Life Insurance MGA Regulation - an opportunity for greater efficiency through a "Shared Accountability Model"?

The new regulatory framework in Ontario for MGAs in life insurance, places significant responsibilities on Insurers, MGAs and Agents.

There is now an opportunity for a well-defined shared accountability model to increase efficiency, reduce overlaps, clarify obligations and confirm possible reliance, while at the same time meeting regulatory obligations and protecting consumer interests.

Please reach out to discuss how we might help.

	Insurer	MGA	Agent
Regulatory adherence	Comply with all applicable regulatory requirements.	Comply with all applicable regulatory requirements.	Comply with all applicable regulatory requirements, including licensing suitability, and disclosure.
Contractual clarity	Establish clear contractual agreements outlining roles, responsibilities and performance.	Establish clear contractual agreements outlining roles, responsibilities and performance.	Establish clear contractual agreements outlining roles, responsibilities and performance.
Operating compliance	Adhere to policies and procedures to meet regulatory requirements, including. treating customers fairly.	Adhere to Insurer's policies and procedures and own regulatory requirements. Act in best interest of clients, providing suitable products and services.	Adhere to Insurer's and MGA's policies and procedures and own regulatory requirements. Act in best interest of clients providing suitable products and services.
Risk management	Work closely with MGAs (3rd party) to identify, assess and mitigate risks.	Implement a risk management framework to identify, assess and mitigate own risks.	Respond to information requests.
Training and support	Provide required training and support to MGAs and Agents to ensure compliance and good practices.	Provide required training and support to the Agents.	Attend and adhere.
Oversight and monitoring.	Implement effective oversight including regular reviews and audits.	Conduct due diligence on agents and establish effective oversight.
Record keeping	Maintain accurate and complete records of client and MGA interactions, transactions, disclosures and oversight activities.	Maintain accurate and complete records of all transactions, communications and compliance activities.	Maintain accurate and complete records of client interactions, transactions and disclosures.
Reporting	Provide timely and accurate reports to clients and regulators.	Provide timely and accurate reports to insurers.	Provide timely and accurate reports to insurers and MGAs.

While sharing accountability, also working together on:

• Collaboration - Foster open and effective communication between all parties.

• Incident Reporting - Establish a clear incident reporting process to promptly report any compliance breaches or regulatory violations.

• Corrective Action - Implement effective corrective action plans to address root causes and prevent future occurrences.