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Financial Services Regulatory Authority of Ontario

IN THE MATTER OF the Insurance Act, R.S.O. 1990, c.I.8, as amended (the “Act”), in particular sections 392.4 and 407.1;

AND IN THE MATTER OF Manpreet Kaur Dhillon.


NOTICE OF PROPOSAL TO REFUSE TO RENEW LICENCE

TO: Manpreet Kaur Dhillon

TAKE NOTICE THAT pursuant to sections 392.4 and 407.1 of the Act, and by delegated authority from the Chief Executive Officer of the Financial Services Regulatory Authority of Ontario (the “Chief Executive Officer”), the Director, Litigation & Enforcement (the “Director”) is proposing to refuse to renew the life insurance and accident and sickness insurance agent licence issued to Manpreet Kaur Dhillon. The reasons for this proposal are described below.

Details of these contraventions and reasons for this proposal are described below. This Notice of Proposal includes allegations that may be considered at a hearing.

SI VOUS DÉSIREZ RECEVOIR CET AVIS EN FRANÇAIS, veuillez nous envoyer votre demande par courriel immédiatement à: contactcentre@fsrao.ca.

YOU ARE ENTITLED TO A HEARING BY THE FINANCIAL SERVICES TRIBUNAL (THE “TRIBUNAL”) PURSUANT TO SECTIONS 407.1(2) AND 407.1(3) OF THE ACT. A hearing by the Tribunal about this Notice of Proposal may be requested by completing the enclosed Request for Hearing Form (Form 1) and delivering it to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you. The Request for Hearing Form (Form 1) must be mailed, delivered, faxed or emailed to:

Address:  
Financial Services Tribunal
25 Sheppard Avenue West, 7th Floor
Toronto, ON
M2N 6S6

Attention: Registrar

Fax: 416-226-7750

Email: contact@fstontario.ca

TAKE NOTICE THAT if you do not deliver a written request for a hearing to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you, orders will be issued as described in this Notice of Proposal.

For additional copies of the Request for Hearing Form (Form 1), visit the Tribunal’s website at www.fstontario.ca

The hearing before the Tribunal will proceed in accordance with the Rules of Practice and Procedure for Proceedings before the Financial Services Tribunal (“Rules”) made under the authority of the Statutory Powers Procedure Act, R.S.O. 1990, c. S.22, as amended. The Rules are available at the website of the Tribunal: www.fstontario.ca. Alternatively, a copy can be obtained by telephoning the Registrar of the Tribunal at 416-590-7294, or toll free at 1-800-668-0128 extension 7294.

At a hearing, your character, conduct and/or competence may be in issue. You may be furnished with further and or other particulars, including further or other grounds, to support this proposal.

REASONS FOR PROPOSAL

    I. INTRODUCTION

  1. These are reasons for the proposal by the Director to refuse to renew the life insurance and accident and sickness insurance agent licence issued to Manpreet Kaur Dhillon (“Dhillon”).

  2. The Director is satisfied that Dhillon provided the CEO with two (2) false documents proposing to certify completion of the required continuing education (“CE”) hours for the 2019-2021 licensing period. In so doing, Dhillon demonstrated incompetence or untrustworthiness to transact the insurance agency business. Further, Dhillon made a material misstatement or omission on the 2021 licence renewal application. For these reasons, the Director believes Dhillon is not suitable to be licensed.

    3. II. BACKGROUND

  3. Dhillon has been licensed as a life insurance and accident and sickness insurance agent (licence # 17161496) under the Act since August 25, 2017.

  4. Dhillon’s licence expired on August 24, 2023.

  5. Dhillon operates as an insurance agent on a part-time basis.

    6. A. 2021 Licence Renewal Application

  6. On August 12, 2021, Dhillon submitted an application to renew their insurance agent licence (“2021 Licence Renewal Application”). At that time, Dhillon confirmed the required 30 CE hours would be completed by August 24, 2021.

  7. In making the 2021 Licence Renewal Application, Dhillon swore to have truthfully answered all questions, and certified that “Providing false, misleading or incomplete information in this application and/or any attachments requested may be sufficient grounds to reject the application or revoke a licence, or result in your prosecution. By clicking the “Confirmed” button below, you swear that you have truthfully answered all questions contained within this electronic application”.

  8. Dhillon further declared an understanding that any licence issued may be revoked for providing false or misleading information in the application.

  9. On August 15, 2022, Dhillon was selected by FSRA for a life agent examination. As a part of this examination, Dhillon was required to submit CE certificates as proof of completion of CE hours for the period 2019/08/25 to 2021/08/24.

  10. Dhillon provided documentation from Success Continuing Education (“Success”) purporting to certify completion of 30 hours of CE on August 16, 2021:

    1. Canada – Contemporary Insurance Topics for 15 hours dated August 16, 2021; and

    2. Canada – Ethics in the Insurance Marketplace for 15 hours dated August 16, 2021.


  11. On September 14, 2022, FSRA reached out to Success to confirm completion of the CE hours identified in the documentation. Success provided information that refuted the completion of courses for the licensing period in question. In an email to FSRA on September 14, 2022, Success advised “there are no courses completed within the time period of 2019/08/25-2021/08/24. There were courses completed in 2018 for 30 hours…”

  12. On February 10, 2023, FSRA advised Dhillon of the misrepresentation to FSRA and the outstanding required CE.

  13. On February 14, 2023, FSRA sent Dhillon written notice of a pending summary administrative penalty for failure to complete CE with an opportunity to provide written submissions.

