The General Insurance Council of Manitoba has sanctioned Douglas Boyd Friesen, a Level 3 adjuster and designated representative of an adjusting firm, for failing to verify that an assistant had a valid licence. The Council is imposing a global fine of $300 and partial investigation costs of $500.
The decision was rendered on September 21, 2026.
An assistant worked without a licence after June 30, 2024
The licence of a Level 1 assistant expired on June 30, 2024. While Mr. Friesen did not verify her status, she continued to carry out adjusting work, with her reports reviewed and countersigned by him, until her licence was reinstated.
She was also communicating with insurers and other parties. The firm was paid for this work.
She submitted her licence reinstatement application on September 6, 2024, and it was reinstated on January 21, 2025.
At least 29 claims handled without a licence
According to Mr. Friesen, the assistant handled at least twenty-nine claims between July 1, 2024, and January 20, 2025. Twenty-eight of them involved one insurer, and another involved an agency, neither of which is named. The investigation also identified other claims that were not included in Mr. Friesen's initial statement.
The investigation followed a complaint received by the General Insurance Council of Manitoba on July 19, 2024, alleging that an assistant at the firm was acting as an adjuster without a licence.
On June 21, 2024, in his renewal application, Mr. Friesen had attested that he had reviewed the firm's list of licence holders and understood his obligation to ensure that no unlicensed person acted as an adjuster.
In addition, a notice from the General Insurance Council of Manitoba dated July 2, 2024, reminded designated representatives to verify licence status.
Mr. Friesen waived his hearing and accepted the proposed decision
Three breaches are upheld against Mr. Friesen:
- He failed to ensure that only licensed persons acted as adjusters for the firm.
- He facilitated unlicensed activity by allowing an unlicensed Level 1 assistant to perform adjuster functions.
- He permitted unauthorized practice of the profession to take place under his supervision.
The Council reviewed the investigation evidence at a meeting held on December 17, 2025, and issued a proposed decision. Mr. Friesen expressly waived his right to request a hearing and accepted the terms of that proposed decision.
The Council rules out fraud but finds the departure serious
In the Council's view, a designated representative must take active steps to verify licence status and ensure compliance within the firm. He cannot simply presume that the licences have been renewed.
The Council also rejected the argument that Mr. Friesen's supervision could substitute for the requirement of a valid licence.
The Council nevertheless specifies that it did not find fraud, theft, or intentional deception. The conduct resulted from inadequate oversight and insufficient licence compliance practices, which constitutes a serious departure from the standard expected of a designated representative.
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