2015 0915 - Advocis - Comment - Expert Committee to Consider Financial Advisory and Financial Planning Policy Alternatives - 274p
2016 0715 - Advocis - Comment - Re: CCIR - Segregated Funds Working Group Issues Paper, May 2016 - 46p
CLHIA Reference Document IVIC Suitability Needs-Based Sales Practices (February 2013) provides a fulsome discussion of relevant suitability guidelines for IVIC sales.
CHLIA Guideline G2, Individual Variable Insurance Contracts relating to Segregated Funds,
CLHIA/IFB/Advocis document “The Approach,” which provides needs analysis criteria.
Appendix One of FSCO’s September 2014 Life Insurance Product Suitability Report
Insurance Distribution in Canada: Promoting a Customer-Focused System, the CLHIA
The CCIR asserts (with no reference to documentary evidence) that complaint and enforcement data indicate that some life insurers may not be monitoring the product knowledge and sales practices of those selling their products in a manner that is comparable to the monitoring conducted on the mutual funds sector. Moreover, the complaint and examination files surveyed by the CCIR indicate that in some cases life insurers have not accepted responsibility for the sales conduct of licensed intermediaries selling their products.
Insurers are best positioned to be responsible for oversight of advisors
Advocis believes that the insurer must bear the responsibility for oversight of the advisor. Indeed, they are the only party properly positioned to do so.