  14. In an email exchange with FSRA between February 15 and 16, 2023, Dhillon asserted having purchased CE courses for the 2019 to 2021 licensing period.

  15. On April 4, 2023, FSRA issued an Order Imposing Summary Administrative Penalty in the amount of $1,000 against Dhillon for failure to complete CE. On May 3, 2023, Dhillon filed a Notice of Appeal with the Tribunal.

  16. On May 29, 2023, FSRA contacted Success and attempted to confirm the authenticity of the documentation provided by Dhillon purporting to certify completion of two CE courses. On May 30, 2023, Success advised FSRA that the two courses referred to in the documentation provided in response to examination were never taken by Dhillon.

    17. B. 2023 Licence Renewal Application

  17. On August 16, 2023, Dhillon submitted an application to renew the insurance agent licence (“2023 Licence Renewal Application”).

  18. Based on the events detailed above, FSRA proposes to refuse to renew Dhillon’s licence.

    19. III. GROUNDS FOR REFUSING TO RENEW LICENCE

  19. Section 14 of Ontario Regulation 347/04 states that an individual who holds a life insurance licence shall complete at least 30 hours every two years of continuing education acceptable to the Chief Executive Officer in respect of life insurance.

  20. Section 392.4 of the Act states that the Chief Executive Officer shall renew an insurance agent’s licence if the agent has satisfied the prescribed requirements for a licence unless he believes on reasonable grounds that the applicant is not suitable to be licensed, having regard to such circumstances as may be prescribed and other matters the Chief Executive Officer considers appropriate.

  21. Section 7(4) of Ontario Regulation 347/04 states that an application for renewal of an insurance agent licence may be refused on any grounds on which the Chief Executive Officer is authorized to suspend or revoke the licence.

  22. Section 392.5(1) of the Act states that the Chief Executive Officer may revoke or suspend an agent’s licence to act as an insurance agent, if the agent has failed to comply with the Act, the regulations or a condition of the licence.

  23. Section 392.5(2) of the Act and section 8 of the Ontario Regulation 347/04 permit the Director to revoke a licence on any grounds on which an application can be refused or if it appears to the Director that the licensee has done any of the following:

    1. Violated any provision of the license in the licensee’s operations as an agent;

    2. Has made a material misstatement or omission in the application for the license;

    3. Has been guilty of a fraudulent act or practice; or

    4. Has demonstrated incompetence or untrustworthiness to transact the insurance agency business for which the license has been granted.


    24. Dhillon Is Not Suitable to be Licensed

  24. Dhillon has been licensed since 2017 and is well aware of the CE requirement. Instead of complying with the requirement, Dhillon chose to make a material misstatement in the 2021 renewal application and submit false documentation to support that misstatement.

  25. The Director is satisfied that Dhillon is not suitable to be licensed. The failure to comply with the CE requirement together with the related misconduct provides grounds to refuse the renewal application.

  26. Dhillon provided responses and false documentation to the life agent examination with the intention of misleading FSRA on the satisfaction of CE hours that were in fact not completed. Dhillon is guilty of fraudulent acts and practices, and demonstrated untrustworthiness to transact the insurance agency business for which the licence was granted, which constitute grounds to refuse the licence renewal application under subsections (c) and (d) of section 8 of Ontario Regulation 347/04.

  27. Further, failure to comply with the CE requirement in section 14 of Ontario Regulation 347/04 provides reason to question whether Dhillon will have the requisite knowledge to carry on business in the insurance industry in a competent manner, and is a ground to refuse the licence renewal application under subsection (d) of section 8 of Ontario Regulation 347/04.

  28. By not completing the required CE hours, Dhillon made a material misstatement or omission in the 2021 Licence Renewal Application, which is a ground to refuse the licence renewal application under subsection (b) of section 8 of Ontario Regulation 347/04.

  29. FSRA must assess suitability keeping in mind that the purpose of licensing is to ensure that the public receives competent and ethical insurance brokering services from those licensed to participate in the industry. Licensed insurance agents serve as trusted advisors to their clients, who often rely on their insurance agents when making important financial decisions that can have a significant impact on their lives and well-being. As such, the questions posed to those who apply for licenses or renewals under the Act and during examinations are vitally important to FSRA in assessing the suitability and qualifications of applicants. These questions are a necessary screening tool to protect the public from unqualified, unsuitable, and unscrupulous persons.

  30. The Director believes that Dhillon is not suitable to be licensed and proposes to refuse to renew the licence.

  31. Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, September 1, 2023

Original signed by

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

Si vous desirez recevoir cet avis en français, veuillez nous envoyer votre demande par courriel immediatement a : contactcentre@fsrao.ca.