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 Rajesh Narayanan Ramdass Raja.

NOTICE OF PROPOSAL TO REFUSE TO RENEW LICENCE AND TO IMPOSE AN ADMINISTRATIVE PENALTY

TO: Rajesh Narayanan Ramdass Raja

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 refuse to renew the life insurance and accident & sickness insurance agent licence issued to Rajesh Narayanan Ramdass Raja.

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 an administrative penalty in the amount of $20,000 on Rajesh Narayanan Ramdass Raja for providing false or misleading statements or representations in the solicitation or registration of insurance, contrary to section 17(c) 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

1. These are the reasons for the proposal by the Director to refuse to renew the life insurance and accident & sickness insurance agent licence issued to Rajesh Narayanan Ramdass Raja (“Ramdass Raja”) and to impose an administrative penalty in the amount of $20,000 on Ramdass Raja.

II. BACKGROUND

A. Licensing History

2. Ramdass Raja was licensed as a life insurance and accident & sickness insurance agent (licence # 16151272) under the Act. Ramdass Raja was first licensed on April 25, 2016.
3. Ramdass Raja’s licence expired on April 24, 2024.
4. On February 26, 2024, Ramdass Raja applied to the Financial Services Regulatory Authority of Ontario (“FSRA”) to renew his licence.

B. Specialty Life Insurance Report

5. On November 28, 2023, Specialty Life Insurance (“SLI”) submitted a Life Agent Reporting Form (“LARF”) to FSRA, alleging misconduct by Ramdass Raja. SLI terminated Ramdass Raja’s contract the same day.
6. The LARF alleged that Ramdass Raja engaged in misconduct by submitting insurance policy applications for individuals who did not exist or applications that otherwise contained false information. The applications were sold in September and October 2023.
7. On January 23, 2024, FSRA conducted an examination of Ramdass Raja’s business practices and identified multiple insurance policies with incomplete, unreliable, and invalid account information.
8. Ramdass Raja falsely advised FSRA that he had met with all insured consumers on the policies.
9. The FSRA investigation confirmed Ramdass Raja was paid over $9,000 in commissions for policies related to one consumer (CG) listed as payor for six (6) policies related to five (5) individuals (the “CG Policies”). When confronted with evidence that bank accounts used to pay premiums for the CG Policies were opened in CG’s name shortly before the CG Policies were taken out, Ramdass Raja admitted that:
   1. He was aware that some of the individuals listed on the policies did not exist,
   2. only one policy application was legitimate,
   3. he shared his advisor code with other licensed agents who conducted some of the fraudulent sales in his name, and
   4. he only received a small percentage of the commissions for the fraudulent policies.
10. Ramdass Raja received commissions totalling $85,249.88 in relation to the fraudulent policies, including the CG Policies.

III. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

A. False Statement in the Solicitation or Registration of Insurance

11. Section 17(c) of Ontario Regulation 347/04 states that a life insurance agent is prohibited from making a false or misleading statement or representation in the solicitation or registration of insurance.
12. Ramdass Raja admitted to repeatedly making false or misleading statements or representations in the registration of insurance.
13. The Director is satisfied that Ramdass Raja contravened section 17(c) of Ontario Regulation 347/04 by submitting life insurance applications for individuals who did not exist, or containing false banking information, and for facilitating others in doing the same using his agent code.

IV. GROUNDS TO REFUSE TO RENEW LICENCE

14. Section 392.4(1) of the Act states that the Chief Executive Officer shall issue a licence to act as an insurance agent in Ontario to an applicant who applies in accordance with section 392.3 of the Act and who satisfies the prescribed requirements for the licence unless the Chief Executive Officer believes, on reasonable grounds, that the applicant is not suitable to be licenced having regard to such circumstances as may be prescribed and such other matters as the Chief Executive Officer considers appropriate.
15. Section 4 of Ontario Regulation 347/04, subsections (a) and (i) respectively, provides that an applicant for a licence shall be granted a licence if the Chief Executive Officer is satisfied that the applicant is of good character and reputation, and otherwise suitable to receive a licence.
16. Section 7(4) of Ontario Regulation 347/04 permits the Chief Executive Officer to refuse renewal of an insurance agent licence on any grounds for which a licence may be suspended or revoked.
17. Section 8 of Ontario Regulation 347/04 permits the Chief Executive Officer to suspend or revoke a licence on any grounds on which an application can be refused or if it appears to the Chief Executive Officer that the licensee has:
    1. violated any provision of the licence in the licensee’s operations as an agent;
    2. made a material misstatement or omission in the application for the licence;
    3. been guilty of a fraudulent act or practice; or
    4. demonstrated incompetence or untrustworthiness to transact the insurance agency business for which the licence has been granted.
18. FSRA must assess suitability keeping in mind that 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.
19. The Director believes, on reasonable grounds, that Ramdass Raja is not suitable and is not of good character or reputation to be licensed under the Act. His conduct poses a significant risk to consumers that cannot be cured by attaching conditions to the licence. Ramdass Raja has demonstrated incompetence and untrustworthiness to transact business as an insurance agent by providing false information to the regulator in response to an investigation, repeatedly submitting applications with incorrect or fraudulent information, and for providing his agent code to allow others to submit fraudulent business in his name.
20. The Director is satisfied that a sanction less than refusal, such as licence conditions, would not reflect the severity of Ramdass Raja’s conduct and would not adequately protect consumers. Ramdas Raja cannot be trusted to act in accordance with his obligations under the Act which are meant to protect consumers and ensure governability by the regulator.

V. GROUNDS FOR IMPOSING AN ADMINISTRATIVE PENALTY

21. The Director is satisfied that imposing an administrative penalty on Ramdass Raja under section 441.3(1) of the Act will satisfy both of the following purpose 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.
22. The Director is satisfied that an administrative penalty in the amount of $20,000 should be imposed on Ramdass Raja for making false or misleading statements in the solicitation or registration of insurance, contrary to section 17(c) of Ontario Regulation 347/04.
23. 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.
24. In respect of the first criterion, the Director is satisfied that Ramdass Raja’s conduct with respect to the policies that he personally submitted was intentional. In assessing the policies submitted by other individuals, the Director is satisfied that Ramdass Raja intentionally provided his agent code to these individuals, which he was reckless in allowing them to continuously use his code to submit applications to SLI.
25. In respect of the second criterion, the Director has considered the harm that resulted from Ramdass Raja, including the direct financial harm to SLI for commissions paid on the fraudulent policies.
26. Ramdass Raja’s misconduct has the potential to harm public confidence in the regulatory regime established by the Act and its regulations by undermining his licence requirements and allowing others to submit fraudulent business. The public should be able to rely upon a licensed individual to act honestly and with integrity.
27. In respect of the third criterion, the Director is not aware of any steps taken by Ramdass Raja to mitigate the loss caused by his actions or take any other remedial action. Ramdass Raja intentionally attempted to conceal his actions from FSRA on multiple occasions.
28. In respect of the fourth criterion, the Director is satisfied that Ramdass Raja derived an economic benefit of commissions from the policies he put through and the policies he allowed others to put through in his name, in total amounting to $85,249.88.
29. In respect of the fifth criterion, the Director is not aware of any other contraventions or failures to comply in the previous five years.
30. 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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