able to test.
00:21:46,969 -- 00:21:51,140
There are things like customer impact that we will be able to test,
00:21:51,140 -- 00:21:53,542
especially in the context of things like rates.
00:21:53,542 -- 00:21:55,878
But, but they're also going to be
00:21:55,878 -- 00:21:57,480
some elements that
00:21:57,480 -- 00:22:01,884
may not necessarily lend themselves to a direct
00:22:01,884 -- 00:22:06,088
testable measure with the pass/fail kind of, kind of approach.
00:22:06,088 -- 00:22:09,792
But again, it's sort of like the
00:22:09,792 -- 00:22:13,696
I'll know if there's a problem when I maybe when I see it.
00:22:13,696 -- 00:22:16,899
And so you've got to understand that the outcomes
00:22:16,899 -- 00:22:18,200
certainly should be measurable.
00:22:18,200 -- 00:22:22,304
And I think it does provide that, that level
00:22:22,304 -- 00:22:25,441
or at least the, the known playing field.
00:22:25,441 -- 00:22:29,145
But you've also got to, to realize and I think it was said earlier
00:22:29,145 -- 00:22:31,914
this morning that, that there will at some point,
00:22:31,914 -- 00:22:33,516
there will be some rules that are necessary.
00:22:33,516 -- 00:22:36,752
There will be some things that that have to continue
00:22:36,752 -- 00:22:41,891
in terms of rules, just because you can't necessarily measure
00:22:41,891 -- 00:22:46,128
and, and, and tune to every single outcome.
00:22:47,863 -- 00:22:49,632
I wonder if Michelle or
00:22:49,632 -- 00:22:52,635
Liz would have more that you like to add to that
00:22:53,202 -- 00:22:56,572
about measuring outcomes?
00:22:56,572 -- 00:22:59,208
So, first now, I would like to,
00:22:59,208 -- 00:23:01,277
thanks to Michelle
00:23:01,277 -- 00:23:05,481
for having me here and for the organizers
00:23:05,481 -- 00:23:10,419
of this wonderful event. So first,
00:23:10,419 -- 00:23:14,156
from my risk analytics experience.
00:23:14,156 -- 00:23:17,226
For sure, there are some things we can measure.
00:23:17,226 -- 00:23:21,463
It's actually, it's related to, the exactly
00:23:21,463 -- 00:23:23,699
it’s related to the risk management,
00:23:23,699 -- 00:23:27,236
identify, measure, mitigate,
00:23:28,337 -- 00:23:30,639
monitor and reports.
00:23:30,639 -- 00:23:33,976
So you hear [unintelligible], for a company, you need to have
00:23:33,976 -- 00:23:36,679
some metrics
00:23:36,679 -- 00:23:40,349
and key RI like a key risk indicators
00:23:40,349 -- 00:23:44,853
and the corresponding, you will establish some thresholds
00:23:44,853 -- 00:23:49,892
based on your practice, based on your domain knowledge, your experience.
00:23:49,892 -- 00:23:51,927
So put them together.
00:23:51,927 -- 00:23:54,997
Of course it is measurable.
00:23:58,600 -- 00:24:01,937
Roosevelt, can you comment on some of the challenges
00:24:01,937 -- 00:24:06,475
in this transformation from a rules based model to a principles based model?
00:24:06,475 -- 00:24:08,243
Sure.
00:24:08,243 -- 00:24:12,114
Well, so, so first, I think one of the challenges is, is really
00:24:12,114 -- 00:24:16,785
just kind of managing the change associated with, with going from
00:24:16,785 -- 00:24:20,122
what has been a rules based environment
00:24:20,122 -- 00:24:22,891
to a principles based environment.
00:24:22,891 -- 00:24:25,761
And so it's really sort
00:24:25,761 -- 00:24:28,297
of reinforcing the mindset that,
00:24:28,297 -- 00:24:33,869
there may be a tendency, especially as you go into it, that
00:24:33,869 -- 00:24:37,806
that you, you still maybe want to make sure you're satisfying some of the old rules
00:24:37,806 -- 00:24:41,310
because, because you might believe that, that, that is still important.
00:24:41,477 -- 00:24:45,714
But, but it's important to to really kind of sort of
00:24:45,714 -- 00:24:48,717
become,
00:24:48,717 -- 00:24:53,856
kind of exercising the muscle that, that says, okay, we're changing here
00:24:54,056 -- 00:24:58,327
and how do we continue to reinforce that, that change.
00:24:58,460 -- 00:25:03,899
It's also challenging to, to really
00:25:04,566 -- 00:25:07,502
is, as you go, as you begin to focus on
00:25:07,502 -- 00:25:10,472
some of these other outcomes like fairness as an example,
00:25:10,472 -- 00:25:14,977
as you, as you go down the path of fairness and,
00:25:14,977 -- 00:25:19,414
you know, consumers understanding and insurers realize that that fairness
00:25:19,414 -- 00:25:24,553
becomes an important focus for, for the principles based regulation.
00:25:24,987 -- 00:25:29,258
One of the challenges might be the perception of
00:25:29,258 -- 00:25:34,162
of why now the regulation and industry is focused on, on fairness.
00:25:34,162 -- 00:25:37,833
Was there a problem before that that, that has always existed
00:25:37,833 -- 00:25:40,135
that I should now be, be upset or concerned about?
00:25:40,135 -- 00:25:44,072
Or the flip side is
00:25:44,339 -- 00:25:48,410
perhaps, there some, that are potentially afraid of, of
00:25:48,410 -- 00:25:51,413
what might be found as you, again, go down this path.
00:25:51,780 -- 00:25:56,752
So I think it's important to, to continue to
00:25:57,285 -- 00:26:01,056
highlight the benefits of, of, of what this can do
00:26:01,056 -- 00:26:03,525
for consumers in terms of protection, in terms
00:26:03,525 -- 00:26:06,695
of, of improving consumer outcomes,
00:26:06,695 -- 00:26:11,066
and also the flexibility that, that it allows for companies
00:26:11,066 -- 00:26:14,703
to, to really improve the consumer experience, to really improve
00:26:14,703 -- 00:26:19,341
the outcomes that get consumers, may and potentially will see.
00:26:23,111 -- 00:26:26,281
Roosevelt, we spent a lot of time talking about innovation
00:26:26,281 -- 00:26:30,952
and how our principles based regulation can encourage innovation.
00:26:30,952 -- 00:26:34,890
I don't know that, that, that necessarily within the industry
00:26:34,890 -- 00:26:37,125
there's a clear connection between the two.
00:26:37,125 -- 00:26:39,628
And I'm, I'm hoping you can discuss that a little bit.
00:26:39,628 -- 00:26:40,695
Yeah, sure.
00:26:40,695 -- 00:26:43,698
And I,
00:26:43,698 -- 00:26:46,168
you probably recognize this from my introduction,
00:26:46,168 -- 00:26:48,937
but I'll say it just to make sure everyone understands.
00:26:48,937 -- 00:26:52,607
I'm obviously I'm from South of the border and so I will,
00:26:52,607 -- 00:26:55,577
I will maybe sprinkle in some examples from my U.S.
00:26:55,577 -- 00:26:57,913
experience and sort of how that relates to
00:26:57,913 -- 00:27:00,916
to the experience that I've had here, here in Ontario.
00:27:01,249 -- 00:27:05,420
But, but the, the, the idea of of innovation
00:27:05,420 -- 00:27:09,758
within a principles based environment I think fits much more
00:27:10,592 -- 00:27:11,560
comfortably,
00:27:11,560 -- 00:27:14,563
than it does in a rules based environment.
00:27:14,829 -- 00:27:17,799
In a lot of cases, in a rules based environment,
00:27:18,233 -- 00:27:20,702
you, the rules don't
00:27:20,702 -- 00:27:24,940
necessarily develop fast enough or develop
00:27:24,940 -- 00:27:30,211
in the way that they need to, to encourage innovation by companies.
00:27:30,211 -- 00:27:34,749
And so the challenge then that, that, that creates is, is
00:27:34,749 -- 00:27:38,453
companies have to attempt to innovate, but do so
00:27:38,453 -- 00:27:42,324
within a set of rules that they maybe even don't, don't yet,
00:27:42,324 -- 00:27:45,293
don’t still completely apply in today's environment.
00:27:45,293 -- 00:27:48,930
If we think about how fast the auto,
00:27:48,930 -- 00:27:52,167
the automobile, has, has changed over the years,
00:27:52,467 -- 00:27:56,237
the automobile that I'm driving today is, is radically different
00:27:56,237 -- 00:27:59,541
than the auto, automobile that I've drove 15, 20 years ago.
00:27:59,541 -- 00:28:04,946
But in some cases and like I say this, for certain in the U.S.,
00:28:05,046 -- 00:28:09,517
the regulatory structures that, that, that, that govern
00:28:09,517 -- 00:28:14,456
auto insurance are still for 15, 20, sometimes even longer ago.
00:28:14,456 -- 00:28:20,128
And so because you you don't have that, that
00:28:20,128 -- 00:28:23,465
environment that encourages innovation, a lot of times
00:28:23,465 -- 00:28:27,235
what you see is that that innovation lags within the insurance industry
00:28:28,603 -- 00:28:32,474
over the last, you know, probably decade.
00:28:32,474 -- 00:28:36,010
Now, there are a lot of companies, Insuretech companies,
00:28:36,010 -- 00:28:39,781
that came to the insurance space that that were going to take over
00:28:39,781 -- 00:28:41,916
the insurance space because they were going to come in
00:28:41,916 -- 00:28:45,119
and innovate all of the existing companies out of business.
