In the submission that it has just made to the consultation on the Report on the Application of the Act respecting the distribution of financial products and services (ARDFPS), the Canadian Life and Health Insurance Association (CLHIA) is asking Quebec’s Ministry of Finance to include distribution without a representative under Quebec’s Act Respecting Insurance rather than under the ARDFPS. The CLHIA would also like Internet sales to be regulated under this law.

“We are asking the Minister to transfer the framework of distribution without representative from the ARDFPS to the Act Respecting Insurance. As for sales by Internet, this is already possible under the Act Respecting Insurance and should continue to be regulated under this law,” Claude Di Stasio, the CLHIA’s Vice President- Quebec Affairs, told The Insurance and Investment Journal in an interview. In her view, insurance company practices should not come under the ARDFPS.

The need to lighten the regulatory burden and avoid duplication between regulatory organizations are also at the heart of the CLHIA’s concerns. “For example, the number of licences should be reduced. One overall licence would be sufficient,” says Di Stasio. The CLHIA’s submission does not call into question the existence of the Chambre de la sécurité financière (Quebec’s life insurance agents’ self regulatory organization). However, it does ask for a clarification of the mandates and missions of each regulatory organization to eliminate duplication, added Di Stasio.

The CLHIA also warned against the duplication in the area of indemnity funds. “We agree with protecting consumers but not with a system that is burdensome and has duplications, explained Di Stasio. The goal of the indemnity funds is not to cover everything and always up to 100%. There should be cappings.”