The Insurance Council of British Columbia (ICoBC) has sanctioned Pamela Tan Gervacio after the former life agent admitted to being exceptionally motivated by the commissions and competitions set out by her agency, in a case that focused on the suitability of policies she sold to her clients.
In at least one case, her supervisor took issue with the suitability of a policy Gervacio sold to her husband, while the insurer’s sales director also warned her that selling the policy could cost Gervacio her career.
The allegations against Gervacio also include that she recommended policies to clients that did not align with their needs and circumstances, as many had high premium-to-income ratios that resulted in numerous cancellations and lapses.
An audit of Gervacio’s files showed that she failed to retain notes to support her rationale for recommendations and made calculation errors when preparing financial needs analysis for clients.
Numerous concerns identified
“Given the numerous concerns council identified with the four audited policies, it is likely that similar issues exist within the other policies sold, indicating a broader pattern of the former licensee’s substandard practices,” the intended decision in the case states.
A life and accident and sickness insurance agent licensed periodically since April 2005, Gervacio’s license was cancelled for non-renewal in August 2025. In June 2023, she received a compliance warning letter from her agency for allegations of churning, not completing a life insurance replacement declaration (LIRD) and for failing to act in the client’s best interest. September that year both the insurer and the agency terminated their contracts with Gervacio.
In her husband’s case, the former agent first sold him a policy with a monthly premium of $2,650. Although the intended decision in the case is redacted, it is noted that the annual premium represented a percentage of his annual income, suggesting that such was unsuitable. After the policy lapsed for nonpayment, even after having the premiums reduced, Gervacio sold him a second policy with the same premiums and coverage.
The former licensee’s supervisor concluded that the second policy was unsuitable. Gervacio says the supervisor told her that the policy would be acceptable if the insurer’s sales director approved it. “When the former licensee contacted the insurer’s sales director for advice, the insurer’s sales director said, ‘I think if you re-wrote it, it could cost you your career,’” the intended decision states.
When asked why she continued in selling the policy after receiving that warning, she stated that she didn’t understand the statement.
In the council’s intended decision, it is also noted that the vast majority of the policies the former agent sold were universal life policies structured with 100 per cent permanent insurance coverage; 60 per cent of the policies were sold to relatives and friends. The former licensee’s persistency ratio was noted as being below 75 per cent. “Of the 55 policies she had sold, 24 had lapsed, been cancelled or were terminated. Of those 24 policies, seven had lapsed with premium-to-income ratios ranging from four per cent to 34 per cent and 11 of the 16 policies that were terminated had premium-to-income ratios ranging between 12 per cent and 53 per cent,” they write.
Gervacio claims that her clients had incomes from other countries but that she was instructed to omit the foreign income in their applications. She also admitted to attempting to recruit these clients to the industry, suggesting the alternative income stream could help them to pay their premiums.
In addition to a $2,000 fine, the council also ordered Gervacio to pay costs in the amount of $3,375, ordered her to complete six remedial courses and refused to consider an application for licensure for a period of two years. If she receives a license again in the future, Gervacio must be supervised for two years.
