For making false and misleading statements and representations in the solicitation or registration of insurance policies, and for misleading the regulator, the Financial Services Regulatory Authority of Ontario (FSRA) has levied a $5,000 administrative penalty and entered into an agreement with Sandeep Singh Dhaliwal, wherein Dhaliwal agrees that he will not apply for any license required from FSRA for five years.

Specifically, the agent agreed that he fraudulently arranged the purchase of Ivari life insurance policies for four clients. In the first instance he told the client that a universal life insurance policy was a savings account with built in insurance, that he would receive 13 to 14 per cent compound interest on his contributions, that his monthly payments would reduce after three months, and he could withdraw his payments after 12. When the policy lapsed, the client had paid premiums amounting to $1,350 which were never refunded.

That client’s son, known as RM in FSRA’s notice of proposal, was also a friend Dhaliwal recruited to help him get clients. RM was unlicensed. Dhaliwal told him to tell potential clients that they were similarly investing in savings plans.

RM’s cousin was told by RM that the “savings plan” would bear eight to 14 per cent in compound interest over a period of 12 months. Dhaliwal submitted an application for that client’s policy without their knowledge or consent, and without meeting the client in question. Ivari in this case refunded the premium payments.

Dhaliwal also arranged for a universal life policy to be purchased without the knowledge or consent of the person he was in a personal relationship with. In this case, she specifically told the agent that she was not interested in purchasing a life insurance policy. Having access to her phone and purse, he procured her social insurance number and bank account details to complete the application

He similarly submitted an application for his partner’s sister without her knowledge or consent, as well. Premium payments made to support the policies – $1,760 by Dhaliwal’s partner and $600 from her sister before the policies lapsed – were never refunded.

In all cases, Dhaliwal was working as an independent contractor with the World Financial Group Insurance Agency of Canada Inc. That company received commissions for the sales; Dhaliwal’s entitlement was reduced by chargebacks.

Dhaliwal also agreed that he provided false and misleading information in the application process when he falsely represented that the first client had no pending or active applications open with other insurers when he applied to both Equitable Life and Ivari at the same time. He also concealed the fact that the first client already had life insurance coverage in place with another company. 

Ivari eventually terminated Dhaliwal’s contract for cause and sent a Life Agent Reporting Form (LARF) to the regulator.