00:28:45,119 -- 00:28:47,989
And what they realized is that when they came to insurance,
00:28:47,989 -- 00:28:53,127
they had to deal with sometimes archaic, sometimes old rules that didn't
00:28:53,127 -- 00:28:56,364
allow for the kind of innovation that they desire to do.
00:28:56,364 -- 00:29:00,101
And so it ultimately tamped down
00:29:00,101 -- 00:29:03,805
in some cases, just they went off and did something else somewhere else
00:29:03,805 -- 00:29:07,342
because they realized they couldn't do it in insurance.
00:29:07,508 -- 00:29:12,447
And, and, so one of the and we've got a couple of examples in the US,
00:29:12,447 -- 00:29:17,285
although one of those gaps might go away if the legislature had their way.
00:29:17,285 -- 00:29:20,488
We've got one example in the US of a state that really
00:29:20,488 -- 00:29:25,193
is more of a principles based environment than it is a rules based environment,
00:29:25,193 -- 00:29:29,530
and a lot of insurance companies use that state as a testing ground.
00:29:29,831 -- 00:29:31,099
They'll, they'll innovate.
00:29:31,099 -- 00:29:34,635
They'll, they'll roll out new things there, they'll refine them, see how they work,
00:29:34,635 -- 00:29:37,939
and then they will modify or adjust it
00:29:37,939 -- 00:29:40,942
maybe to fit in some of the other states that they operate in.
00:29:40,942 -- 00:29:42,010
But, but
00:29:42,343 -- 00:29:45,880
I think the insurance industry, especially in the U.S.
00:29:45,880 -- 00:29:49,250
and the lack of innovation that's happened there is
00:29:49,250 -- 00:29:52,153
kind of a testament to
00:29:52,153 -- 00:29:56,023
sometimes just the, the, the way that rules based environments
00:29:56,023 -- 00:29:59,794
don't work for innovation and also just the way
00:29:59,794 -- 00:30:03,297
in some cases that companies have been conditioned that, that it's
00:30:03,297 -- 00:30:06,534
not going to make sense to try to innovate because I won't be able to do it.
00:30:08,136 -- 00:30:12,373
That's, that's really interesting that PBR states are actually used
00:30:12,373 -- 00:30:16,944
as a testing ground for new ideas that can later be rolled out
00:30:16,944 -- 00:30:20,181
in rules based environments where there are more constraints or more
00:30:20,181 -- 00:30:22,083
that where, there's more lagginess.
00:30:22,083 -- 00:30:23,518
for sure.
00:30:23,518 -- 00:30:25,987
I'm going to move to Michelle now and Michelle,
00:30:25,987 -- 00:30:29,257
maybe we can switch to OGC
00:30:29,257 -- 00:30:32,293
and ORM and dig a little bit deeper there.
00:30:32,293 -- 00:30:35,863
Can you talk to us a little bit about how insurers can leverage
00:30:35,863 -- 00:30:39,433
the new rate and underwriting guidance to be more resilient?
00:30:40,101 -- 00:30:40,668
Sure.
00:30:40,668 -- 00:30:43,037
This is a very good question.
00:30:43,037 -- 00:30:48,209
So first that I think for most of you in the audience, maybe wondering why
00:30:48,209 -- 00:30:53,581
Michelle from Discover Financial Services Company is here actually
00:30:53,581 -- 00:30:58,319
by following the responsible maybe some insights from my end.
00:30:58,319 -- 00:31:01,022
Well, just to remove or
00:31:01,022 -- 00:31:04,091
maybe clarify, your wondering.
00:31:04,558 -- 00:31:06,360
And so
00:31:06,360 -- 00:31:09,363
what I wanted to say, is
00:31:09,530 -- 00:31:15,403
I worked in, for most of my career and the for my, my for most of my career,
00:31:15,403 -- 00:31:18,339
I worked in financial industry
00:31:18,339 -- 00:31:21,342
and financial services companies.
00:31:21,342 -- 00:31:24,378
But for more than two years
00:31:24,378 -- 00:31:27,782
in my past, I worked for an insurance company,
00:31:28,015 -- 00:31:31,419
American Family Insurance Enterprise.
00:31:31,419 -- 00:31:35,222
So then I have two sides of this story, right?
00:31:35,222 -- 00:31:39,493
And now I would like to say it's across the industry
00:31:39,493 -- 00:31:40,294
experience.
00:31:40,294 -- 00:31:43,297
Knowledge easier can be learned from each other,
00:31:43,531 -- 00:31:47,301
and especially of financial industry, like our principle based
00:31:47,301 -- 00:31:51,305
regulatory requirements are much easier.
00:31:51,305 -- 00:31:54,141
For example, for my, the
00:31:54,141 -- 00:31:59,180
most, from my most recent experience working on model risk management,
00:31:59,180 -- 00:32:03,083
it's really, it's principle based like in U.S.
00:32:03,184 -- 00:32:06,554
We have SR11-7.
00:32:06,821 -- 00:32:09,957
So this is supervisory guidance
00:32:10,124 -- 00:32:14,929
from FRB from OCC, from FDIC, and
00:32:14,929 -- 00:32:19,733
from like a credit, from the government entities.
00:32:20,401 -- 00:32:22,069
So principle based.
00:32:22,069 -- 00:32:26,440
And the for each financial company, they have their own understanding,
00:32:26,440 -- 00:32:30,444
interpreting, interpretation of this guidance
00:32:30,444 -- 00:32:35,216
and are based on their firm's unique risk profile.
00:32:35,216 -- 00:32:40,721
And there being this models they come up with their own solution.
00:32:40,721 -- 00:32:44,325
So this principle based approach is definitely,
00:32:44,325 -- 00:32:48,996
it's innovative and will help insurers
00:32:48,996 -- 00:32:53,167
with new technologies regarding this
00:32:53,167 -- 00:32:56,270
like pricing how insurers
00:32:56,270 -- 00:32:58,706
leverage this rules based,
00:32:58,706 -- 00:33:01,108
principle based risk management
00:33:01,108 -- 00:33:04,078
to help with their business model
00:33:04,078 -- 00:33:07,081
to help their risk management.
00:33:07,114 -- 00:33:11,819
I think the first I would like to say is to establish
00:33:11,819 -- 00:33:15,322
your operational risk management framework.
00:33:15,322 -- 00:33:16,190
So what is a
00:33:16,190 -- 00:33:16,757
framework?
00:33:16,757 -- 00:33:19,793
Framework is basically, it's about like a governance,
00:33:20,294 -- 00:33:24,365
about your operational risk management
00:33:25,232 -- 00:33:28,235
policies, standards, procedures,
00:33:28,435 -- 00:33:30,738
all kinds of templates, job aids.
00:33:30,738 -- 00:33:33,741
So our firm has to have all those
00:33:34,808 -- 00:33:37,111
those things like
00:33:37,111 -- 00:33:40,848
a policy procedures in place.
00:33:40,848 -- 00:33:43,751
And after that, you need to, like Michelle mentioned,
00:33:43,751 -- 00:33:46,720
you need to have like a different
00:33:46,720 -- 00:33:48,922
line of, different lines
00:33:48,922 -- 00:33:52,326
of defense, majorly it’s three lines
00:33:52,326 -- 00:33:55,295
of defense model
00:33:55,295 -- 00:33:59,566
so this is a free market establishment after that it’s
00:33:59,566 -- 00:34:03,036
about the implementation, about execution,
00:34:03,036 -- 00:34:07,174
you can't adjust to have, to have things in paper
00:34:07,174 -- 00:34:09,776
just to have to talk the talk,
00:34:09,776 -- 00:34:14,114
and then you need to walk the walk, so this is execution.
00:34:14,114 -- 00:34:17,584
And after that, executing how to manage it.
00:34:17,584 -- 00:34:20,487
And the question has me ask it’s
00:34:20,487 -- 00:34:26,193
about your risk identification, measurement,
00:34:26,193 -- 00:34:29,897
your [unintelligible] establishment, your metrics,
00:34:29,897 -- 00:34:35,035
your thresholds for example, if you put like a below 5% it’s green
00:34:35,035 -- 00:34:39,573
and between 5% to 10% is yellow
00:34:39,806 -- 00:34:42,643
and if it’s above 10% it’s red.
00:34:42,643 -- 00:34:45,646
So it's a very obvious variable.
00:34:45,646 -- 00:34:48,181
And after then it’s risk
00:34:48,181 -- 00:34:51,285
mitigation, and the work is conducted
00:34:51,285 -- 00:34:55,122
by human, and human creates errors and mistakes.
00:34:55,122 -- 00:35:00,160
So everywhere there is a risk, there is issue.
00:35:00,160 -- 00:35:03,930
So when we identify it, we needed to have work plan,
00:35:03,930 -- 00:35:08,669
we needed to mitigate it and eventually the risk got controlled.
00:35:08,669 -- 00:35:13,507
So this is, also includes contingency planning.
00:35:13,507 -- 00:35:16,777
If the risk is huge, you should have
00:35:16,777 -- 00:35:19,713
some contingency plan in place.
00:35:19,713 -- 00:35:24,885
And I go, for example, a system failure. If it happens, what should we do?
00:35:25,085 -- 00:35:30,891
So this kind of response needs to be in place and that monitoring
00:35:30,891 -- 00:35:34,061
and the reporting, report and, report to your risk
00:35:34,061 -- 00:35:36,730
committee, to your board of directors.
00:35:36,730 -- 00:35:40,400
So they see your executives in the C3
00:35:40,400 -- 00:35:44,905
can be very aware of their firm's unique
00:35:45,238 -- 00:35:50,477
risk profile and they can be very much responsive.
