IN THE MATTER OF the Insurance Act, R.S.O. 1990, c.I.8, as amended (the “Act”), in particular sections 441.2 and 441.3;

AND IN THE MATTER OF Chintankumar Narendra Thakkar.

NOTICE OF PROPOSAL TO IMPOSE AN ADMINISTRATIVE PENALTY

TO: Chintankumar Narendra Thakkar

TAKE NOTICE THAT pursuant to section 441.3 of the Act, by delegated authority from the Chief Executive Officer (the “Chief Executive Officer”) of the Financial Services Regulatory Authority of Ontario (“FSRA”), the Director, Litigation and Enforcement (the “Director”) is proposing to impose an administrative penalty in the amount of $30,000 on Chintankumar Narendra Thakkar for acting as an insurance agent without a licence, contrary to subsection 392.2(6) of the Act and subsection 2(1) of Ontario Regulation 347/04.

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 441.3(2) AND 441.3(5) 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, 7^th Floor
Toronto, Ontario
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. TAKE FURTHER NOTICE of the payment requirements in section 5 of Ontario Regulation 408/12, which states that the penalized person or entity shall pay the penalty no later than thirty (30) days after the person or entity is given notice of the order imposing the penalty, after the matter is finally determined if a hearing is requested or such longer time as may be specified in the order.

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. The Director proposes to impose an administrative penalty in the amount of $30,000 on Chintankumar Narendra Thakkar (“Thakkar”) for acting as an insurance agent without a licence, contrary to subsection 392.2(6) of the Act and subsection 2(1) of Ontario Regulation 347/04.

II. BACKGROUND

2. Thakkar was employed as a Billing Specialist with an insurance company (the “Insurer”) from April 2021 to February 2022. After February 2022, Thakkar was not employed by the Insurer.
3. Thakkar is not and has never been licensed as an insurance agent under the Act. Thakkar is not and has never been a registered insurance broker under the Registered Insurance Brokers Act.
4. Between 2022 and 2024, Thakkar acted as an insurance agent in numerous automobile insurance registrations.
5. In meetings with prospective insureds, Thakkar held himself out as an insurance agent for the Insurer and engaged in activities restricted to licensed insurance agents under the Act, including soliciting and transmitting insurance applications.
6. Thakkar collected documents and personal information from the prospective insureds to apply for automobile insurance on their behalf.
7. Thakkar used the Insurer’s online system to bind insurance policies on behalf of the prospective insureds. During the application process, Thakkar impersonated the prospective insureds when using the Insurer’s online platform.
8. When binding insurance policies, Thakkar misrepresented to the Insurer that the prospective insureds were eligible for group automobile insurance discounts. The prospective insureds did not belong to these groups and thus did not qualify for these premium reductions.
9. Thakkar impersonated prospective insureds in telephone calls with the Insurer.
10. Thakkar collected fees of between $100 and $300 from the prospective insureds which they paid directly to Thakkar via e-transfer. In total, Thakkar collected at least $10,000 in fees from his unlicensed insurance agent activities.
11. FSRA issued a Cease-and-Desist letter to Thakkar on January 24, 2024, after receiving a complaint from the Insurer.
12. Following the discovery of Thakkar’s unlicensed activity and misrepresentation with respect to eligibility for group automobile insurance discounts, the insurance policies were cancelled. In at least one instance, the Insurer denied a claim made under a policy sold by Thakkar.

III. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

A. Unlicensed Insurance Agent Activity

13. Section 1 of the Act defines an insurance agent as a person who, for compensation, solicits insurance on behalf of an insurer, or transmits an insurance application or policy for another person, or acts in the negotiation of insurance with an insurer.
14. Section 2(1) of Ontario Regulation 347/04 provides that no individual, partnership or corporation shall act as an agent unless the individual, partnership or corporation is licensed.
15. Section 392.2(6) of the Act provides that every person who acts as an insurance agent in Ontario without the required licence is guilty of an offence.
16. Section 392.2(6) of the Act and section 2(1) of Ontario Regulation 347/04 are listed in Schedule I of Ontario Regulation 408/12 (Administrative Penalties).
17. Thakkar repeatedly acted as an insurance agent by transmitting insurance applications on behalf of his clients to the Insurer and charging a fee for this service. Thakkar was not licensed at the time of these transmissions and has never been licensed as an insurance agent in any capacity.
18. The Director is satisfied that Thakkar contravened section 392.2(6) of the Act and section 2(1) of Ontario Regulation 347/04 by acting as an insurance agent while not being licensed.

IV. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

19. The Director is satisfied that imposing administrative penalties on Thakkar under section 441.3(1) of the Act will satisfy one or both of the following purposes under section 441.2(1) of the Act:
    1. To promote compliance with the requirements established under the Act.
    2. To prevent a person from deriving, directly or indirectly, any economic benefit as a result of contravening or failing to comply with a requirement established under this Act.
20. The Director is satisfied that an administrative penalty in the amount of $30,000 should be imposed on Thakkar for acting as an insurance agent without a licence under the Act, contrary to section 392.2(6) of the Act and subsection 2(1) of Ontario Regulation 347/04.
21. In determining the amount of the administrative penalty, the Director has considered the following criteria as required by section 4(2) of Ontario Regulation 408/12:
    1. The degree to which the contravention or failure was intentional, reckless or negligent.
    2. The extent of the harm or potential harm to others resulting from the contravention or failure.
    3. The extent to which the person or entity tried to mitigate any loss or take other remedial action.
    4. The extent to which the person or entity derived or reasonably might have expected to derive, directly or indirectly, any economic benefit from the contravention or failure.
    5. Any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by the person or entity.
22. In respect of the first criterion, the Director is satisfied that Thakkar’s actions were intentional.
23. Thakkar engaged in a prolonged and intentional pattern of misconduct for his personal gain and to the detriment of consumers who relied on him. Thakkar knowingly acted as an unlicensed insurance agent in multiple transactions, having gained close knowledge of the Insurer’s processes while employed with it. Thakkar misrepresented himself to the prospective insureds. Thakkar knowingly transmitted ineligible applications for group automobile insurance rates.
24. In respect of the second criterion, the Director is satisfied that Thakkar’s conduct caused significant harm.
25. Clients who purchased policies through Thakkar were at risk of denied claims or policy cancellations. After Thakkar’s misconduct was discovered, the policies were cancelled. At least one insurance claim was denied.
26. Thakkar undermined the insurance licensing system in Ontario. The public relies on the regulatory regime established by the Act and is entitled to have confidence that regulated activities are carried out by those who are duly licensed to do so. The insurance agent licensing scheme provided in the Act is therefore a critical and necessary component in protecting the public interest. Unlicensed activities undermine the protections of the Act.
27. Automobile insurance protects the public from the risks associated with driving. Drivers without proper insurance place the public at substantial risk.
28. In respect of the third criterion, the Director is unaware of any steps taken by Thakkar to remedy or mitigate his contraventions. Thakkar continued to engage in unlicensed activity even though he was aware of the risks to the prospective insureds, and only stopped upon discovery of the scheme by the Insurer.
29. In respect of the fourth criterion, the Director is satisfied that Thakkar gained significant financial benefit from his unlicensed insurance activities. Thakkar collected at least $10,000 in fees. By operating outside the licensing framework, he also avoided compliance costs, such as licensing fees and insurance.
30. In respect of the fifth criterion, the Director is unaware of any other contraventions or failures to comply with a requirement under the Act or with any other financial services legislation in Ontario or of any jurisdiction during the preceding five years by Thakkar.
31. Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, November 14, 2025.

Original signed by

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

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