When FSRA Proposes Action Against Your Licence
This page is for people and businesses licensed under the Insurance Act to act as insurance agents or adjusters, including partnerships and corporations that hold agency licences. FSRA can act on its own review, on a complaint, or on information from insurers, managing general agents and other regulators. Hearings are before the Financial Services Tribunal (FST).
Illustrative example, not an actual FSRA notice
“Take notice that the Chief Executive Officer proposes to revoke your licence as a life insurance agent and to impose an administrative penalty, for the reasons set out in this notice. You may request a hearing before the Financial Services Tribunal within 15 days after this notice is given.”
Brokers of property and casualty insurance are generally regulated by the Registered Insurance Brokers of Ontario, a separate regulator. This page covers FSRA-licensed agents and adjusters.
Who Investigates and Who Decides
- Regulator
- FSRA, acting through its Chief Executive Officer (CEO) under the Insurance Act, Part XIV (agents, brokers and adjusters), and its regulations and FSRA rules.
- Who decides
- The CEO proposes licence action. If you request a hearing, the Financial Services Tribunal decides and may direct the CEO to carry out the proposal, with or without changes, or substitute its own opinion and impose conditions (Insurance Act, s. 407.1(4)).
- Who hears appeals
- The Divisional Court (s. 407.1(5)). The FST’s order takes effect immediately, but the FST may stay it pending appeal (s. 407.1(6)).
Individuals and agencies
Licences can be issued to partnerships and corporations, and an agency licence can be revoked or suspended as to particular members (Insurance Act, ss. 399–400). A finding about one agent can therefore raise questions about the agency’s supervision, and the reverse.
Common Issues in Insurance Agent Investigations
Suitability and needs analysis
Selling products that do not fit the client’s needs, or not documenting a needs analysis, especially for segregated funds, universal life and replacement policies.
Misrepresentation and replacements
Misleading illustrations, undisclosed costs, and replacing policies to the client’s disadvantage.
Licensing and errors and omissions coverage
Acting while unlicensed or after lapsed E&O coverage, failing to complete continuing education, and inaccurate licence applications.
Premiums and money handling
Misappropriating premiums or client funds, and paying compensation for placing or negotiating insurance to people who are not agents or brokers (s. 403).
Managing general agent oversight
Concerns about how a managing general agent (MGA) recruited, trained or supervised agents can lead to questions for the agents themselves. Amendments passed in 2024 will require life and accident and sickness MGAs to hold their own licence (ss. 407.3–407.13), but as of this page’s research date those provisions were awaiting proclamation.
What Can Happen Next
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Notice of Proposal
Before refusing, renewing on new conditions, amending, suspending or revoking an agent or adjuster licence without your consent, the CEO must give written notice with reasons (Insurance Act, s. 407.1(1)–(2)).
Deadline
The FST must hold a hearing if you request one in writing within 15 days after the notice is given (Insurance Act, s. 407.1(3)). The FST’s Form 1 is used to request a hearing on a Notice of Proposal. Confirm with the FST or a lawyer how the date of giving is determined for your notice.
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Administrative penalties
The CEO may propose a general administrative penalty of up to $100,000 for an individual or $200,000 for any other person, or any lesser prescribed amount (Insurance Act, ss. 441.3, 441.5(1)). Summary penalties under s. 441.4 are capped at $25,000 (s. 441.5(2)). For a proposed general penalty, you may request a hearing within 15 days after the notice is given (s. 441.3(5)).
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Hearing and appeal
The FST decides the matter after a hearing. A party may appeal the FST’s order to the Divisional Court (Insurance Act, s. 407.1(5)).
Enforcement is public. FSRA publishes its enforcement actions, including Notices of Proposal and outcomes, in a public database.
Checklist: Responding to an FSRA Notice
Documents to gather
- The Notice of Proposal or penalty, and proof of the date it was given
- Client files: needs analyses, illustrations, applications, replacement disclosures and signed forms
- Premium and commission records, and any trust or client-money records
- Licence applications, renewals, continuing education and E&O certificates
- Communications with clients, the insurer and your MGA or agency
Details to check in the notice
- What is proposed: licence action, a penalty, or both
- The date the notice was given, and your 15-day window
- Whether you, your agency, or both are named
Rules and resources to consult
- Insurance Act, Part XIV (including ss. 399–407.1) and Part XVIII.1 (ss. 441.2–441.5)
- The regulation governing agents, and FSRA rules and guidance for life and general agents
- Financial Services Tribunal rules and Form 1 (Request for Hearing)
- Your E&O insurer
Frequently Asked Questions
I sell property and casualty insurance as a broker. Is FSRA my regulator?
Usually not for licensing conduct. Registered insurance brokers are generally regulated by the Registered Insurance Brokers of Ontario. Check which licence you hold and which body issued it.
Can FSRA suspend my licence before a hearing?
Section 407.1 excludes interim orders authorized elsewhere in the Act from the notice process. Check whether your notice includes an interim order, and get advice immediately if it does.
Will this be public?
Yes. FSRA publishes enforcement actions, including Notices of Proposal, in its public enforcement database.
Sources
Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.
- Insurance Act, R.S.O. 1990, c. I.8, ss. 399–400, 403, 407.1, 441.3–441.5 (MGA provisions ss. 407.3–407.13 not yet proclaimed) — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
- Financial Services Tribunal, “Forms” (Form 1: Request for Hearing) — Checked November 10, 2026.
- FSRA, public enforcement database — Checked November 10, 2026.