00:35:50,477 -- 00:35:53,513
And after that, I think this is not,
00:35:53,513 -- 00:35:56,550
not that they lost the thing, but the it's a very important
00:35:56,550 -- 00:35:59,853
the firm needs to be compliant
00:36:00,253 -- 00:36:03,590
with the law, with the regulations.
00:36:03,590 -- 00:36:05,959
So this is a fundamental part
00:36:05,959 -- 00:36:11,031
to run our business, especially for a consumer based business.
00:36:12,499 -- 00:36:13,166
Michelle, in
00:36:13,166 -- 00:36:17,671
your consulting work, where do you typically see the biggest gaps?
00:36:18,772 -- 00:36:21,441
Yeah, mentioning.
00:36:21,441 -- 00:36:26,046
And if we talk about the gaps, because I have this
00:36:26,046 -- 00:36:30,684
consumer financial services, the experience and also insurance
00:36:30,684 -- 00:36:33,987
experience and that this,
00:36:34,220 -- 00:36:38,224
I don't want to just frustrating you but I think this
00:36:38,224 -- 00:36:43,496
not only my personal experience but for most folks if they have across
00:36:43,496 -- 00:36:48,335
the industrial experience, they may have kind of impression.
00:36:48,335 -- 00:36:50,770
So financial, financial
00:36:50,770 -- 00:36:52,605
firms, maybe it's more innovative,
00:36:52,605 -- 00:36:55,842
for talking about risk management
00:36:55,842 -- 00:36:58,912
might be more effective and efficient.
00:36:59,479 -- 00:37:02,482
So comparing to industries,
00:37:02,515 -- 00:37:07,887
I feel there are several gaps that I would like to mention.
00:37:08,355 -- 00:37:12,659
For example, lack of clear definition of
00:37:12,659 -- 00:37:16,162
stakeholder roles and responsibilities.
00:37:16,596 -- 00:37:20,333
This is, is so important because once you set up
00:37:20,333 -- 00:37:24,771
very clear roles and responsibilities, people can just work out their,
00:37:24,771 -- 00:37:27,607
their job requirements.
00:37:27,607 -- 00:37:33,079
And then there is a no just arguing and the who should do this,
00:37:33,079 -- 00:37:37,050
who should do that, so everyone is clear
00:37:37,283 -- 00:37:40,286
that this is my upstream responsibilities.
00:37:40,720 -- 00:37:43,723
This is downstream responsibilities.
00:37:43,890 -- 00:37:49,195
So people are in place to take care of their own plate.
00:37:49,195 -- 00:37:52,599
This is very clear, this lack of
00:37:52,632 -- 00:37:57,904
definition of the roles and responsibilities,
00:37:57,904 -- 00:38:01,207
after that is, for example, lack of effective
00:38:01,207 -- 00:38:04,210
risk management systems
00:38:04,744 -- 00:38:08,381
like a GRC, governance risk and control.
00:38:08,381 -- 00:38:13,386
So if our firm has a very good, has vast GRC system,
00:38:13,386 -- 00:38:16,589
actually, all kinds of risks can be well managed,
00:38:16,589 -- 00:38:19,259
not only operational risk management
00:38:19,259 -- 00:38:21,794
under its models risk management
00:38:21,794 -- 00:38:26,799
at the same time your, for example, the creditors
00:38:26,799 -- 00:38:30,003
your credit and risk management,
00:38:30,436 -- 00:38:35,408
your P&C related risk management
00:38:35,408 -- 00:38:38,478
and the top of the house level, if you, say you
00:38:38,511 -- 00:38:40,847
would like to have a have a risk report.
00:38:40,847 -- 00:38:45,652
So just to go through this systemically, because some partners
00:38:46,119 -- 00:38:51,524
so in the end all kinds of risk profiles that can be aggregated
00:38:51,524 -- 00:38:53,793
and the report
00:38:53,793 -- 00:38:56,796
can be correspondingly
00:38:57,030 -- 00:39:00,700
And again, it's lack of talents
00:39:00,700 -- 00:39:03,736
in the current era of AI, GNI,
00:39:03,736 -- 00:39:06,906
data scientists and data
00:39:06,906 -- 00:39:10,109
engineer engineers and the modelers.
00:39:10,543 -- 00:39:12,912
And also the staff turnover is very,
00:39:12,912 -- 00:39:17,216
very quick, very frequent and the knowledge transfer
00:39:17,283 -- 00:39:21,821
and you know, it's pretty much is there and related to this one,
00:39:22,021 -- 00:39:26,359
and what I would like to maintain are another gap it’s model
00:39:26,359 -- 00:39:30,563
not only model documentation but also all kinds of [unintelligible]
00:39:30,563 -- 00:39:32,565
related documentation.
00:39:32,565 -- 00:39:38,004
So you it's not comprehensible, not transparent,
00:39:38,004 -- 00:39:41,607
and especially for some key business processes.
00:39:41,607 -- 00:39:44,277
You know, it's not well documented,
00:39:44,277 -- 00:39:48,414
and again for people and the new hires,
00:39:48,848 -- 00:39:52,752
it's very challenging for them to follow
00:39:53,085 -- 00:39:56,923
the key processes,
00:39:57,123 -- 00:40:00,026
key requirements to fulfill their job
00:40:00,026 -- 00:40:03,029
responsibilities.
00:40:03,763 -- 00:40:06,132
Michelle, I wonder also if you can comment
00:40:06,132 -- 00:40:09,335
on some of the challenges that organizations face
00:40:09,335 -- 00:40:13,406
in really embedding the right mindset into their organizations.
00:40:13,406 -- 00:40:16,909
And as I mentioned before, not just in the pricing area,
00:40:17,343 -- 00:40:20,579
not just amongst risk management experts,
00:40:20,579 -- 00:40:24,617
but across the organization and embedded right into the business.
00:40:25,551 -- 00:40:27,586
Yeah. Thank you
00:40:27,586 -- 00:40:29,989
Michelle for another wonderful question.
00:40:29,989 -- 00:40:33,693
I think, for this one, the first challenge
00:40:33,726 -- 00:40:37,897
I would like to say in the past, for example, in the era of rule based
00:40:37,897 -- 00:40:40,132
regulatory requirements,
00:40:40,132 -- 00:40:46,472
I feel incentives for insurers were not strong.
00:40:46,472 -- 00:40:49,342
Sometimes it's very late,
00:40:49,342 -- 00:40:52,345
because the cost was huge,
00:40:52,345 -- 00:40:58,718
their checklist is so long and there are lots to do
00:40:58,718 -- 00:41:01,721
and the transferring from this rule based
00:41:01,721 -- 00:41:04,457
requirements to principle based on requirements.
00:41:04,457 -- 00:41:08,694
As we just discussed, flexibility is much easier
00:41:09,028 -- 00:41:13,999
and especially the incentives to insurance are very obvious.
00:41:13,999 -- 00:41:16,602
For example, if you show your evidence,
00:41:16,602 -- 00:41:19,805
you have a very robust risk management.
00:41:19,805 -- 00:41:23,609
ORM is so strong. Documentation
00:41:23,609 -- 00:41:26,812
is in place, it's a very comprehensive well,
00:41:27,046 -- 00:41:30,649
and therefore you are being this decision making, you'll have rationale.
00:41:30,749 -- 00:41:31,917
Strong rationale.
00:41:31,917 -- 00:41:34,053
Justification,
00:41:34,053 -- 00:41:38,757
and the regulators come to exam and then provide
00:41:38,757 -- 00:41:44,196
green light and then, like an incentives you can see the new filing guidances as well
00:41:45,030 -- 00:41:46,365
will
00:41:46,365 -- 00:41:49,668
provide a very fast filing process
00:41:49,668 -- 00:41:54,473
for the accredited companies and then for this company
00:41:54,473 -- 00:41:56,876
there are new products, new services
00:41:56,876 -- 00:42:00,512
that go to markets that go into markets that will be very fast.
00:42:00,512 -- 00:42:04,250
And then it's very competitive and that they can make
00:42:04,283 -- 00:42:06,719
a lot of revenues and the profits.
00:42:06,719 -- 00:42:12,057
So this one, it’s the, first the challenge, the second one is, I feel,
00:42:12,057 -- 00:42:15,060
it's most of all companies.
00:42:15,060 -- 00:42:16,962
A lack of
00:42:16,962 -- 00:42:19,365
strong risk culture
00:42:19,365 -- 00:42:22,334
and most of them it’s very much
00:42:22,334 -- 00:42:25,738
reactive for, like it’s not proactive
00:42:26,005 -- 00:42:29,541
or even like proactive when the active
00:42:29,541 -- 00:42:33,612
so you, this way, when, like bad things happen
00:42:33,879 -- 00:42:38,550
and they just very much use reactive, their solution is one time
00:42:38,817 -- 00:42:40,619
not sustainable, not scalable
00:42:40,619 -- 00:42:44,523
and they put them together actually, this, the cost
00:42:44,623 -- 00:42:49,061
is a huge for your company but they have take this
00:42:49,061 -- 00:42:52,464
principle based approach eventually, you know
00:42:52,464 -- 00:42:58,203
their system will be very robust and that it’s very, very straightforward
00:42:58,203 -- 00:43:01,974
and a very comprehensive and very efficient.
00:43:01,974 -- 00:43:04,910
I think an agile ecosystem, reactive,
00:43:04,910 -- 00:43:08,981
very fast solutions are very sustainable.
