After a sophisticated scheme, wherein agents submitted false applications to generate significant commissions was uncovered and reported by Foresters, the Financial Services Regulatory Authority of Ontario (FSRA) announced it has revoked insurance licenses from Daumier Financial Services Inc., and its contracted agents: Carmen Munoz Gutierrez, Ana Huang Yu, Andres Antoinio Hernandez Silva, Maylin Rodriguez Perez and Michael Lue. It also declined to issue a license to an Ontario numbered company in the case.

In May 2023 FSRA received a life agent misconduct report from Foresters detailing a scheme where the agents submitted applications for policies containing false information for individuals who did not exist. “Between June and September 2022 the Foresters life agent misconduct report (LAMR) agents submitted approximately 237 policy applications for two different companies,” they write, “asserting that the respective owners of the companies sought individual insurance policies for their employees.” The LAMR also stated the agents attempted the same scheme for a third company before being shut down by the insurer.

Once the policy applications were submitted and up-front commissions received, the firm would direct some of the commissions to a bank account funding the premiums payments to maintain the scheme. Foresters paid out more than $750,000 in upfront commissions for the 237 policies.

Agents set up fake domains 

Another LAMR indicated that the agents were engaged in an even larger scheme against Specialty Life Insurance Inc. (SLI). As of August 2023, SLI had more than 4,500 active policies placed by the firm and its agents. “SLI paid Daumier Financial and the SLI LAMR agents $63,175,697.30,” the notice of proposal in the case states. In the SLI scheme, the agents also set up fake domains that appeared similar to the real domains of legitimate businesses.

“FSRA received spreadsheets outlining the policies from SLI and from Foresters. There is a significant overlap of purported employees on both lists,” the notice of proposal continues. “It is clear from the materials that Daumier Financial, Munoz Gutierrez, Huang Yu, Hernandez Silva, Rodriguez Perez, and Lue (the Daumier agents) have repeatedly provided false or misleading representations in the registration of insurance,” the notice concludes.

“The extent of the false information is serious. The Daumier agents submitted nearly 5,000 false applications to two insurers and Munoz Gutierrez and Hernandez Silva provided false information regarding the companies who those applications were purportedly submitted for. Additionally, by funneling funds to pay premiums, the Daumier agents avoided detection of the scheme to continue to generate commissions from Foresters and SLI.”