The Insurance Council of British Columbia has taken disciplinary action against Rajdeep Kaur Nagra (licence no. LIC-172041C107184R1), a life and accident and sickness insurance agent, following an investigation that revealed a years-long pattern of failures she struggled to explain — or even acknowledge.

The respondent has held a life and accident and sickness insurance licence since January 2008. At the centre of the Council's decision, rendered on September 24, 2026, is the regulatory complexity that comes with holding two distinct authorized trading relationships simultaneously. The respondent held both an affiliated authority to represent (ATR) under which her affiliated agency managed her errors and omissions (E&O) coverage, and an unaffiliated ATR, which required her to maintain personal E&O coverage independently. The investigation was triggered when the Council received a list of lapsed E&O policies indicating the respondent's coverage had been cancelled on March 30, 2023. Throughout the investigation, the respondent was evasive and persistently failed to respond to Council staff inquiries. Her affiliated agency terminated her on April 5, 2025, citing her lack of cooperation with the Council. The respondent stated she was unaware of the implications of holding an unaffiliated ATR and believed her agency managed all her E&O coverage, attributing some periods of non-compliance to personal circumstances.

Years of non-compliance uncovered

Against this regulatory backdrop, the audit of her E&O policies and broader investigation revealed a cumulative pattern of non-compliance across seven counts. On the continuing education (CE) front, the respondent failed to meet CE requirements for three consecutive licence periods (2021/2022, 2022/2023, and 2023/2024), accumulating a total shortfall of 36 credits. The respondent stated that a computer crash resulted in the loss of her CE records, and that she subsequently made up the 36 outstanding credits outside the audit period.

The E&O breaches were more extensive. The respondent failed to maintain required E&O insurance for her unaffiliated ATR across two distinct periods, resulting in a combined total of 845 days without coverage. During the first of those lapses, in 2017, she conducted three insurance transactions (one segregated fund and two life insurance policies) without the required E&O coverage for her unaffiliated ATR, exposing three clients to potential risk. The respondent also failed to notify the Council of the E&O lapses within the five-business-day window required by Council Rule 7(11).

False declarations and misleading statements

Beyond the coverage and notification failures, the respondent made material misdeclarations on her annual renewal forms regarding CE completion for the three licence periods and E&O coverage for the 2022/2023 period. More serious still, the investigation uncovered a breach of integrity that went beyond coverage gaps. The respondent told the Council's investigator that she had not conducted any insurance transactions during the periods without E&O coverage, a statement directly contradicted by evidence from two insurers. She also failed to respond to the Council's inquiries in a timely manner on multiple occasions during the investigation. The respondent acknowledged that CE compliance and adherence to the Code of Conduct were her personal responsibility.

Aggravating factors outweigh mitigating circumstances

Faced with this accumulation of breaches, the Council weighed the appropriate sanction and identified four aggravating factors:

- the respondent's experience in the insurance industry;
- the repeated nature of the breaches across multiple licence periods;
- her evasiveness during the investigation; and
- her misdeclarations on renewal forms and to the Council's investigator.

Against these, the Council acknowledged mitigating factors: personal circumstances during the periods of CE non-compliance, the fact that the E&O lapse for the unaffiliated ATR was not deliberate, and the respondent's completion of the 36 outstanding CE credits outside the audit period. The Council found that the aggravating factors outweighed the mitigating ones.

The Council reviewed several precedents, which indicated fine ranges of $1,500 to $2,000 for E&O breaches and $500 to $1,000 per licence period for CE breaches. The Council treated these precedents as instructive rather than binding and selected a midpoint of $750 per CE period to reflect the weight it placed on the aggravating factors. None of the precedent cases had included a supervision condition; the Council determined that a two-year supervision requirement was warranted here to help guide the respondent's practice going forward. The Council expressed concern over her inability to differentiate between her affiliated and unaffiliated ATRs, over her capacity to practise competently in line with usual insurance practice, and over the risk that her unresponsiveness toward the regulator could affect her handling of client inquiries. The Council also acknowledged a potential for harm to clients with respect to the policies written during periods when the respondent did not hold the required E&O coverage.

Fine, mandatory training and supervision

The sanction imposed reflects all these considerations. The respondent is required to pay a total fine of $4,750: $2,250 for three periods of deficient CE credits and $2,500 for E&O-related breaches, covering the lapses, the transactions conducted without coverage, and the failure to notify. The fine is payable by January 22, 2027. Investigation costs of $2,000 are payable by December 23, 2026. The respondent must complete specified professional development courses by December 23, 2026, and is subject to a two-year supervision by an approved Life Agent, applicable during active licensing. Her licence now carries a condition triggering automatic suspension if she fails to comply with any term of the sanction.