00:43:08,981 -- 00:43:12,918
So cost is a much saved, another one,
00:43:12,918 -- 00:43:18,157
I would like to say it’s the operational risk management,
00:43:18,157 -- 00:43:22,494
actually, is an integral part of what enterprises risk management.
00:43:22,494 -- 00:43:25,597
So if the, the third challenge is,
00:43:25,597 -- 00:43:29,568
I think it's like our firm's ERM
00:43:29,768 -- 00:43:33,238
is a bottom up, not a top down.
00:43:33,238 -- 00:43:36,041
So it's harder for bottom level
00:43:36,041 -- 00:43:39,077
individuals to pursue innovation.
00:43:39,077 -- 00:43:43,248
So, if there is, something from the top advocates,
00:43:43,248 -- 00:43:48,987
for example, CEO says let's do ORM, let’s do MRM.
00:43:48,987 -- 00:43:50,355
So you can imagine.
00:43:50,355 -- 00:43:55,093
This effect is a huge, it's easier for people to follow.
00:43:55,694 -- 00:44:00,265
And the last one I would like to mention is the gap.
00:44:00,265 -- 00:44:02,134
It's a very lagged.
00:44:02,134 -- 00:44:05,537
Adoption of modern risk management.
00:44:05,537 -- 00:44:09,041
The concept, the framework especially
00:44:09,074 -- 00:44:13,745
we’ve talked about AI generated for AI a lot.
00:44:13,745 -- 00:44:17,282
So for companies everyone
00:44:17,316 -- 00:44:20,118
either to you have a very adaptive mindset,
00:44:20,118 -- 00:44:25,090
open minded to learn from outside and to be,
00:44:25,090 -- 00:44:29,828
to be more like a modern technology
00:44:29,895 -- 00:44:33,832
oriented and as you act, act fast.
00:44:34,399 -- 00:44:35,233
Thank you, Michelle.
00:44:35,233 -- 00:44:40,238
I'm sure there are many challenges associated with making this shift
00:44:40,238 -- 00:44:42,808
and really developing new processes and getting attention
00:44:42,808 -- 00:44:46,711
from across the organization and not just where some of these practices
00:44:46,711 -- 00:44:50,048
have historically sort of been siloed within organizations.
00:44:50,048 -- 00:44:51,616
Yeah. Thank you so much.
00:44:51,616 -- 00:44:55,620
I think maybe we'll switch now to a discussion on unfair bias
00:44:55,620 -- 00:44:56,688
and discrimination.
00:44:56,688 -- 00:45:00,792
So I'm going to turn our attention to Liz, who's a bit of a change maker
00:45:00,792 -- 00:45:04,729
at Definity, and I'm hoping you could share a bit about your story there.
00:45:04,729 -- 00:45:06,965
Liz, we'll start with the first question.
00:45:06,965 -- 00:45:10,368
How can actuaries identify, measure and mitigate unfair
00:45:10,368 -- 00:45:12,804
bias and discrimination in their models?
00:45:12,804 -- 00:45:15,740
It's a big question. It is a big question.
00:45:15,740 -- 00:45:19,511
Yes. Again, I just want to thank you for having me today
00:45:19,511 -- 00:45:21,479
and to be a part of this really important discussion.
00:45:21,479 -- 00:45:24,216
I think that there's a huge responsibility
00:45:24,216 -- 00:45:27,252
for actuaries and data scientists to take this into consideration
00:45:27,252 -- 00:45:29,054
throughout the predictive modeling lifecycle.
00:45:29,054 -- 00:45:32,357
So when we talk about different bias considerations, I think for a
00:45:32,357 -- 00:45:36,895
lot of folks, the default is to just check at the model evaluation step.
00:45:36,895 -- 00:45:39,898
But realistically, bias can be introduced at any point in the predictive
00:45:39,898 -- 00:45:41,166
modeling lifecycle.
00:45:41,166 -- 00:45:44,569
So there's, there's very important considerations that have to be made
00:45:44,569 -- 00:45:47,772
that might be specific to certain parts of your,
00:45:47,906 -- 00:45:51,977
your model risk management or your predictive modeling plan.
00:45:51,977 -- 00:45:53,545
So there might be considerations that you would need
00:45:53,545 -- 00:45:57,482
to make at the planning phase versus your data extraction or your preparation
00:45:57,482 -- 00:46:00,251
phase and understand thing is my data is inherently biased,
00:46:00,251 -- 00:46:02,554
and if the inputs are biased, what are my model results
00:46:02,554 -- 00:46:03,622
going to look like?
00:46:03,622 -- 00:46:06,558
So there's different detection tests that we can leverage
00:46:06,558 -- 00:46:08,927
depending on the type of model that we're building.
00:46:08,960 -- 00:46:11,463
So if we're thinking about it from an actuarial perspective
00:46:11,463 -- 00:46:14,632
and maybe something that's more traditional in the pricing sense.
00:46:14,632 -- 00:46:17,502
So a lot of us are familiar with the development of loss cost models,
00:46:17,502 -- 00:46:21,573
which are typically one that has a continuous response variable.
00:46:21,573 -- 00:46:26,344
So for things that are of the similar nature rather than a classification model,
00:46:26,344 -- 00:46:29,447
there would be certain techniques I would want to employ to detect bias.
00:46:29,447 -- 00:46:33,451
That being said, what works well for one type of model might not work
00:46:33,451 -- 00:46:34,352
well for another.
00:46:34,352 -- 00:46:37,789
So we really have to be conscientious of what that use case is
00:46:37,789 -- 00:46:40,358
and whether it makes sense for what we're building.
00:46:40,358 -- 00:46:43,394
But the same can be said about the mitigation techniques that we're using.
00:46:43,528 -- 00:46:47,999
So mitigation techniques also need to be specific in understanding
00:46:47,999 -- 00:46:50,368
what it is that our model's output is.
00:46:50,368 -- 00:46:54,205
And do these outputs result
00:46:54,205 -- 00:46:57,408
in unfair outcomes that we can control.
00:46:57,408 -- 00:47:01,379
But there is also times in which we need to be considerate of tradeoffs.
00:47:01,379 -- 00:47:05,183
So it's possible that you build a model where you've detected bias,
00:47:05,183 -- 00:47:09,087
you can mitigate it and the accuracy and the predictive power of your model
00:47:09,087 -- 00:47:11,556
is more or less the same. And that's very straightforward.
00:47:11,556 -- 00:47:15,760
But as Michelle was alluding to, there might be situations where
00:47:15,760 -- 00:47:16,494
that isn't the case
00:47:16,494 -- 00:47:19,264
and you do have this sort of tradeoff that you have to be considerate of,
00:47:19,264 -- 00:47:21,866
which is why it's important to build a model risk
00:47:21,866 -- 00:47:25,403
management framework that has the sort of ecosystem, right.
00:47:25,403 -- 00:47:29,474
So it's not just the responsibility of the actuary or the data science
00:47:29,474 -- 00:47:34,045
or the predictive analytics practitioner having this sort of cross-functional group
00:47:34,045 -- 00:47:36,748
to assess your models and properly vet the considerations
00:47:36,748 -- 00:47:40,752
and what outcomes look like for consumers is imperative.
00:47:40,752 -- 00:47:42,754
And without having that
00:47:42,754 -- 00:47:46,691
level of consideration and due diligence is very difficult
00:47:46,691 -- 00:47:51,062
to ensure that we truly do have fair outcomes for our consumers.
00:47:52,830 -- 00:47:55,033
I wonder, Liz, if you can
00:47:55,033 -- 00:47:59,871
talk a little bit about the journey at Definity, just at a really high level
00:47:59,871 -- 00:48:03,641
because you've really been such an integral part of them
00:48:04,075 -- 00:48:08,379
understanding fairness within their own organization
00:48:08,379 -- 00:48:12,250
and how to address it not just in modeling but in other areas of the organization
00:48:12,250 -- 00:48:12,717
as well.
00:48:12,717 -- 00:48:14,519
Can you tell us a bit about that? For sure.
00:48:14,519 -- 00:48:16,954
So a little bit of background
00:48:16,954 -- 00:48:20,992
about our journey we've formally formed our Working Group
00:48:20,992 -- 00:48:24,462
to address bias and fairness in predictive models in 2022.
00:48:24,462 -- 00:48:27,598
But that doesn't mean we weren't actively doing it prior to that.
00:48:27,598 -- 00:48:31,269
The issue was that we were seeing these gaps across different departments,
00:48:31,269 -- 00:48:34,972
so some departments were very active and proactive
00:48:34,972 -- 00:48:36,474
about doing these sorts of checks,
00:48:36,474 -- 00:48:39,444
whereas some departments were more reactive in nature.
00:48:39,444 -- 00:48:43,014
And like Michelle was talking about earlier, being reactive
00:48:43,014 -- 00:48:45,583
is not sustainable, but it's also quite harmful.
00:48:45,583 -- 00:48:49,153
And so having this proactive approach is beneficial
00:48:49,153 -- 00:48:53,024
not just for the model risk management perspective, but also for the consumers
00:48:53,024 -- 00:48:54,025
at the end of the day.
00:48:54,025 -- 00:48:58,462
So recognizing that we had this gap was a true driving force
00:48:58,462 -- 00:49:00,464
for developing our working group
00:49:00,464 -- 00:49:03,901
and to determine what it is that we wanted to achieve
00:49:03,901 -- 00:49:06,838
because like we were saying earlier, it can be very overwhelming.
00:49:06,838 -- 00:49:07,939
You don't know where to start.
