On September 26, 2023, CAFII hosted a webinar and virtual fireside chat with Glen Padassery and Stuart Wilkinson. In addition to representatives from CAFII’s 15 member companies and 9 Associates, representatives from the following allied industry Associations attended:
- Canadian Life and Health Insurance Association, or CLHIA;
- the Travel Health Insurance Association, or THIA;
- the Insurance Bureau of Canada, or IBC;
- The British Columbia Financial Services Authority, or BCFSA ;
- The Insurance Council of British Columbia ;
- Alberta Treasury Board & Finance, or ATBF;
- The Alberta Insurance Council, or AIC;
- The Alberta Auto Insurance Rate Board ;
- The Financial and Consumer Affairs Authority of Saskatchewan, or FCAA ;
- The Financial Services Regulatory Authority of Ontario, FSRA ;
- Quebec’s Autorité des marchés financiers, or the AMF;
- The Financial and Consumer Services Commission of New Brunswick, or FCNB ;
- The OmbudService for Life and Health Insurance, or OLHI.
In attendance as keynote presenters from FSRA were Glen Padassery, Executive Vice President, Policy & Chief Consumer Officer, and Acting EVP, Auto/Insurance Products at the Financial Services Regulatory Authority of Ontario or FSRA); and by Stuart Wilkinson, FSRA’s Chief Consumer Officer.
As Executive Vice President, Policy & Chief Consumer Officer; and Acting EVP, Auto/Insurance Products at FSRA, Glen Padassery is responsible for working across core regulatory areas to develop rules regulating a myriad of sectors. In addition to leading FSRA’s strategic policy function, Mr. Padassery also has responsibility for the Innovation Office and the Consumer Office roles within the organization. He has spent over 20 years within the public sector, with extensive policy, program design, and consumer protection experience, most recently as Assistant Deputy Minister of Consumer Protection with Ontario’s Ministry of Government and Consumer Services.
Mr. Padassery’s colleague Stuart Wilkinson has spent over a decade working in public policy with a focus on financial services regulation in Ontario. He has held several different roles at FSRA, including Senior Manager of Strategic Policy on the Authority’s pre-launch transition team; Director of Auto / P&C Insurance Policy after FSRA launched, and most recently as Chief Consumer Officer. As Chief Consumer Officer, Mr. Wilkinson is responsible for leading FSRA’s Consumer Office. Before joining FSRA, Stuart Wilkinson worked in the P&C insurance industry and at the Ontario Ministry of Finance, where he provided advice to the government on financial services regulation, including reforms to the province’s auto insurance system and the government’s response to the expert panel that originally recommended the creation of FSRA.
After brief introductory remarks by Glen Padassery, the fireside chat began with Stuart Wilkinson explaining the history of the Office of the Consumer, including why it was created and its main functions. In 2016, the Ontario government hosted an expert panel review of three regulatory agencies and concluded that a new regulatory authority should be created – FSRA. The panel also suggested the creation of the Office to give voice to Ontario consumers of various financial products across the Ontario insurance industry. Therefore, when FSRA and the Office began, it had the panel’s recommendation for a Consumer Office, a refreshed consumer-focused mandate from the government, and a regulator down the street in the Ontario Securities Commission that had already created a strong Investor Office. At its inception, the Office’s purpose was to give voice to Ontario consumers where there has, historically, been a lack of such a voice. This remains its core focus.
Funding for the Office, like FSRA, is derived from fees and assessments collected from FSRA regulates. The Office is a common cost centre in FSRA, and as such, each section regulated by FSRA bears a portion of the Office’s cost. Cost assignment is largely determined by size. FSRA has always been and will continue to be transparent about its use of funds. With government approval, FSRA has the authority to retain its proceeds from enforcement action, although there are stipulations on the proper use of these funds. Soon, FSRA will be publishing its revised approach to the use of these funds to show its commitment to transparency in the sector.
Early in 2023, FSRA’s enterprise-wide strategy function was moved into the Office, which prompted a re-evaluation of the Office’s objectives. With the top priority continuing to remain amplifying the voices of Ontario consumers, the Office also identified a few other key areas. They are:
· Strategic foundations: this relates to the foundational frameworks and processes that support and sustain FSRA. The flagship responsibility with this objective is to effectively lead FSRA’s enterprise-wide strategic and business planning process.
· Policy leadership: the Office will identify and address issues and opportunities that are multi-sectorial, allowing FSRA to broaden its reach and understanding of Ontario consumers.
An important caveat was noted: the Office does not deal with consumer inquiries or complaints directly – FSRA has a separate centre for that. The Office is also not responsible for the delivery of FSRA consumer educational activities.
Stuart Wilkinson then highlighted the Office’s achievements to date. In terms of consumer-focused endeavours, the Office created a Consumer Advisory Panel whose main function is to inform FSRA of consumer perspectives and provide feedback on a variety of industry-specific topics. The Panel is now in its fourth year of operation and has allowed for a high quality of engagement between FSRA and its members. The Panel not only generates interesting discussions but it provides important and insightful feedback from industry stakeholders. The Office’s research efforts have also been successful, and it is now generating insightful publications summarizing consumers’ voices. Each publication also includes a responsive plan-of-action on how the Office plans on using or acting upon its findings.
Regarding its strategic foundation objectives, the Office is a few weeks away from publishing its proposed Statement of Priorities for feedback. Finally, in terms of policy leadership, the Office is responsible for some FSRA publications, including a framework for complaints resolution and a recent consultation draft of guidance on IT risk management. It also has also created an internal framework for the use of disclosure as a consumer protection tool, which has been shared with and presented to many of its regulator peers. This has helped the Office to take a more thoughtful approach as an organization to how and when it thinks of disclosure as a viable tool for achieving positive consumer outcomes.
Stuart Wilkinson then touched upon the ways in which the Office impacts CAFII members, the primary and perhaps most immediate impact being that CAFII members now have a regulator actively trying to work alongside them to understand Ontario consumers. This increasingly collaborative environment also indicates an industry shift in thinking towards a more consumer-centric model. That being said, there is still much work that needs to be done. Stuart Wilkinson identified two specific items: sharing consumer research and improving its external-facing processes. These are top priorities because the Office wants interactions with stakeholders, such as CAFII members, to be more efficient and informed. One such way FSRA and the Office have made efforts to improve their external-facing process is by making this the longest consultation period to date for their priorities.
Keith Martin mentioned that protecting consumers can be challenging because as a group they are not organized, not funded, and do not have one focused perspective. Stuart Wilkinson said that he completely agreed, and he said that insurance protection was critically important to Ontarians. A consumer-centric approach already exists within the insurance sector, and FSRA is aligned with that focus. A focus on vulnerable consumers is particularly important for FSRA going forward. Keith Martin noted that the insurance relationship with consumers is entirely based on trust, and what FSRA wants and what the industry is foundationally based on is completely aligned, and Stuart Wilkinson said that he was completely in agreement on that: “There is really strong alignment between all parties.”
Finally, the virtual fireside chat concluded with a brief explanation of the Office’s plans for the rest of 2023 and beyond. Of continued interest, the Office’s objectives include transforming its strategy and business planning process; publishing final guidance on IT risk management; launching its new approach to using proceeds from enforcement; and continuing to conduct and publish research results. However, aside from those objectives, Stuart Wilkinson indicated that one of the future goals for FSRA and the Consumer Office is to increase understanding and efforts around the treatment of vulnerable consumers across sectors. FSRA and the Consumer Office will be reaching out to CAFII members to ask for input and insight on this topic.
