Draft F2020-21 FSRA Priorities and Budget

December 16, 2019

Download PDF:

Draft F2020-21 FSRA Priorities and Budget

Letter Summary:

FSRA is responsible for the regulation of a number of financial services, including P&C insurance, credit unions, L&H insurance, mortgage brokering, pensions and financial planners/advisors. It has set out a number of cross-sector priorities as well as sector specific priorities that builds on this year’s targets and is focused on burden reduction, regulatory effectiveness and protecting the public interest. Some cross-sector priorities include reviewing guidance inherited by FSRA (with a goal of reducing 40% of the existing guidance), establishing service standards, modernizing systems and processes, transitioning to principled-based regulations and improving information sharing with other regulators. Specific priorities for the mortgage broker sector includes supporting the MOF’s policy direction on mortgage brokerage legislation and enhancing market conduct oversight. For the financial planners/advisors sector, they include developing the process for approval and supervision of credentialing bodies by posting rules for consultation on the title protection framework.

Overview of the Council’s Comments:

We are supportive of each of FSRA’s cross-sector fiscal 2020-2021 priorities, particularly those relating to reducing regulatory burden without having a negative impact on investor protection.

We believe the transition to principles-based regulation will allow market participants of various sizes and complexities to operate within the enumerated framework.

We understand that as part of its burden reduction efforts, FSRA is in the process of reviewing existing guidance with a view to ensuring clarity and eliminating overlap or potentially inconsistent requirements. We agree that it is important for regulated entities and investors to understand the intended effects of any published guidance, and we encourage initiatives related to data driven analytics.

Information sharing with other regulators is also listed as one of FSRA’s cross sector priorities. We firmly believe that if information is shared with other regulators in Ontario and across Canada, it could assist with regulatory investigations, which is consistent with upholding investor protection and market integrity.

The Consultation notes that FSRA is in the process of setting up its Consumer Advisory Panel. We understand that the purpose of the panel is in part to provide ongoing advice to FSRA from a consumer perspective on proposed policy-related matters, and to identify topics for future policy consideration, outreach and/or educational activities. We believe this forward-looking initiative is positive and would encourage the panel to consider bench marking and reviewing regulations across jurisdictions internationally to look for ways in which their regulators approach their investor protection mandates.