00:49:07,939 -- 00:49:09,607
There are many different considerations
00:49:09,607 -- 00:49:13,110
that need to be made, but we're actually lucky to be here today
00:49:13,110 -- 00:49:16,847
with one of the authors of some of the CAS research paper series,
00:49:16,847 -- 00:49:20,751
and we used a lot of their work to determine what it is
00:49:20,751 -- 00:49:23,921
that we wanted to achieve and what made sense for our book of business.
00:49:23,921 -- 00:49:27,625
So we took a look at the literature and the research that was out there
00:49:27,625 -- 00:49:30,828
to determine, okay, what can we develop as practical tools
00:49:30,828 -- 00:49:34,365
that folks can leverage based off of the projects that they're working on
00:49:34,365 -- 00:49:38,603
and not being overly prescriptive on very specific use cases.
00:49:38,603 -- 00:49:43,474
Now, that doesn't mean that we don't have this sort of lack of rules,
00:49:43,474 -- 00:49:47,511
if that makes sense, because you need to understand the why behind the how.
00:49:47,511 -- 00:49:51,449
And the why is something that we identified as a major barrier
00:49:51,449 -- 00:49:55,386
in our organization, because for a lot of folks who work as either
00:49:55,386 -- 00:49:59,523
actuaries or data scientists or anything else, it's very analytical of nature.
00:49:59,523 -- 00:50:02,493
More likely than not, your undergraduate degree
00:50:02,493 -- 00:50:05,496
or your post-secondary education was within STEM.
00:50:05,496 -- 00:50:08,332
But historically, a lot of STEM degrees don't really address
00:50:08,332 -- 00:50:11,602
the effects of systemic bias on predictive models.
00:50:11,602 -- 00:50:14,071
And I don't know if they even do it today.
00:50:14,071 -- 00:50:17,108
They might, but I wish I had that when I was in university and I didn't.
00:50:17,108 -- 00:50:22,113
So knowing that even though actuaries go through this sort of very rigorous
00:50:22,113 -- 00:50:25,316
exam process, but this is actively addressed
00:50:25,316 -- 00:50:28,119
in our literature, it's a, it's a gap that needs to be addressed
00:50:28,119 -- 00:50:32,189
because it's one thing to do the how, it's one thing to apply the tools.
00:50:32,189 -- 00:50:35,392
But if you're not fully understanding why you're doing it
00:50:35,392 -- 00:50:38,762
or if you don't fully understand what you're doing,
00:50:38,996 -- 00:50:42,466
it makes it very difficult to ensure that what you're doing is promoting
00:50:42,466 -- 00:50:45,870
positive outcomes. And you don't even know what you're looking for.
00:50:45,903 -- 00:50:46,871
That's it. Yeah.
00:50:46,871 -- 00:50:48,405
Do you want to add anything on that, Roosevelt?
00:50:48,405 -- 00:50:50,541
Well, there's, there's a lot of
00:50:50,541 -- 00:50:55,513
I maybe pick up on one point that then there's may
00:50:55,513 -- 00:50:59,450
I can't underscore enough that question
00:50:59,450 -- 00:51:03,487
of understanding the outcomes that you're seeing in fairness test
00:51:03,487 -- 00:51:06,924
and then identifying the appropriate way to address those outcomes
00:51:07,458 -- 00:51:10,094
is one of the challenges is
00:51:10,094 -- 00:51:13,864
that we're wrestling with in the U.S.
00:51:13,898 -- 00:51:15,666
is that
00:51:15,666 -- 00:51:18,202
there's sort of two sides of the coin there.
00:51:18,202 -- 00:51:23,007
There's some regulators that believe, if I define this very specific test
00:51:23,007 -- 00:51:27,878
and I define a very specific parameter or a very specific outcome that, that,
00:51:27,878 -- 00:51:30,247
that determines pass or fail,
00:51:30,247 -- 00:51:33,784
then I've satisfied the fairness criteria.
00:51:34,251 -- 00:51:37,254
And, and one of the things that we've been
00:51:37,988 -- 00:51:40,524
saying to anybody that will listen is that,
00:51:40,524 -- 00:51:43,027
testing is one thing.
00:51:43,027 -- 00:51:46,797
What you do with that test is critically important
00:51:47,197 -- 00:51:50,034
because ultimately you could actually end up
00:51:50,034 -- 00:51:53,504
creating a worse situation on the outcome
00:51:53,504 -- 00:51:56,507
than, than if you did nothing at all.
00:51:56,774 -- 00:52:00,577
And unfortunately,
00:52:00,577 -- 00:52:04,314
especially in kind of the world today,
00:52:04,314 -- 00:52:07,785
the headlines drive more of the policy than, than
00:52:07,785 -- 00:52:10,587
sometimes the scientific reality.
00:52:10,587 -- 00:52:14,691
And so I, it for those that, that,
00:52:14,691 -- 00:52:17,661
that, that are involved in this I can't underscore that enough.
00:52:17,661 -- 00:52:20,230
Yeah, there's one thing to test for fairness.
00:52:20,230 -- 00:52:23,066
What you do with the results of that test is
00:52:23,066 -- 00:52:26,069
vitally more important than even the test.
00:52:26,336 -- 00:52:29,006
And maybe just to build on that, Michelle was talking
00:52:29,006 -- 00:52:32,276
about how we have different levels of signoff, right?
00:52:32,276 -- 00:52:36,113
So a definitive part of that model
00:52:36,113 -- 00:52:39,550
risk management element is when we're building a new model
00:52:39,550 -- 00:52:42,786
that has a certain level of risk associated to it.
00:52:42,786 -- 00:52:46,723
Not only are we showing that the model was properly built and whatnot,
00:52:46,723 -- 00:52:50,928
but we are also showing the proper bias detection and mitigation techniques
00:52:50,928 -- 00:52:52,029
that were applied.
00:52:52,029 -- 00:52:56,366
And when we are showing these things, it's not just to a VP who's also an actuary.
00:52:56,366 -- 00:52:59,903
There's this understanding that model explainability is not just
00:52:59,903 -- 00:53:03,607
from the perspective of data scientists, but to folks who might be non-technical
00:53:03,607 -- 00:53:05,008
in their day-to-day job.
00:53:05,008 -- 00:53:07,344
So if we have folks who are in legal, for example,
00:53:07,344 -- 00:53:09,746
and we even saw this in our talks earlier today,
00:53:09,746 -- 00:53:13,350
they might not be analytics practitioners, but they understand the outcomes.
00:53:13,350 -- 00:53:18,422
And so when we, when we talk about bias and fairness and the ways in which we are
00:53:18,422 -- 00:53:21,458
mitigating it, having a layered
00:53:21,458 -- 00:53:24,828
approach and not just a siloed one is crucial.
00:53:24,828 -- 00:53:29,199
And I think that if FSRA is moving forward with this sort of approach
00:53:29,199 -- 00:53:33,637
with PBR, it's going to force folks to get on to the same page.
00:53:33,637 -- 00:53:35,772
I think that's such a great point.
00:53:35,772 -- 00:53:40,677
I wonder also, Liz, if, if the job is becoming more difficult with things
00:53:40,677 -- 00:53:45,215
like artificial intelligence and machine learning, it's just complex stuff.
00:53:45,215 -- 00:53:46,383
It is.
00:53:46,516 -- 00:53:49,786
Even with the rise of Gen AI, we have to sort of think
00:53:49,786 -- 00:53:52,589
outside the box as to how we can address bias with that, right?
00:53:52,589 -- 00:53:55,125
Because even if we think about large language models,
00:53:55,125 -- 00:53:57,094
there is an example that was being provided today
00:53:57,094 -- 00:54:01,098
and the previous talk about the app that was built.
00:54:01,098 -- 00:54:03,500
It was essentially a chat bot about foot pain.
00:54:03,500 -- 00:54:04,101
Right?
00:54:04,101 -- 00:54:08,038
And there was a clear bias in the way that the question was being built.
00:54:08,038 -- 00:54:11,174
And so naturally the outcomes are going to be biased as well.
00:54:11,174 -- 00:54:11,775
And so
00:54:12,008 -- 00:54:14,111
it's, it's complex,
00:54:14,111 -- 00:54:18,315
but I think it's something that we need to be actively thinking about.
00:54:18,315 -- 00:54:22,119
And by building PBR, it's
00:54:22,219 -- 00:54:24,721
going to be formulated in a way where we don't have to go
00:54:24,721 -- 00:54:27,357
well, we've never seen before, so we don't really know what to do.
00:54:27,357 -- 00:54:30,927
It gives us the framework and the tools to think, well,
00:54:30,927 -- 00:54:33,463
I've seen something similar before, how is this different?
00:54:33,463 -- 00:54:37,467
How can I leverage that and have this sort of transferable ability
00:54:37,467 -- 00:54:40,871
or tool kit to then assess something new that I've never seen before,
00:54:40,871 -- 00:54:43,874
but I understand it from other perspectives.
00:54:46,209 -- 00:54:47,143
Ok. So this is,
00:54:47,143 -- 00:54:50,080
this is more of an exploratory question, and I'll pose it to you, Liz,
00:54:50,080 -- 00:54:54,017
but I welcome anyone else on the panel that wants to jump in.
00:54:54,918 -- 00:54:58,154
How do you define what is fair?
00:54:58,154 -- 00:55:00,457
And do we need one definition of fair?
00:55:00,457 -- 00:55:02,759
Do we need to define it?
00:55:02,759 -- 00:55:04,261
Yeah, that is a hard question.
00:55:04,261 -- 00:55:05,729
Thank you so much for asking it.
00:55:05,729 -- 00:55:07,764
Yeah, everyone's wrestling with it.
00:55:07,764 -- 00:55:10,667
Everyone and I understand why.
