Red Tape Challenge: Financial services summary

Re: Mortgage brokerages – information disclosure

The forms for investing in a mortgage for a non-accredited investor are too long and have irrelevant information. They should focus on the rank of the mortgage, prior encumbrances, loan to value, fees earned by the brokerage, fees earned by any referral sources, appraised value and the relevant risks associated with investing in the mortgage. I do not think the current forms do an adequate job explaining prior encumbrances and that investors understand the associated risks.

Re: Registered Insurance Brokers Act

Section 10 of Regulation 991 of the Registered Insurance Brokers Act needs to be updated to provide an exemption for sophisticated insurance buyers (e.g. multinational corporations with risk departments) who are hampered, not assisted, by its onerous obligations. Simple parameters could be established to qualify as a sophisticated commercial purchaser exempt from the requirements of sub section 10.1 (c).

Re: Mortgage Brokerages – information disclosure

Investors are looking for more concise disclosure. The current language used in the disclosure is not plain and leave room for many interpretations. Disclosure should be shortened to 4 pages max which will give room for all necessary information. Additional pages could be added at the brokers discretion for more complex deals.

Re: Automobile insurance - disputes between insurance companies

Section 10 (2) should be amended to read: "This Regulation, and in particular Sections 3 and 3.1, apply to the insurer given notice under s. 10 (1), if that insurer given notice wishes to dispute its obligation to pay benefits under this Regulation". This is necessary to clear up the confusion over how to interpret the current wording of s. 10 (2). The amendment is necessary to make clear what was originally intended. As amended, all insurers must abide by the 90 day time limit under s. 3, commence the arbitration within 1 year and complete the arbitration within 2 years. Current interpretation has allowed insurers to avoid the time limits which are necessary to keep the dispute mechanism a quick, efficient and low cost method to settle disputes.

Most commented on pieces of legislation

1. Taxation Act (17 comments)
2. Employment Standards Act (16 comments)
3. Financial Services Commission of Ontario - fee assessment (14 comments)

Most commented on categories

1. Employment and labour regulations (47 comments)
2. Financial services regulations (46 comments)
3. Taxation and financial reporting regulations (28 comments)