The Discipline Committee of Quebec’s Chambre de l’assurance has sanctioned representative Denis Lemieux (certificate No. 121131) with a 12-month temporary suspension and a $5,000 fine.

In August 2025, the respondent was found guilty on five of the six counts in the disciplinary complaint. The sanction hearing was held on December 2, 2025. The decision was rendered in French on May 27.

The finding of guilt spanned 224 paragraphs and 48 pages, as the hearing required testimony from several witnesses. The sanction decision contains 115 paragraphs. Because the parties proposed sanctions that were “diametrically opposed,” the Discipline Committee was required to conduct a more detailed review of the case law submitted.

During the period covered by the allegations in the complaint, the respondent held a certificate in accident and sickness insurance, first as an independent representative and later as a representative of a financial services firm. Most of his clientele consisted of seniors living in assisted-living residences.

Four violations were sanctioned by temporary suspensions. The suspension periods will be served concurrently. The committee also ordered the respondent to pay costs and the expenses associated with publishing the disciplinary notice.

Regarding those costs, counsel for the respondent argued that he should be required to pay only five-sixths of the expenses, given that he was acquitted on Count 5. The committee rejected that argument, noting that the documentary evidence related to that count was straightforward and did not require witness testimony, unlike Counts 1 through 4, which occupied most of the hearing on the merits.

Risk of reoffending

The respondent is 63 years old and has 33 years of experience. He has no disciplinary record, but the syndic of the Chambre de la sécurité financière (CSF) imposed administrative measures on him in 2007, 2009, 2013 and 2016.

Given the significant gap between the parties’ recommendations on sanction, the committee took into account the vulnerability of the first two consumers referred to in Counts 1 through 5 and also considered the fact that both were met by the respondent in their homes.

The complainant pointed to several factors supporting the proposed sanctions, including the four administrative notices concerning issues similar to the misconduct alleged in the complaint. Counsel for the assistant syndic emphasized the repetitive nature of the violations and argued that the respondent presents a very high risk of reoffending.

For his part, counsel for the respondent argued that the administrative notices are old, contain no details regarding the alleged conduct and do not constitute disciplinary antecedents.

Counsel also noted that Lemieux changed firms and is no longer an independent representative, that he has modified his practice and has expressed remorse. In his view, given the steps taken to change the way he works, the risk of reoffending is not high.

The second client

The most severe sanction relates to Counts 2 and 4, which involve misconduct concerning the second client identified in the complaint.

The Discipline Committee imposed a 12-month temporary suspension. The respondent had the client, who has an intellectual disability, sign two insurance applications. The client stated that she had no recollection of the circumstances that led her to sign the contracts and added that she did not understand what an insurance contract is.

The committee found that he failed to act with integrity by having this consumer sign two insurance applications. A first contract was issued in January 2019, and another was purchased from a different insurer in September 2019.

For Counts 2 and 4, the complainant recommended a suspension of between two and five years, along with a $5,000 fine on Count 4. Counsel for the respondent argued that a three-month temporary suspension would be appropriate.

The committee concluded that a 12-month temporary suspension is an appropriate and individualized sanction for Counts 2 and 4. Imposing a fine on Count 4 as proposed by the complainant would be “needlessly punitive,” it added.

Incomplete needs analysis

For the misconduct alleged under Count 3, the committee imposed a one-month temporary suspension. The respondent failed to conduct a complete and compliant financial needs analysis when the second contract was purchased in September 2019.

The committee adopted the sanction proposed by the complainant for this count. Counsel for the respondent had instead suggested a $5,000 fine. The committee noted that the first administrative notice received by the respondent in 2009 concerned the importance of preparing a complete and compliant financial needs analysis before submitting an insurance application for a client.

The committee found that the respondent should not have conducted the financial needs analysis without the presence of trusted individuals who usually assisted the client with her financial decisions.

The first client

The committee imposed a four-month temporary suspension for the violations upheld under Count 1 of the complaint.

“The representative’s conduct must be characterized by dignity, discretion, objectivity and moderation,” the committee stated in its finding of guilt.

In April 2016, the respondent arranged for a consumer to purchase a life insurance policy even though she was receiving social assistance and struggling to make ends meet.

One year later, the client’s daughter succeeded in convincing her mother to cancel the policy because “the coverage is in no way necessary.” In May 2017, the client wrote to the insurer requesting that the contract be cancelled.

In February 2019, the respondent visited the client and arranged for her to purchase a policy similar to the one issued in April 2016. That second contract was cancelled a few months later.

A representative “worthy of the profession would not have attempted once again to have an elderly person, who relied heavily on her daughter for financial matters, purchase an insurance contract,” the committee wrote regarding the issuance of the second policy.

For this first count, counsel for the respondent suggested a one-month temporary suspension, while the complainant proposed a suspension of between two and five years along with a $5,000 fine. The committee found both recommendations inappropriate.

Replacement notice

The $5,000 fine was imposed for the violation alleged under Count 6. The respondent failed to provide complete replacement notices when having four clients sign new insurance applications. For three of those clients, the complainant alleged that the respondent prepared only one replacement notice even though two policies were being cancelled.

The committee granted the respondent 12 months to pay the fine, as well as the costs and expenses related to the publication of the suspension notice.

For Count 6, the complainant proposed a two-month temporary suspension, while counsel for the respondent suggested a $3,000 fine.

The committee noted that, in the case of the clients concerned by this count, it was the clients themselves who approached the respondent to change their insurance policies.