00:55:10,667 -- 00:55:15,472
Even if we think about how we define fairness from a purely data science
00:55:15,472 -- 00:55:18,975
or machine learning or AI perspective, there is no one definition.
00:55:18,975 -- 00:55:21,845
And so this comes to be a problem
00:55:21,845 -- 00:55:25,015
for how we define it globally, right?
00:55:25,015 -- 00:55:27,984
So in the context of this, I think it's important
00:55:27,984 -- 00:55:32,055
that we can't take a sort of one size fits all approach.
00:55:32,055 -- 00:55:36,159
It really has to be in relation to what we're talking about.
00:55:36,159 -- 00:55:41,231
So if we're talking about unfair outcomes with respect to, let's say,
00:55:41,231 -- 00:55:44,167
auto pricing, that might be different in terms
00:55:44,167 -- 00:55:47,003
of considerations that we would have for underwriting.
00:55:47,003 -- 00:55:50,106
And if, with what FSRA is developing,
00:55:50,106 -- 00:55:53,877
I think what's important here is that they have the ability to be
00:55:55,044 -- 00:55:57,514
not overly prescriptive in terms of
00:55:57,514 -- 00:56:00,383
what's considered to be fair, because for
00:56:00,383 -- 00:56:05,388
if we're asking the industry to define fairness on their own,
00:56:05,488 -- 00:56:08,491
you are going to have multiple different answers.
00:56:08,858 -- 00:56:12,462
And that makes it very difficult to ensure proper, fair outcomes.
00:56:12,462 -- 00:56:17,133
But if we have the sort of guidance about what does fair mean in this context,
00:56:17,133 -- 00:56:19,803
then the insurers can go ahead and say,
00:56:19,803 -- 00:56:22,272
Well, that makes sense given the business that I underwrite.
00:56:22,605 -- 00:56:25,909
And it allows the insurers to be on the same page.
00:56:25,909 -- 00:56:30,046
It also sort of a risk mitigation technique for the regulator themselves
00:56:30,046 -- 00:56:31,047
because you're ensuring
00:56:31,047 -- 00:56:34,050
that everyone is on the same page, that they have the tools to assess
00:56:34,050 -- 00:56:35,018
what makes sense
00:56:35,018 -- 00:56:39,022
for their specific use cases, again, without being overly prescriptive.
00:56:39,022 -- 00:56:42,158
So I know it's not really an answer because I don't fully have an answer,
00:56:42,158 -- 00:56:46,429
but I think that rather than having a one-size-fits all approach,
00:56:46,429 -- 00:56:50,099
it's important just to formulate your considerations
00:56:50,099 -- 00:56:53,002
based off of what it is that you're working on.
00:56:53,002 -- 00:56:54,504
Do you think organizations need
00:56:54,504 -- 00:56:58,041
to be declarative about what their fairness definition is?
00:56:58,041 -- 00:57:00,043
It's another tricky one. That is a tricky one,
00:57:01,611 -- 00:57:02,412
Very tricky.
00:57:02,412 -- 00:57:05,415
I think it's something to consider moving forward with this.
00:57:05,882 -- 00:57:06,482
Okay.
00:57:06,482 -- 00:57:10,520
It's a conversation starter, certainly. For sure.
00:57:11,387 -- 00:57:12,088
Okay.
00:57:14,023 -- 00:57:15,124
The relationship
00:57:15,124 -- 00:57:18,895
between insurers and the regulator
00:57:18,895 -- 00:57:22,532
will change in the context of principles based regulation.
00:57:22,799 -- 00:57:24,600
How do you see that?
00:57:24,600 -- 00:57:26,436
Well, how do you see it changing?
00:57:26,436 -- 00:57:27,970
What will work best?
00:57:27,970 -- 00:57:30,606
What support is needed for the industry?
00:57:30,606 -- 00:57:35,178
It's just a kind of an open ended question and maybe everyone can comment on that.
00:57:35,845 -- 00:57:37,480
Do you want to start Roosevelt?
00:57:37,480 -- 00:57:40,183
Sure, sure.
00:57:40,183 -- 00:57:43,720
So I, one of the refreshing things
00:57:43,720 -- 00:57:46,923
that I've seen as part of the,
00:57:46,923 -- 00:57:51,027
the principles based regulatory structure, is really just
00:57:51,027 -- 00:57:55,198
the collaborative environment that, that's been set up here.
00:57:55,198 -- 00:57:58,367
It's unlike anything I've ever seen in my career.
00:57:58,367 -- 00:58:02,205
And I think you're, you're really onto something here.
00:58:02,271 -- 00:58:07,076
But I think, that, that, that idea of the regulator
00:58:07,076 -- 00:58:09,579
and the industry collaborating
00:58:09,579 -- 00:58:12,215
to focus on the consumer
00:58:12,215 -- 00:58:16,953
outcomes is, it's the way really that that regulation
00:58:16,953 -- 00:58:20,356
should work to be, to be honest, is that if everybody's
00:58:20,356 -- 00:58:23,259
kind of pushing in the same direction and focused on the consumer.
00:58:23,259 -- 00:58:27,363
Then, then that hopefully that change will, will continue.
00:58:27,930 -- 00:58:33,135
You know, certainly kind of reinforcing the principles based guidelines.
00:58:33,135 -- 00:58:36,606
Again, with change, it's sometimes easy to revert back to
00:58:36,606 -- 00:58:39,442
what we know on both sides, industry and regulation.
00:58:39,442 -- 00:58:43,879
And so, really kind of reinforcing the fact that, that, that this really
00:58:43,879 -- 00:58:47,583
is a changing environment and that we really want to do
00:58:47,583 -- 00:58:51,621
what's best for the consumer, I think we’ll begin
00:58:51,621 -- 00:58:55,424
require everyone to kind of flex their change muscles.
00:58:55,791 -- 00:59:00,997
But, but it, is continuing to to collaborate and
00:59:00,997 -- 00:59:03,466
and seeing the benefits of that collaboration,
00:59:03,466 -- 00:59:06,836
I think will just continue to strengthen the environment going forward.
00:59:07,770 -- 00:59:08,204
I agree.
00:59:08,638 -- 00:59:09,872
Michelle, would you like to comment?
00:59:09,872 -- 00:59:14,010
Yeah, I feel this one will bring good things
00:59:14,010 -- 00:59:16,846
for both, both sides.
00:59:16,846 -- 00:59:20,116
And I echo, I just, I would like to echo
00:59:20,116 -- 00:59:23,786
what those words just said.
00:59:23,786 -- 00:59:28,324
So more collaborative being on the
00:59:28,324 -- 00:59:30,860
Regulators and insurers will be
00:59:30,860 -- 00:59:34,330
more collaborative in the collective efforts,
00:59:34,330 -- 00:59:37,133
so it’s not just the one side for example
00:59:37,133 -- 00:59:41,604
Usually in the past, the regulation was the legacy governance
00:59:41,604 -- 00:59:44,440
body there and the insurers that have to follow
00:59:44,907 -- 00:59:48,978
all kinds of rules, checklist, but going forward,
00:59:49,145 -- 00:59:52,348
because it is a principle based and then,
00:59:52,348 -- 00:59:55,618
there will be lots of conversations, so
00:59:55,618 -- 00:59:58,888
there will be a lot of mutual understanding.
00:59:58,888 -- 01:00:02,158
Consensus for this, for this specific business
01:00:02,158 -- 01:00:05,928
requirements situation and in the end,
01:00:05,928 -- 01:00:10,266
following that principle and the solutions will be much,
01:00:10,266 -- 01:00:12,768
much, much better.
01:00:12,768 -- 01:00:16,138
And they're also easier and agile
01:00:16,372 -- 01:00:19,375
based and agile solutions.
01:00:19,375 -- 01:00:23,546
And at the same time, I mean, solutions, would it be
01:00:23,546 -- 01:00:29,218
very sustainable and scalable, not just a mega B to this specific rules,
01:00:29,218 -- 01:00:33,222
but the principles, these kind of a and, is a high, high level.
01:00:33,222 -- 01:00:38,761
So I would like to use towards a sustainable and the scalable to describe
01:00:38,761 -- 01:00:40,896
that.
01:00:40,896 -- 01:00:44,433
I really like what you said about it being a collective thing
01:00:44,733 -- 01:00:48,370
because fairness is a collective issue like even if we strip away
01:00:48,604 -- 01:00:51,941
this sort of pathway to an accelerated filing process,
01:00:51,941 -- 01:00:54,943
if some insurers are doing it really well, but others aren't,
01:00:55,477 -- 01:00:57,146
you haven't mitigated bias.
01:00:57,146 -- 01:00:58,347
It's still going to be there.
01:00:58,347 -- 01:01:02,151
If you have these pockets of industry where some industry,
01:01:02,151 -- 01:01:04,586
some insurers are doing it really well and others aren't really addressing it
01:01:04,586 -- 01:01:08,590
at all, then you were still looking at unfair outcomes.
01:01:08,590 -- 01:01:11,360
These disparities will still be present.
01:01:11,360 -- 01:01:15,497
That's why I think that it's important that FSRA is taking that
01:01:15,497 -- 01:01:19,368
on, and integrating it intentionally and not being reactive.
01:01:19,368 -- 01:01:24,640
Because, if everyone is on that sort of same page, and understanding of fairness
01:01:24,640 -- 01:01:28,877
that will ensure that will ensure fair outcomes for our consumers.
01:01:28,877 -- 01:01:30,312
And ultimately, at the end of the day,
01:01:30,312 -- 01:01:32,681
we're in the business of consumer protection.
