IN THE MATTER OF the Insurance Act, R.S.O. 1990, c.I.8, as amended (the “Act”), in particular sections 392.4, 407.1, 441.2 and 441.3;

AND IN THE MATTER OF Angie Sau Chu Lau.

NOTICE OF PROPOSAL TO REVOKE LICENCE AND TO IMPOSE
ADMINISTRATIVE PENALTIES

TO: Angie Sau Chu Lau

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 and Enforcement (“Director”) is proposing to revoke the insurance agent licence issued to Angie Sau Chu Lau (“Lau”).

AND TAKE NOTICE THAT pursuant to section 441.3 of the Act, and by delegated authority from the Chief Executive Officer, the Director is proposing to impose two administrative penalties totalling $150,000 on Lau for the following contraventions:

An administrative penalty of $100,000 for using inducement, coercion or undue influence in order to control, direct or secure insurance business, contrary to section 17(a) of Ontario Regulation 347/04; and
An administrative penalty of $50,000 for failing to disclose in writing a conflict of interest with transactions, contrary to section 16 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 407.1(2), 407.1(3), 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

These are reasons for the proposal by the Director to:
1. revoke the insurance agent licence issued to Angie Sau Chu Lau (“Lau”); and
2. impose administrative penalties in the total amount of $150,000 on Lau.
In addition, the Director is issuing an interim suspension for the insurance agent licence issued to Lau.

II. BACKGROUND

Lau is a licensed life insurance and accident and sickness insurance agent (licence #14135942). Lau was first licensed on February 28, 2016. Her licence is scheduled to expire on February 27, 2026.
Lau was contracted with Desjardins Financial Security Independent Network (“Desjardins”) since 2016, when she became licensed as an insurance agent. On March 25, 2024, Desjardins terminated Lau’s contract for the conduct described below.
On March 28, 2024, Desjardins filed a Life Agent Misconduct Report (“LAMR”) with the Financial Services Regulatory Authority of Ontario (“FSRA”) regarding Lau.
Lau was also licensed as a Dealing Representative (Mutual Fund Dealer) with Desjardins Financial Security Investments Inc. until March 25, 2024.

III. FACTS

Lau had a longstanding client base, with many clients who trusted her. Client funds were invested in both mutual funds and segregated fund products. Segregated funds are similar to mutual funds with an insurance component and are classified as a type of insurance under the Act.
In January to March of 2024, Lau contacted numerous clients and convinced them to cash out their segregated funds and provide her with the proceeds. In some cases, Lau advised clients to take the money from their segregated funds held in Registered Retirement Savings Accounts (“RRSPs”) and/or Tax-Free Saving Accounts (“TFSAs”).
Some clients who redeemed segregated funds incurred fees. Others who redeemed from their RRSPs were subject to taxes.
Lau told clients that the money they provided to her would be invested. She provided minimal details on the type of investment but told clients that it would pay a high rate of interest over three months. Lau provided clients with post-dated cheques that purported to include the high investment returns. Lau did not provide any written disclosure, including any disclosure of the risks or her role in the supposed investment.
In total, 36 of Lau’s clients redeemed their Desjardins segregated fund investments between January to March of 2024. The gross amount of redemptions was $2,279,915.04. Net of taxes and fees the amount redeemed was $1,937,218.45. At least $781,623 of the client funds were deposited into one of Lau’s personal bank accounts.
At the end of the alleged investment period, Lau told her clients that she had been scammed, that the post-date cheques would not be honoured, and that the funds would not be recovered.
When Desjardins investigated Lau for the unusually high number of client redemptions, Lau provided false information intended to deceive Desjardins. She told Desjardins that the redemptions were initiated by clients for personal or financial reasons and that she had not received any of the funds.
FSRA sent Lau an inquiry letter requiring the production of records and attendance at an interview. She did not attend the interview or provide the requested records. Lau told the FSRA Investigator that she was unable to respond to the inquiry for an extended period due to a medical condition.
Lau filed a fraud report with the Canadian Anti-Fraud Centre. In the complaint, Lau stated that she was the victim of a $3-million crypto-currency fraud. She did not identify which portion of the losses were client funds.
Lau’s bank account records show large transfers of funds to different recipients. The names of the recipients do not match the names in Lau’s complaint nor the name of the crypto platform.

IV. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

Undue Influence

Section 17(a) of Ontario Regulation 347/04 states that an agent who holds a life insurance licence shall not offer inducement or use coercion or undue influence in order to control, direct or secure insurance business.
Lau offered inducement and used undue influence to control and direct insurance business. She used her position of trust as her clients’ long-time insurance agent and her knowledge of their insurance investments to improperly encourage them to withdraw their funds and invest with her.
The Director is satisfied that Lau offered inducement and used undue influence to control insurance business, contrary to section 17(a) of Ontario Regulation 347/04.

