We remind interested parties to submit comments to the Financial Services Regulatory Authority of Ontario's (FSRA) consultation about its proposed approach to strengthen the protection of vulnerable consumers in its regulated sectors (Proposed Approach). FSRA has requested comments on the Proposed Approach by March 8, 2024.

FSRA's Proposed Approach

The Proposed Approach would apply to all of the sectors that FSRA regulates in the Province of Ontario, which are: property and casualty insurance, life and health insurance, credit unions and caisses populaires, loan and trust companies, mortgage brokers, health services providers (related to auto insurance), pension plan administrators, and financial planners and advisors. The Proposed Approach would add to the separate consumer protection measures enforced by FSRA relating to its regulated sectors. FSRA is requesting comments both on the proposed obligations for regulated entities in the Proposed Approach, as well as the definition of "vulnerable consumers."

The objective of the Proposed Approach is to close the gap between the experiences of vulnerable consumers and non-vulnerable consumers in the sectors it regulates. The expectations in the Proposed Approach are centered on the following two goals:

  1. Promoting inclusive and fair treatment of vulnerable consumers and preventing targeted financial mistreatment.
  2. Improving consumer education, engagement, and awareness building efforts.

Part of a trend

The exploitation of vulnerable consumers, especially older consumers, is a problem of significant magnitude in Canada. This problem has spurred lawmakers and industry regulators across Canada to explore initiatives geared toward addressing the issue. The Proposed Approach appears to be a part of the trend of new laws and financial industry regulations encouraging financial services firms to take proactive steps to protect vulnerable consumers.

Next steps

Once the comment period has closed, FSRA will publish a consultation summary report and next steps in finalizing and implementing its proposed approach. For those interested in submitting comments, FSRA has published a list of questions that will help guide their consultation submission in Section C of the Proposed Approach.

For any questions you may have about these topics, please contact the authors or a member of our Financial Services Regulation Group.