01:01:32,681 -- 01:01:37,119
Consumer protection is a collective that is not something that one
01:01:37,119 -- 01:01:42,124
insurer does and the others just follow in whatever way they say makes sense.
01:01:42,124 -- 01:01:45,494
It's something that we all need to be buying into, and I'm hoping that
01:01:45,494 -- 01:01:48,864
with this supervisory framework moving forward that insurers
01:01:48,864 -- 01:01:52,868
will understand and put in the work and the time to understand
01:01:52,901 -- 01:01:55,938
why this is important, why this is valuable, and why this can't
01:01:55,938 -- 01:02:00,442
just be the responsibility of one specific team in organization.
01:02:01,009 -- 01:02:01,710
I love that.
01:02:01,710 -- 01:02:05,480
And I love this idea of the principles almost like being shared
01:02:05,480 -- 01:02:08,550
values between the regulator and the industry.
01:02:08,550 -- 01:02:12,554
And we're all working together in order to achieve the same,
01:02:12,554 -- 01:02:15,357
the same outcomes for sure, and more dialog.
01:02:15,357 -- 01:02:18,393
So we talked about that this morning and I mentioned it earlier in the talk
01:02:18,393 -- 01:02:22,664
that there just really needs to be more exchanged between FSRA
01:02:22,664 -- 01:02:27,436
and the industry in order to make PBR a success going forward.
01:02:27,436 -- 01:02:28,937
So we're looking forward to that.
01:02:28,937 -- 01:02:32,474
This is one of many discussions that we'll be having with the industry
01:02:32,474 -- 01:02:36,645
and you'll see us out meeting with insurers and responding to questions
01:02:36,645 -- 01:02:39,881
and providing all the support that's needed to make sure that
01:02:39,881 -- 01:02:43,719
this is a really successful transformation and that everyone wins.
01:02:43,719 -- 01:02:44,786
Consumers win
01:02:44,786 -- 01:02:48,156
because we achieve all the outcomes that we were talking about before,
01:02:48,156 -- 01:02:53,061
and insurers are able to innovate and bring products
01:02:53,061 -- 01:02:57,065
to market more quickly, to move rate changes through more quickly.
01:02:57,065 -- 01:03:01,069
And all of that, all the flexibility that's needed for a healthy marketplace.
01:03:01,069 -- 01:03:04,639
So that concludes our formal panel discussion.
01:03:05,007 -- 01:03:10,412
We are now going to take questions online. And, and in the room,
01:03:10,579 -- 01:03:13,181
and if there are any questions that are left unanswered, as I mentioned
01:03:13,181 -- 01:03:17,152
before, we'll catch up with those separately.
01:03:18,920 -- 01:03:19,521
Okay.
01:03:19,521 -- 01:03:23,658
The first question, which is anonymous, was,
01:03:23,658 -- 01:03:27,929
when, FSRA has its supervisory framework and new guidance live.
01:03:27,929 -- 01:03:30,599
What happens to UDAP and TAC.
01:03:30,599 -- 01:03:35,771
So I think everyone is familiar with UDAP, but for anyone on online,
01:03:35,871 -- 01:03:38,874
Unfair, Deceptive Acts or Practices
01:03:38,874 -- 01:03:42,010
and TAC is the Take All Comers Rule.
01:03:42,010 -- 01:03:44,679
So the short answer to this question is nothing.
01:03:44,679 -- 01:03:47,516
Nothing changes with either a UDAP or TAC.
01:03:47,516 -- 01:03:50,018
TAC is part of the Insurance Act.
01:03:50,018 -- 01:03:51,353
And UDAP is a rule.
01:03:51,353 -- 01:03:53,889
So effectively they're both legislation.
01:03:53,889 -- 01:03:57,692
The supervisory framework is guidance that will be issued.
01:03:57,692 -- 01:04:01,730
So Joanne mentioned this morning that we're moving to
01:04:01,730 -- 01:04:05,267
kind of a hybrid model where there's principles, but there are also rules.
01:04:05,267 -- 01:04:07,702
And so those are rules that will remain in place
01:04:07,702 -- 01:04:09,771
and we'll continue to supervise against them.
01:04:11,973 -- 01:04:13,909
The next question
01:04:13,909 -- 01:04:17,145
is will FSRA define fairness for insurers?
01:04:17,145 -- 01:04:20,148
How will FSRA evaluate fairness?
01:04:20,248 -- 01:04:24,085
So fairness is chapter one in the supervisory guidance.
01:04:24,085 -- 01:04:28,323
As I mentioned, we're working through some of the principles of fairness.
01:04:28,323 -- 01:04:31,393
So unfair bias, discrimination, proxy
01:04:31,393 -- 01:04:34,829
discrimination, rating accuracy, things like that.
01:04:34,829 -- 01:04:38,033
So we're working through all of those pieces right now.
01:04:38,300 -- 01:04:43,138
Whether there will be one common definition of fairness,
01:04:43,438 -- 01:04:46,207
I would say there will be common principles
01:04:46,207 -- 01:04:49,577
that we'll all be measuring ourselves against, and we'll have to think
01:04:49,577 -- 01:04:53,081
about what some of the outcomes are that we will test within the context
01:04:53,081 -- 01:04:56,084
of the new guidance.
01:04:57,886 -- 01:04:58,887
The next question
01:04:58,887 -- 01:05:01,856
is, besides fairness and transparency,
01:05:01,856 -- 01:05:04,993
what are the other principles for auto insurance?
01:05:05,126 -- 01:05:07,929
So FSRA has six key principles
01:05:07,929 -- 01:05:10,765
that are listed in our standard filing and guidance.
01:05:10,765 -- 01:05:13,568
Certainly, fairness is one of them.
01:05:13,568 -- 01:05:16,504
As part of our consumer focus principle.
01:05:16,504 -- 01:05:20,742
But there are also things like sustainability, innovation,
01:05:21,009 -- 01:05:24,913
transparency and other measures that will be part
01:05:24,913 -- 01:05:28,316
of chapter four and the new guidance, the new filing guidance.
01:05:28,316 -- 01:05:30,685
So the standard filing guidance will go away.
01:05:30,685 -- 01:05:32,687
All of the principles are articulated there.
01:05:32,687 -- 01:05:35,390
They'll become part of the new supervisory guidance.
01:05:39,127 -- 01:05:40,395
The next
01:05:40,395 -- 01:05:43,264
question is for insurers that are accredited,
01:05:43,264 -- 01:05:47,101
I guess the accreditation status will be good for several years.
01:05:47,101 -- 01:05:50,705
Can you please clarify. You mentioned proactive supervision.
01:05:50,705 -- 01:05:55,410
Does it mean that FSRA will continuously monitor and audit insurers?
01:05:55,410 -- 01:05:57,512
This is a great question.
01:05:58,079 -- 01:06:00,848
The, the timeframe
01:06:00,848 -- 01:06:04,285
that we're working with right now for accreditation is three years.
01:06:05,053 -- 01:06:08,189
So you go through the assessment process, you become accredited
01:06:08,189 -- 01:06:13,161
and then officially or formally you won't be reassessed for three years.
01:06:13,161 -- 01:06:15,496
But during that time they'll still be ongoing
01:06:15,496 -- 01:06:18,499
monitoring what we call proactive supervision.
01:06:18,900 -- 01:06:21,336
So there will be regular data exchange,
01:06:21,336 -- 01:06:24,872
regular interactions with insurers
01:06:24,872 -- 01:06:28,910
and testing of some of the principles to make sure that they're being applied
01:06:28,910 -- 01:06:33,581
consistently, consistently, and that we're achieving the right outcomes.
01:06:33,581 -- 01:06:37,919
So there will be, there will be ongoing
01:06:37,919 -- 01:06:42,490
monitoring and supervision even after accreditation takes place.
01:06:42,490 -- 01:06:45,193
And then, of course, another formal process in three years.
01:06:49,097 -- 01:06:51,699
The next question is, my
01:06:51,699 -- 01:06:55,036
organization has operational risk management in place.
01:06:55,036 -- 01:06:57,438
Does FSRA expect insurers to
01:06:57,438 -- 01:07:00,675
create a new one for Ontario Auto Insurance?
01:07:00,875 -- 01:07:05,646
Will FSRA's new ORM framework benefit consumers?
01:07:05,646 -- 01:07:08,483
So I'll answer the first question.
01:07:08,483 -- 01:07:10,985
No. Organizations are not expected to,
01:07:10,985 -- 01:07:15,490
to create a new ORM for auto insurance.
01:07:15,623 -- 01:07:18,759
A lot of those practices are already in place
01:07:18,759 -- 01:07:21,762
within most organizations, as I mentioned before.
01:07:21,762 -- 01:07:24,532
I would say in small organizations that would be
01:07:24,532 -- 01:07:29,070
maybe a difference just due to resources and the size of business.
01:07:29,070 -- 01:07:31,205
And, and having that sort of infrastructure
01:07:31,205 -- 01:07:35,276
within their organization isn't necessarily warranted.
01:07:35,610 -- 01:07:38,613
So we'll be applying the principles
01:07:38,613 -- 01:07:42,650
of proportionality when we're doing the accreditation.
01:07:42,650 -- 01:07:45,653
If those organizations pursue accreditation.
01:07:45,653 -- 01:07:49,123
But we're not expecting companies to create anything new,
01:07:49,123 -- 01:07:53,828
but we will have minimum requirements in each one of those areas.
01:07:53,828 -- 01:07:57,031
And it's important that those that their ORM is robust
01:07:57,031 -- 01:08:01,102
and that it is consistently followed.
