The Financial Services Regulatory Authority of Ontario (FSRA) has continued work in a case started by its predecessor organization, the Financial Services Commission of Ontario (FSCO) back in 2017 over allegations that John Willoughby made use of pre-signed forms and extensively altered client forms using different methods. 

FSRA found Willoughby to be unsuitable to be licensed, ruling on an application made by Willoughby just two months before the new regulator assumed FSCO’s responsibilities. Willoughby withdrew his request for a hearing in the first half of 2022.

Licensed in Ontario since 1994 until he was terminated in 2016. FSCO received a life agent reporting form (LARF) from Sun Life Financial saying the firm had identified pre-signed blank forms, altered forms where the representative used whiteout and wrote over top of earlier entries, and instances where client signatures were cut from one form and taped to another. Sun Life’s LARF initially included evidence from 18 client files. On review of close to eighty client files, Sun Life discovered issues in 26 client files. These included forms that were added after clients had already signed their documentation, and forms that were reused multiple times by altering the dates and other information.

When asked for an explanation, Willoughby’s responses to the regulator included that the issue had not been brought to his attention before and he did not think he was responsible for the irregularities in the documentation.

“Based on the investigation conducted, the superintendent concluded that the irregularities in the documents were significant and concerning and that Mr. Willoughby was responsible for the irregularities,” FSCO’s notice states. “In the superintendent’s opinion, Mr. Willoughby’s actions put his clients and the public at risk.”