Conflict of Interest Disclosure

Section 16 of Ontario Regulation 347/04 states that an agent shall disclose in writing to clients any conflict of interest or potential conflict of interest of the agent that is associated with the transaction or recommendation.
Lau made no written disclosures to her clients. She did not provide them with details about the investment. She did not disclose in writing her actual or potential conflict of interest caused by her direct involvement and financial benefit from the investment.
The Director is satisfied that Lau did not disclose in writing to clients the conflict of interest or potential conflict of interest associated with the withdrawals to invest with her.

V. GROUNDS FOR REVOCATION OF LAU’S INSURANCE AGENT LICENCE

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.
Section 392.5(2) of the Act further states that the Chief Executive Officer may revoke or suspend an agent’s licence if any prescribed grounds for revoking or suspending a licence, or for refusing to issue a licence exist.
Section 8 of Ontario Regulation 374/04 provides the prescribed grounds. Section 8 permits the Chief Executive Officer to revoke a licence on any grounds in which an application for licence may be refused or if, after due investigation and hearing, it appears to the Chief Executive Officer that the licensee:
1. has violated any provision of the licence in the licensee’s operations as an agent;
2. has made a material misstatement or omission in the application for the licence;
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 licence has been granted.
The Director has reasonable grounds to believe that Lau is not suitable for licensing under the Act. Lau has demonstrated incompetence and untrustworthiness by using her position as an insurance agent and her longstanding client relationships to persuade her clients to liquidate their insurance products in order to invest in a dubious investment scheme.
Further, Lau lied to Desjardins about why her clients were cashing out their investments. She said it was because of their financial situations when, in reality, she encouraged them to make the withdrawals.
Lau did not participate in FSRA’s investigation.
Agents who lie to an insurer and who do not cooperate with the regulator’s investigation are not suitable to be licensed. Cooperation with investigations is a core component of being in a regulated profession.
Furthermore, Lau has contravened the Act by offering inducement and using undue influence to control and direct insurance business, contrary to section 17(a) of Ontario Regulation 347/04. She also contravened section 16 of Ontario Regulation 347/04 by failing to disclose a conflict of interest or potential conflict of interest with the client transactions.
The purpose of licensing is to ensure that consumers receive competent and ethical insurance brokering services from those licensed to participate in the industry. When FSRA issues a licence, it is considered a public endorsement that the licensee can serve as a trusted advisor 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.
The Director believes, on reasonable grounds, that Lau is not suitable and is not of good character or reputation to be licensed under the Act. Her conduct poses a significant risk to consumers that cannot be cured by attaching conditions to the licence.
The Director is satisfied that a sanction less than refusal, such as licence conditions, would not reflect the severity of Lau’s conduct and would not adequately protect consumers. Lau cannot be trusted to act in accordance with her obligations under the Act which are meant to protect consumers and ensure governability by the regulator.

VI. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

The Director is satisfied that imposing administrative penalties under section 441.3(1) of the Act for Lau’s contraventions as described above will satisfy both of the following purposes under section 441.2(1):
1. To promote compliance with the requirements established under the Act; and
2. to prevent a person from deriving, directly or indirectly any economic benefit because of contravening or failing to comply with a requirement established under the Act.
The Director is satisfied that administrative penalties of $150,000 should be imposed on Lau. These administrative penalties will promote compliance with the Act and will help prevent Lau from retaining the economic benefit she expected to receive from her contraventions.
Section 17(a) of Ontario Regulation 347/04 carries a maximum penalty of $100,000 for an individual. Section 16 of Ontario Regulation 347/04 carries a maximum penalty of $50,000 for an individual.
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; and
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.
Consideration of these criteria shows that the maximum amounts under the Act are appropriate for both contraventions.
In respect of the first criterion, the Director is satisfied that Lau’s conduct was intentional. Lau repeatedly targeted individuals over whom she held a position of trust as their insurance agent and persuaded them to withdraw their funds and provide them to her. She did not make any written disclosure to the clients of actual or potential conflicts of interest. Lau knew her conduct was not acceptable or appropriate, as she then lied about it to Desjardins.
In respect of the second criterion, the Director is satisfied that Lau’s conduct caused financial harm to her clients. Lau’s clients withdrew $1,937,218.45 from their accounts, at least $781,623 of which was directly transferred to Lau and not repaid. While Desjardins ultimately repaid some clients for their losses, this simply transferred the loss from those clients to Desjardins.
In respect of the third criterion, the Director is not aware of any steps taken by Lau to mitigate any loss caused by her conduct or any other remedial action. She has not repaid the affected clients. While she appears to have reported the fraud, her fraud report portrayed the losses as her own and did not take responsibility for her own role in losing client funds.
In respect of the fourth criterion, the Director is satisfied that Lau expected to derive a substantial direct economic benefit from her conduct. Lau’s clients transferred her at least $781,623.
In respect of the fifth criterion, the Director is unaware of any contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation in Ontario or of any jurisdiction during the preceding five years by Lau. The Director is aware that the Canadian Investment Regulatory Organization has initiated proceedings against Lau for failure to comply with the Mutual Fund Dealer Rules.
Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, December 2, 2025.

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.

NOTICE OF PROPOSAL TO REVOKE LICENCE AND TO IMPOSE ADMINISTRATIVE PENALTIES