01:08:01,102 -- 01:08:04,972
And so they'll be testing for processes and that sort of thing.
01:08:04,972 -- 01:08:06,507
Hopefully that answers that question.
01:08:07,475 -- 01:08:09,010
The next question, does it
01:08:09,010 -- 01:08:12,780
mean that accredited insurers will get the approval
01:08:12,780 -- 01:08:16,317
for new products and business models much easier and faster?
01:08:16,317 -- 01:08:19,387
Will accredited insurers need to file at all?
01:08:22,757 -- 01:08:25,426
So accredited insurers will need to file.
01:08:25,426 -- 01:08:27,561
The requirements for filing will be different
01:08:27,561 -- 01:08:31,399
for accredited companies than it will be for non-accredited companies.
01:08:31,399 -- 01:08:35,436
But the idea here is that will increase speed to market.
01:08:35,436 -- 01:08:39,540
So accredited insurers, you know, having demonstrated
01:08:39,540 -- 01:08:42,777
that they're already operating in line with our principles and their serving
01:08:42,777 -- 01:08:46,447
target consumer outcomes, we'll have a streamlined process
01:08:46,447 -- 01:08:49,917
for applying for rate changes, product
01:08:49,917 -- 01:08:52,286
changes, model changes, things like that.
01:08:52,286 -- 01:08:54,955
But one of the things that I really want to impress
01:08:54,955 -- 01:08:59,627
is that it is possible to test new products and new business ideas today.
01:08:59,627 -- 01:09:01,862
We have the Innovation Office.
01:09:01,862 -- 01:09:05,699
We wish that the Innovation Office was busier than it is,
01:09:05,699 -- 01:09:10,204
but we do have the ability even today, to review those new business ideas,
01:09:10,204 -- 01:09:14,441
and we're very much eager to hear about those ideas
01:09:14,441 -- 01:09:17,444
and provide opportunities for organizations to test
01:09:17,444 -- 01:09:21,315
new business model ideas, new product ideas, things like that.
01:09:21,515 -- 01:09:25,085
So I guess from this question I'd like to impress on everybody is that
01:09:25,085 -- 01:09:29,590
we're open for business from that perspective,
01:09:29,590 -- 01:09:33,027
and we'd really like to hear more of those proposals coming forward.
01:09:36,931 -- 01:09:37,831
The next
01:09:37,831 -- 01:09:43,404
question is, is FSRA's accreditation system created for large insurers?
01:09:43,404 -- 01:09:45,606
Only small insurers do not have resources.
01:09:45,606 -- 01:09:49,610
How will small insurers be evaluated in the accreditation system?
01:09:49,610 -- 01:09:54,682
So as I mentioned before, our expectations for small organizations
01:09:54,782 -- 01:09:57,518
with small books of business and
01:09:57,518 -- 01:10:00,254
and that have
01:10:00,254 -- 01:10:04,391
less risky profiles will be different than the accreditation
01:10:04,391 -- 01:10:07,728
requirements for larger and more complex organizations.
01:10:07,728 -- 01:10:10,998
The details of that will be articulated in the supervisory...
01:10:10,998 -- 01:10:16,337
in the supervisory framework, but the short story is that small,
01:10:16,337 -- 01:10:19,273
there will be advantages even for small organizations
01:10:19,273 -- 01:10:22,876
to achieve accreditation and will be reasonable in terms of how
01:10:22,876 -- 01:10:26,480
we approach those requirements and what our expectations will be.
01:10:29,350 -- 01:10:30,617
The next question is,
01:10:30,617 -- 01:10:33,620
what are the timelines for accreditation to start?
01:10:33,887 -- 01:10:36,557
When will companies be able to start applying?
01:10:38,158 -- 01:10:39,626
So the new supervisory
01:10:39,626 -- 01:10:44,098
framework will be in effect towards the end of 2025.
01:10:44,631 -- 01:10:47,968
We're hoping that some insurers will come forward earlier
01:10:47,968 -- 01:10:51,972
in the process and express interest in being part of our pilot.
01:10:52,740 -- 01:10:55,175
But it's not too soon
01:10:55,175 -- 01:10:58,812
for us to start hearing from organizations and start lining that up.
01:10:58,812 -- 01:11:01,782
But the assessment process won't start until towards
01:11:01,782 -- 01:11:04,785
the end of next year.
01:11:06,019 -- 01:11:08,589
The next question is,
01:11:08,589 -- 01:11:11,825
why is PBR good for consumers
01:11:11,825 -- 01:11:14,161
and good for insurers?
01:11:14,161 -- 01:11:17,397
So I think we covered this question at length.
01:11:17,831 -- 01:11:20,167
But just to summarize for consumers,
01:11:20,167 -- 01:11:23,136
certainly fairness in rating,
01:11:23,370 -- 01:11:26,139
more choice through innovation,
01:11:27,474 -- 01:11:30,711
rating accuracy, I think all of those things are wins
01:11:30,711 -- 01:11:34,181
for consumers, more value for money through innovation and new products
01:11:34,181 -- 01:11:36,183
coming to market, things like that.
01:11:36,183 -- 01:11:40,888
For organizations, I think it's more flexibility.
01:11:40,888 -- 01:11:43,557
So, with, being focused on outcomes,
01:11:43,557 -- 01:11:47,160
then it gives insurers the flexibility to,
01:11:47,261 -- 01:11:50,530
you know, solve, solve for that, have more, more flexibility
01:11:50,530 -- 01:11:54,067
as long as they're achieving the target outcomes so they can decide
01:11:54,067 -- 01:11:56,403
how they, the achievement, achieve them.
01:11:56,403 -- 01:11:59,072
And there's more flexibility around that.
01:12:01,408 -- 01:12:04,144
A question maybe for Liz and Michelle.
01:12:04,144 -- 01:12:07,114
For those of us who are not underwriters or developing models,
01:12:07,114 -- 01:12:10,751
can you give an example of how bias may come up?
01:12:12,185 -- 01:12:13,720
Do you want to start?
01:12:13,754 -- 01:12:15,756
I can start.
01:12:15,756 -- 01:12:18,759
Yeah, thanks for this question
01:12:19,893 -- 01:12:24,998
and for any business actually there are models around,
01:12:24,998 -- 01:12:28,201
model outputs are used in our strategy.
01:12:28,201 -- 01:12:31,772
In your business decision sometimes, you know,
01:12:31,772 -- 01:12:36,109
for another set of strategies use, use cases.
01:12:36,109 -- 01:12:39,546
Actually, there is a no model involvement
01:12:39,546 -- 01:12:42,549
but there are some that casual based
01:12:43,683 -- 01:12:46,186
decision making processes
01:12:46,186 -- 01:12:51,391
and the just the, because of, of for example rule based that you factor based
01:12:51,391 -- 01:12:54,795
so the rule and a factor may contain some
01:12:54,795 -- 01:12:58,064
you know negative bias related for example
01:12:58,064 -- 01:13:00,700
PII related information.
01:13:00,700 -- 01:13:03,170
And then, in the end the business
01:13:04,137 -- 01:13:06,406
solutions decisions
01:13:06,406 -- 01:13:10,744
may contain bias, something.
01:13:11,044 -- 01:13:14,347
So there this is a one example I can provide.
01:13:14,347 -- 01:13:16,516
So it is you can, yeah.
01:13:16,516 -- 01:13:17,250
And then more.
01:13:17,250 -- 01:13:19,119
You said exactly what I was going to say so thanks,
01:13:19,119 -- 01:13:22,556
but I will expand a bit on that because I think that
01:13:22,556 -- 01:13:26,459
for, for some folks at least what we've seen internally is that
01:13:26,459 -- 01:13:29,863
this is the responsibility of the actuaries,
01:13:30,030 -- 01:13:33,033
the data scientists, the analytical folks.
01:13:33,033 -- 01:13:35,001
Bias can be as simple as a rule, right?
01:13:35,001 -- 01:13:36,436
It could be something that's exclusionary.
01:13:36,436 -- 01:13:40,941
It could be something that is unfair, that isn't the result of a model output.
01:13:40,941 -- 01:13:42,609
But I don't think enough folks realize
01:13:42,609 -- 01:13:46,046
that a lot of the business decisions are from model outputs.
01:13:46,046 -- 01:13:48,348
They're just not directly building them.
01:13:48,348 -- 01:13:51,851
They're using what was the outcome of that model.
01:13:51,851 -- 01:13:56,056
So I think it's important to not just understand that,
01:13:56,056 -- 01:13:58,191
but to challenge your own internal biases.
01:13:58,191 -- 01:13:59,659
Everyone has bias.
01:13:59,659 -- 01:14:02,896
That's not a social commentary on whether you are a good or bad person.
01:14:02,896 -- 01:14:05,165
Everyone has a bias that is normal,
01:14:05,165 -- 01:14:08,134
but understand how that relates to your work that you do, how that relates
01:14:08,134 -- 01:14:11,304
to the consumers that you're serving, and reflect upon that actively.
01:14:11,304 -- 01:14:15,675
Because when it comes to the notions of bias and fairness, it's not a checkbox,
01:14:15,675 -- 01:14:17,077
it's a journey. At the end of the day.
01:14:19,112 -- 01:14:21,381
Thank you so much, Liz.
01:14:21,381 -- 01:14:24,784
I think we're at time, so thank you everyone for joining us today.
01:14:24,784 -- 01:14:28,354
And I want to say thank you to Roosevelt, Michelle and Liz for joining us,
01:14:28,354 -- 01:14:31,357
and we look forward to more conversations with you in the future.
01:14:31,658 -- 01:14:32,158
Thank you.