The Life Insurance Council of Manitoba has found that Westoba Credit Union Ltd. violated licensing rules by selling incidental insurance products without a valid licence for about six and a half years and has imposed a $50,000 fine and assessed $5,000 in investigation costs. The credit union held a Restricted Insurance Agent licence (No. RIA-28541).

The decision was rendered on October 19, 2026.

Its successor entity, formed through an amalgamation, expressly declined a hearing and accepted the terms of the Council's intended decision.

More than six years of unlicensed insurance sales

Westoba Credit Union Ltd., referred to in the decision as the Former Entity, held a Restricted Insurance Agent licence first issued on June 1, 2015. Financial institutions selling incidental insurance in Manitoba must be licensed by the Council.

The licence belongs to the entity but depends on a qualified Designated Official, who must renew annually by May 31. Its Designated Official left on September 5, 2017. The credit union neither notified the Council nor appointed a replacement.

The credit union failed to renew its licence by May 31, 2018. The licence therefore expired and was never renewed. From June 1, 2018, to December 31, 2024, it nonetheless kept selling life, disability, critical illness, loss of employment and creditor protection insurance as part of its retail and business operations.

During that period, it issued approximately 4,594 certificates of insurance and provided members with more than 13,000 individual insurance coverages. Policyholders paid approximately $7.45 million in premiums, and the credit union earned approximately $1.59 million in commissions.

Compliance declarations raise questions

Senior leadership signed attestations and undertakings confirming compliance and stating that unlicensed insurance activity would not be conducted. The chief operating officer signed a standards and acknowledgement document with the insurer on July 31, 2018. The chief executive officer signed an undertaking and agreement on or about December 15, 2020.

The matter came to light after the credit union amalgamated with two other entities on or about January 1, 2025. The new entity's Designated Official disclosed concerns about licensing non-compliance in a letter dated February 26, 2025.

The Council found six violations involving licensing failures, unauthorized insurance sales, unfair or deceptive practices, misrepresentation and questions about the credit union's competence and trustworthiness.

Valid policies do not diminish regulatory violations

The Council held that the licence holder alone is responsible for maintaining a valid licence, ensuring that a Designated Official was in place and maintaining adequate compliance systems. Selling insurance after expiry was unlicensed activity. The attestations of compliance given while unlicensed amounted to misrepresentation or deceit. The Council also found that committing prohibited acts constituted unfair or deceptive practices.

The CEO stated that the Council never contacted him about the lapse. The Council rejected this as an excuse, noting that the licence holder is expected to have systems to monitor its licensing status.

According to the insurer, all policies issued during the unlicensed period remained valid and in force. The Council concluded that this does not mitigate the seriousness of the conduct. In its view, the licensing regime is a fundamental component of consumer protection and regulatory oversight, and operating outside it undermined that regime whether or not individual policies remained valid.

The Council described the conduct as a significant breakdown in internal controls and regulatory compliance. It said the failure was not due to a lack of awareness, but rather a failure to meet clearly established and ongoing obligations.

Fine, investigation costs and future obligations

The Council imposed a $50,000 fine and assessed investigation costs of $5,000. It also ordered the new entity to notify the Council within 15 days of any future changes in its Designated Official. The Council determined that publication of the decision was in the public interest.