2021 07 – CISRO – Comments – Principles of Conduct for Intermediaries Working Group – Stakeholder Submissions – 68p

2021 07 - CISRO - Comments - Principles of Conduct for Intermediaries Working Group - Stakeholder Submissions - 68p

2021-2022 - CISRO - Principles of Conduct for Intermediaries Working Group - [link]
- 2022 - CISRO - CISRO Principles of Conduct for Insurance Intermediaries - 3p
- 2021 07 - CISRO - Comments - Principles of Conduct for Intermediaries Working Group - Stakeholder Submissions --- [BonkNote] --- 68p

1-5 -Advocis
6-7 - Add
7-10 - CADRI
11-14 - CAFII
15 - Consumer Advocates for Insurance (French)
16 - Blank
17-18 - CAILBA
19-21 - MarkUp By?
22-24 - CLHIA
25 - IBAC
26-28 - IBAO
29-30 - RCCAQ
31-36 - IBC
37-41 - IFB
42-45 - Insurance Institute
46-48 - Ontario Mutual Insurance Association
49 - TPAAC
50 - CIAA - Insurance Adjsters
51 - HollisWealth Advisory Services
52 - Larry Chang, CFA |
- Principle 7: Claims, Complaints Handling, and Dispute Resolution: Intermediaries must handle or assist in the handling of claims, complaints, and disputes in a timely and fair manner.
- Intermediaries must also inform the complainants of their rights to access third-party dispute resolution mechanisms, and provide a list of providers who the complainants can contact for help. These information too must be provided in a timely manner.
53 - Michael A. Gigliotti
- “… intermediaries must seek complete information from the Customer in order to understand and identify their unique needs”
- This is rarely possible given the reality of dealing with customers in the real world. In fact quite often customers simply dictate what they want with a minimal amount of information shared. Regardless of the amount of fact finding I can still give good advice in the best interests of the client without complete information.
- Regulators and people with high minded thinking often ignore the real world.
  - So I’d suggest you adjust the above draft principle accordingly. Thanks.
54-68 - J Griffin

1-5 -Advocis
- Professional financial advisors and planners are critical to the ongoing success of the economy, helping consumers to make sound financial decisions that ultimately lead to greater financial stability and independence both for the consumer and the country.

17-18 - CAILBA
- Second, MGA’s monitor advisors only on a risk-based basis.
  - For our purposes and as addressed in CLHIA Guideline G-18: Insurer-MGA Relationships, ‘risk-based’ supervision and monitoring takes into account, among other things,
    - (i) with respect to the MGA, its business structure, number of advisors, where the advisors work, the sales and marketing support it provides, the types of products and services involved in typical transactions, and reported complaints and concerns, and
    - (ii) with respect to the advisor, its information as provided through the initial screening process, experience, client base, typical transactions, and reported complaints and concerns.
37-41 - IFB
- Principle 5. Disclosure: Intermediaries must provide Customers with objective, complete, relevant, and accurate information and explanations so that they can make informed decisions throughout the business cycle.
- Intermediaries must:
  - Properly disclose relevant information to all necessary parties; including the insurer; and
  - Disclose information and explanations in a manner that is clear and understandable for Customers, regardless of the distribution model or medium used.
- While we agree with the intent of the Principle, it should be noted that intermediaries are generally required to use the marketing and product information provided by the manufacturer (insurance company) and are prohibited from developing their own.
- This was acknowledged in the CCIR/CISRO FTC Guidance which states:
  - "The Insurer is responsible for providing promotional material that is accurate, clear and not misleading not only to Customers but also to Intermediaries who may rely on such information"
  - [Bonk: IAIS - CP 19 Conduct of Business International Association of Insurance Supervisors
    - https://www.iaisweb.org › icp-online-tool › 13530-icp-1...
    - ... responsible for providing promotional material that is accurate, clear and ... not only to customers but also to intermediaries who may rely on such information"]

6-7 - Add
7-10 - CADRI
11-14 - CAFII
15 - Consumer Advocates for Insurance (French)
16 - Blank
17-18 - CAILBA
19-21 - MarkUp By?
22-24 - CLHIA
25 - IBAC
26-28 - IBAO
29-30 - RCCAQ
31-36 - IBC
42-45 - Insurance Institute
46-48 - Ontario Mutual Insurance Association