The discipline committee of the Registered Insurance Brokers of Ontario (RIBO) has reprimanded PC Financial Insurance Brokers Inc., an Ontario auto insurance brokerage, and ordered it to pay a $50,000 fine for professional misconduct. The brokerage used postal-area filters in auto insurance quotes from 2014 to April 12, 2022, contrary to the Take-All-Comers rule.

The decision was rendered on October 22, 2026.

Postal-area filters kept some consumers out of auto insurance quotes

The central finding is that PC Financial Insurance Brokers Inc. used filters based on forward sortation areas (FSAs), the first segment of a postal code, to exclude consumers in certain geographic areas from auto insurance quotes. The practice ran from at least 2014 to April 12, 2022.

The Take-All-Comers rule requires that the lowest available rate from affiliated insurers be provided. It also requires that access to auto insurance not be refused, restricted or differentiated, except in line with underwriting rules filed with and approved by the Financial Services Regulatory Authority of Ontario (FSRA). Auto insurance is mandatory in Ontario.

The brokerage obtained quotes mainly through aggregator websites, where it bought leads, and through a quoting platform run by a third-party provider. The filters were put in place through instructions to the aggregators and through the platform's configuration.

They were sometimes applied because of insurers' concerns, such as loss ratios and the profitability of certain areas. At other times they reflected the brokerage's own considerations, such as lead conversion rates and marketing efficiency.

The filters were not part of the approved underwriting rules filed with FSRA, so some consumers may not have received the lowest rate available.

The brokerage did not directly employ licensed brokers. It had retained an entity controlled by another company to provide brokerage services.

Practices continued after RIBO's 2020 guidance

RIBO issued guidance to principal brokers on February 28, 2020, reminding them of their obligations and the requirements of the Take-All-Comers rule, and FSRA issued additional guidance on November 15, 2021, clarifying how the rule applies. The brokerage did not modify or discontinue its use of the filtering after RIBO's guidance.

The filtering was removed from its internal system around February 28, 2022. It continued to operate on one aggregator website until April 12, 2022.

In about March 2023, RIBO began receiving information from FSRA raising concerns about the filtering practices applied through aggregator sites.

A guilty plea and allegations withdrawn on consent

The hearing dealt with both liability and penalty. The brokerage and its counsel attended, and the parties presented a joint submission on penalty.

The brokerage pleaded guilty to one count of misconduct, based on the Take-All-Comers breach. Both parties jointly submitted that there was sufficient evidence to support a finding of misconduct.

Other allegations of breach were withdrawn on consent. They are therefore not findings of guilt.

The brokerage ceased its brokerage activities in March 2026. It surrendered its brokerage licence effective April 30, 2026.

The committee finds the $50,000 fine proportionate to the length of the misconduct

The committee noted that the number of affected consumers was not quantified. It found that the length of the practice and its potential to restrict access to quotes complying with the Take-All-Comers rule increased the seriousness of the misconduct.

Two aggravating factors were identified: the duration of the practice and the failure to act on RIBO's directive. The committee mentioned the brokerage's lack of prior investigations or disciplinary action by RIBO in more than 16 years, apart from this matter. It did not treat this as a mitigating factor, given the length of the misconduct, and considered it neutral.

The mitigating factors were the guilty plea, full cooperation with the investigation, the admission of the misconduct in the agreed statement of facts, and the resolution by agreement, which avoided a contested hearing.

The committee found the joint submission reasonable and proportionate to the seriousness and duration of the misconduct and to the failure to act after RIBO's 2020 guidance. It described the $50,000 fine as significant without being unduly punitive. The maximum fine for a non-individual member is $100,000.

Because the brokerage has stopped operating and surrendered its licence, the committee gave more weight to general deterrence and public confidence than to rehabilitation and specific deterrence.

In its words, the Take-All-Comers rule "is a significant consumer protection and market conduct requirement in Ontario auto insurance." It added that "general deterrence and maintaining confidence in the regulatory system therefore assume greater significance," and that serious or sustained non-compliance may result in significant disciplinary consequences.

The brokerage must pay the $50,000 fine to the Minister of Finance within 30 days of the order. It also receives a reprimand, and the decision is to be published.