IN THE MATTER OF the Insurance Act, R.S.O. 1990, c.I.8, as amended (the “Act”), in particular sections 441, 441.2 and 441.3;

AND IN THE MATTER OF Andi Efovia.

NOTICE OF PROPOSAL TO IMPOSE ADMINISTRATIVE PENALTIES AND IMPOSE COMPLIANCE ORDER

TO: Andi Efovia

TAKE NOTICE THAT pursuant to section 441 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, (the “Director”)is proposing to issue a compliance order to Andi Efovia directing him to cease and desist from conducting insurance business in the Province of Ontario, including advertising, soliciting, offering, selling, and adjusting auto insurance.

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 in the total amount of $25,000 on Andi Efovia as follows:

1. One administrative penalty in the amount of $15,000 for contravening 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 duly licensed; and
2. One administrative penalty in the amount of $10,000 for contravening section 401 of the Act by representing himself and/or holding himself out to the public as an insurance agent while not being duly licensed.

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.

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YOU ARE ENTITLED TO A HEARING BY THE FINANCIAL SERVICES TRIBUNAL (THE “TRIBUNAL”) PURSUANT TO SECTIONS 441(3), 441(5), 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 W, Suite 100
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. These are the reasons for the proposal by the Director to:
   1. Impose a compliance order on Andi Efovia (“Efovia”); and
   2. Impose two administrative penalties in the total amount of $25,000 on Efovia

II. BACKGROUND

A. Efovia

2. Efovia is not, and has never been licensed as an insurance agent under the Act or as an insurance broker under the Registered Insurance Brokers Act, R.S.O. 1990, c. R.19.

B. Unlicensed Insurance Agent Activity

Complaints from Insurers

3. In January and February 2024, the Financial Services Regulatory Authority of Ontario (“FSRA”) received complaints from Co-operators General Insurance Company (“Co-operators”) and TD Insurance (“TDI”) alleging that,
   1. In 2022 and 2023, Efovia applied for approximately 89 auto insurance policies on behalf of consumers;
   2. Efovia provided false and/or misleading information when applying for the auto insurance policies resulting in lower premiums for applicants;
   3. Efovia impersonated consumers or represented himself as a friend or translator of the consumers while arranging auto insurance policies for them; and
   4. Efovia held himself out as an insurance agent on social media.

FSRA Investigation

4. Efovia held himself out as an insurance agent and advertised his services on YouTube, offering to arrange insurance coverage at lower premium payments.
5. In 2022 and 2023 Efovia arranged or attempted to arrange for the issuance and placement of auto insurance policies with Co-operators or TDI for consumers, while not being licensed to do so.
6. FSRA examined information and documents relating to 10 policies written by Co-operators and 7 policies written by TDI (the “Subject Policies”) and identified one or more of the following discrepancies and false information in the Subject Policies:
   1. False contact information, including phone number and email addresses were provided to insurers. Efovia used and provided to Co-operators and TDI at least 3 email addresses and one phone number operated by him;
   2. Efovia provided his own payment and contact information for some of the Subject Policies. Payments relating to 5 of the Co-operators Subject Policies were made using the credit card of Efovia’s spouse; and
   3. Efovia appears to have impersonated consumers or acted as a friend or translator of the consumers on the phone calls with the insurers over which the policies were arranged.
7. The policy holders of the 7 TDI Subject Policies paid Efovia between $250 - $2,000 for the arrangement of their policies (“Service Fee”) using Interac e-transfer service which was deposited to Efovia’s bank account.

III. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

A. Unlicensed Activity

8. As per section 1 of the Act, an “agent” means a person who for compensation, commission or any other thing of value, solicits insurance on behalf of an insurer or transmits, for a person other than himself, herself or itself, an application for, or a policy of insurance to or from such insurer, or offers or assumes to act in the negotiation of such insurance or in negotiating its continuance or renewal with such insurer.
9. Section 392.2(6) of the Act provides that every person who acts as an insurance agent in Ontario without the licence required by Part XIV of the Act is guilty of an offence.
10. 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 under the regulation.
11. Section 401 of the Act provides that a person who, not being duly licensed as an agent, represents or holds himself, herself or itself out to the public as being such an agent, or as being engaged in the insurance business by means of advertisements, cards, circulars, letterheads, signs, or other methods is guilty of an offence.
12. As described above, in 2022 and 2023, Efovia, while not being licensed as an insurance agent under the Act, applied for, arranged, or attempted to arrange auto insurance policies for consumers. Efovia’s unlicensed activity was conducted systematically and repeatedly over a sustained period of time.
13. Efovia advertised his unlicensed insurance agent services on social media and held himself out as an insurance agent to the public.
14. The Director is satisfied that Efovia 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 duly licensed.
15. Further, the Director is satisfied that Efovia contravened section 401 of the Act by representing himself and holding himself out as an insurance agent to the public while not being duly licensed.

IV. GROUNDS FOR IMPOSING COMPLIANCE ORDER

16. Section 441(1) of the Act provides that upon examination or investigation, or upon any other evidence, the Chief Executive Officer shall make a report if they are of the opinion that a person has committed or is committing any act, or has pursued or is pursuing any course of conduct, that is an unfair or deceptive act or practice or might reasonably be expected to result in a state of affairs that would constitute an unfair or deceptive act or practice.
17. Section 441(2)(a) of the Act provides that the Chief Executive Officer may order the person identified in the report to cease or refrain from doing any act or pursuing any course of conduct identified by the Chief Executive Officer, after giving notice in writing.
18. Section 3(1) of the Unfair or Deceptive Acts or Practices Rule provides that the commission of any act prohibited under the Act, or under any regulation or Authority rule made under the Act is an unfair or deceptive act or practice.
19. As stated in Part III of the proposal and described in the Chief Executive Officer’s Report at Schedule “A” to this Notice of Proposal, Efovia, on several occasions and over a sustained period of time, contravened the Act and its regulations by acting as an insurance agent and holding himself out as such without being duly licensed under the Act.
20. In view of the above, the Director is of the opinion that Efovia has committed unfair or deceptive acts or practices and should be ordered to permanently and immediately cease and desist from conducting insurance business in the Province of Ontario, including advertising, soliciting, offering, selling, and adjusting auto insurance.
21. The order is appropriate to protect the public, insurers, and maintain confidence in the regulatory regime under the Act.
22. The Director is therefore satisfied that there are sufficient grounds to impose the compliance order described in this Notice of Proposal.

V. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

23. The Director is satisfied that imposing administrative penalties on Efovia 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.
24. In determining the amount of the administrative penalties below, 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.
25. The Director is satisfied that an administrative penalty in the amount of $15,000 should be imposed on Efovia for contravening 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 duly licensed.
26. The Director is satisfied that an administrative penalty in the amount of $10,000 should be imposed on Efovia for contravening section 401 of the Act by representing himself and holding himself out as an insurance agent while not being duly licensed.
27. In respect of the first criterion, the Director is satisfied that Efovia knowingly, intentionally, and repeatedly engaged in unlicensed insurance agent activity over a sustained period of time and advertised his unlicensed services.
28. Efovia’s conduct exhibits a deliberate and systematic effort to contravene the Act. Efovia developed a scheme to attract and arrange auto insurance policies for a large number of consumers using false information and impersonating consumers.
29. In respect of the second criterion, the Director is satisfied that Efovia’s unlicensed insurance agent activities have caused and had the potential to cause significant harm to insurers and consumers and has harmed the public interest.
30. The affected consumers were deceived into relying on an unlicensed person to arrange their insurance and paid a fee for doing so. Being unlicensed, Efovia had no regulatory oversight or E&O insurance and arranged insurance by using deceptive means. The insurance coverage of the consumers who had acquired insurance through Efovia were cancelled or had the potential to be cancelled or denied, putting the consumers, other members of the public, and other insurers at risk of financial harm.
31. Co-operators and TDI incurred the risk of providing insurance coverage based on false representations and also risked determining incorrect premiums on that basis.
32. The auto insurance regime in Ontario is a public good. As auto insurance is mandatory, the harm arising from any irregularity or avoidance of premiums is ultimately borne by other consumers.
33. The insurance agent licensing regime provided in the Act and its regulations is a critical and necessary component in protecting the public interest. The public and industry participants rely on the regime and are entitled to have confidence that regulated activities are carried out by persons who are duly licensed to do so.
34. The conduct of Efovia has resulted in a significant and repeated subversion of the licensing regime which not only put the interests of consumers and insurers at risk of potential harm but also undermined the integrity of the regime and harmed the public interest.
35. In respect of the third criterion, The Director is not aware of any steps taken by Efovia to remedy or mitigate the contraventions identified in this Notice of Proposal. Efovia declined to cooperate with FSRA’s investigation and did not respond to a letter dated June 5, 2024, issued to him by FSRA in respect of the investigation.   
36. In respect of the fourth criterion, the Director is satisfied that Efovia repeatedly gained or reasonably expected to have gained financial benefit from the above-described unlicensed activity. Efovia appeared to have earned at least $9,000 as Service Fees for applying and arranging insurance for consumers.
37. In respect of the fifth criterion, the Director is not aware of any other contraventions or failures to comply in the preceding five years by Efovia.   
38. Such further and other reasons as may come to the attention of the Director.

DATED at Toronto, Ontario, January 14, 2026

Original signed by

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

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SCHEDULE “A”
REPORT OF THE CHIEF EXECUTIVE OFFICER

I. INTRODUCTION

1. The Director, by delegated authority from the Chief Executive Officer, is of the opinion that Efovia is committing acts or pursuing a course of conduct that constitutes an unfair or deceptive act or practice under the Act. This is the Director’s report pursuant to section 441 of the Act.

II. FACTS

2. The Director is satisfied of the facts as outlined in the Notice of Proposal, above.
3. Efovia is not, and has never been licensed as an insurance agent under the Act or as an insurance broker under the Registered Insurance Brokers Act, R.S.O. 1990, c. R.19.
4. In 2022 and 2023, Efovia deliberately engaged in the solicitation and arrangement of insurance policies written by Co-operators General Insurance Company and TD Insurance for consumers. This constituted unlicensed insurance agent activity contrary to section 392.2(6) of the Act and section 2(1) of Ontario Regulation 347/04.
5. Further, Efovia held himself out as an insurance agent and advertised his services on YouTube, while not being duly licensed, contrary to section 401 of the Act.

III. UNFAIR OR DECEPTIVE ACTS OR PRACTICES

6. Section 439 of the Act states that no person shall engage in an unfair or deceptive act or practice. Section 438 of the Act defines unfair or deceptive act or practice as any activity or failure to act that is prescribed by the Authority rules as an unfair or deceptive act or practice.
7. Section 3(1) the Unfair or Deceptive Acts or Practices Rule provides that the commission of any act prohibited under the Act, or under any regulation or Authority rule made under the Act is an unfair or deceptive act or practice.
8. As described in Section III of the Notice of Proposal, the Director is satisfied that Efovia deliberately and repeatedly 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 duly licensed.
9. The Director is further satisfied that Efovia contravened section 401 of the Act by representing himself as and holding himself out as an insurance agent to the public while not being duly licensed.
10. Accordingly, the Director is of the opinion that Efovia has committed unfair or deceptive acts or practices and should be ordered to permanently and immediately cease and desist from conducting insurance business in the Province of Ontario, including advertising, soliciting, offering, selling, and adjusting auto insurance.