1. Addressing Licensing Standards: To develop a harmonized or mutually recognized set of licensing standards
2. Maintaining Education Standards: To ensure the standards of qualification remain current and viable.
3. Establishing Practice Standards: To develop a common set of principles and practices for the distribution of insurance products and services by insurance intermediaries.
4. Co-operating with Other Regulators: To further refine the working relationship with members of the Canadian Council of Insurance Regulators (CCIR) and Joint Forum of Financial Market Regulators (Joint Forum) with respect to insurance intermediary issues.
5. Sharing Information among Internal Members: To disseminate information on policies and decisions
6. Communicating with External Stakeholders: To establish effective methods of communication with industry, other regulators and the public.
7. Monitoring Trends in the Industry: To establish a process to identify changing market place conditions and products and assess the implication for regulatory standards.

CISRO also sets out the four Strategic Priorities as follows:

1. Development of a set of principles governing the practices of intermediaries.
2. Development of Common Licensing Standards
3. Development of a CISRO Structure
4. Development of a Communication Protocol Between CISRO Members

The plan notes that CISRO members decided it was premature for CISRO to have a secretariat, constitution, by-laws or incorporation. CISRO does not have a website but the strategic plan can be found on the FSCO site

• All contracts

Electronic Commerce
The paper seeks input on provisions to be excluded from the application of the Electronic Transactions Act (ETA) i.e. that must be provided in hard copy. Two areas are being considered are terminations of coverage and changes of beneficiary.

Telephonic Communication
Important information received over the telephone to be verified in writing to the client. Licensed agents may be exempt from this requirement.

Notification of Limitation Period Expiry
An insurer is to make reasonable efforts to provide written notification of the date upon which, to the best knowledge of the insurer, the claimant’s right to sue the insurer will expire. The paper seeks input as to when notification should occur.

• P&C Contracts

Applicability of Statutory conditions

Statutory conditions will not apply to certain classes of insurance eg specialized insurance, hail, credit, mortgage, travel and title insurance.

Fire Coverage
Regulations set out which causes of fire can be excluded. The intent is to have the current list of events to continue to apply (i.e. riot, war, invasion). At question is whether or not to expand the list to fire following earthquake and terrorism. Fire during vacancy will not be a permitted exclusion for vacancy of 30 days or less.

Innocent Co-insured Claims Procedures
The proposed regulation would require a person whose claim would otherwise be barred by the wrongful acts of their co-insured to submit to an examination under oath on request of the insurer. Input is sought on whether the regulation should also specifically require that the claimant co-operate with the insurer in its investigation of the loss and provide all relevant information and documents in addition to those required by the contract.

• Life and A&S Contracts

Access to group Insurance Contract
The paper seeks further details about the practical risks of commercial information disclosure. The regulation plans to restrict access to information that is not relevant to the contractual rights of the group insured. As well, to address industry concerns, it is proposed that an insurer may, with court approval, deny access to other aspects of the contract on the basis that disclosure could harm commercial interests.

Regulation of group insurance
Regulations respecting group and creditor’s group insurance products are thought necessary to cover regulatory and consumer protection problems, especially with point of sale disclosure and certainty of coverage. Regulators are also concerned that some consumers may misrepresent their health history and status in response to unclear or general questions used in the sign-up process. As well, there are concerns about conflict of interest in contract formation and claims settlement.

Commission/ fee disclosure -The regulation would require disclosure of fees/commission paid to the employer or financial institution that sells group/ creditor’s group insurance.

Claims settlement - The paper requests input on a proposal that would require that claims settlement not be done by a group policyholder (e.g. the employer or financial institution) or administrator.

Medical information – Regulations propose to require that the questions asked during enrolment in creditor’s group insurance target specific conditions or diseases (e.g. have you had tuberculosis?), rather than asking open-ended general questions (e.g. have you had respiratory problems?), in order to avoid the possibility of misunderstandings that could lead to non-disclosure of pertinent information. As well, persons conducting the enrolment would be required to advise the applicant that a failure to disclose information could result in loss of coverage. Failure to comply with these requirements would bar the insurer from using the answers to deny a claim

• Technical Provisions

Transitional Provisions
Provisions, wherever possible, are to apply to new and renewal policies only. New claims provisions to apply to claims arising after implementation date. 12 months transition is proposed.

Click here for the BC Finance discussion paper. Submissions are due by April 16. Regulations will be drafted by Fall of 2010.