The Insurance Council of British Columbia (ICoBC) has found that Ebube Ferdinand Osemene (licence no. LIC-2022-0033541-R01), a life and accident & sickness insurance agent, failed to meet the competency and client-service standards required of a licensee.

The decision was rendered on September 15, 2026.

The respondent had recommended universal life insurance to the complainants without conducting an adequate Financial Needs Analysis. When they later sought to exit the policies, he incorrectly told them no cancellation form was required, believing he could transfer the request to the insurer directly. On June 28, 2023, the complainants submitted a refund request; the insurer cancelled the four policies and refunded the premiums.

The investigation

In parallel, the insurer conducted its own investigation, terminated its advisor contract with the respondent, and revoked his commissions through clawbacks. On September 5, 2024, Council received a Life Agent Reporting Form (LARF) from the insurer, along with a complaint filed by the complainants.

The insurer's review also revealed record-keeping problems that extended beyond the complainants' own files. Personal Financial Summary (PFS) forms for several clients were found to be unsigned, undated, or both. Two other clients of the respondent each stated they had no concerns about his recommendations or service, but their files nonetheless contained unsigned or undated forms.

Osemene’s supervisor at the agency noted that initial paperwork was satisfactory, but that client follow-up needed improvement and which the supervisor had discussed with the respondent. The supervisor did not, however, identify suitability concerns with the policies sold.

Council also considered the agent's professional profile in assessing the circumstances. He was a new agent under supervision at the material time, working part-time. Osemene also holds licences in Alberta and Ontario. He cooperated with Council's investigation and acknowledged his documentation failures.

The counts

From those facts, Council sustained three counts against the respondent: recommending universal life insurance without an adequate Financial Needs Analysis, failing to maintain complete and accurate client records, and providing incorrect information about the cancellation process.

On the first count, the respondent failed to inform the complainants properly of all aspects of the products and overlooked term insurance as a more suitable alternative given their financial circumstances.

Documentation was the focus of the second count: the respondents did not maintain complete and accurate records, including unsigned and undated PFS forms for four clients.

On the third count, he provided contradictory information about the cancellation and refund process, including incorrectly advising that no cancellation form was required.

The decision

Not every allegation was sustained, however. Two did not result in findings against the respondent. The allegation that he processed insurance policies against the complainants' instructions and sold policies without their knowledge was not sustained, as Council found he did not willfully mislead them.

An allegation regarding failure to deliver the insurance policies was withdrawn after the respondent provided email proof of delivery on May 12, 2023. Council also found insufficient evidence that the respondent willfully withheld material information, took advantage of the complainants, or placed his own interests above theirs, and concluded that no breach of the usual practice of dealing with insurers principle had occurred.

Council’s findings

In assessing those breaches, Council drew a clear line between competency failures and dishonesty. The respondent's failures were competence-related rather than deliberate: Council found him credible and genuine in his intentions to help the complainants, did not find him untrustworthy, and accepted that any failure to provide full and accurate product information reflected a gap in knowledge and skill rather than bad faith. Council acknowledged that the respondent had shared illustrations and provided a basic overview of term insurance, and that the supervisor had not flagged suitability concerns. It nonetheless concluded that "a prudent and competent agent would not have proceeded to recommend universal life insurance in these circumstances."

On the documentation front, Council noted that, had proper records of communications been maintained, the dispute over whether the applications were final or a pre-approval would likely have been resolved. Council was direct on the broader principle: "ignorance or a lack of sufficient knowledge about an insurance product is not an excuse to provide clients with subpar insurance advice."

The sanctions

That distinction shaped the sanctions directly. Because the respondent had not acted dishonestly and had cooperated with the investigation, Council did not apply precedents reserved for deliberate misrepresentation or repeated misconduct.

Reflecting its finding of competency failures without dishonest intent, Council imposed the following sanctions:

- A fine of $1,000, payable by December 14, 2026;
- Completion of five specified courses by December 14, 2026;
- Investigation costs of $2,100, payable by December 14, 2026;
- A condition on the licence that failure to comply will result in automatic suspension and an inability to complete the 2028 annual renewal.

The sanctions on the second and third counts are combined with those imposed under the first. The British Columbia Financial Services Authority retains a right of appeal to the Financial Services Tribunal within 30 days of the decision taking effect.