Canadian Council of Insurance Regulators and Canadian Insurance Services Regulatory Organizations announce Fintech/Insurtech Advisory Hub

On May 7, 2020, the Canadian Council of Insurance Regulators (CCIR) and the Canadian Insurance Services Regulatory Organizations (CISRO) announced the launch of the CCIR-CISRO Fintech/Insurtech Advisory Hub (Advisory Hub).

The purpose of the Advisory Hub is to allow interested entities to seek and obtain clarification on what would be required to operate or provide their innovative insurance products or services in Canadian jurisdictions.  This means the Advisory Hub will:

  • increase regulatory visibility to Fintechs and other businesses wishing to develop innovative products and services;
  • provide a common access point for all jurisdictions, giving ease of access to all regulators for Fintechs and other businesses; and
  • allow businesses to get clarification and direction about the insurance sector and regulations, prior to launching their products and services in individual jurisdictions.

The Advisory Hub is intended to address businesses which may be subject to insurance legislation and regulations, including concepts such as digital platforms that connect consumers with firms that insure risks; technology and/or data-driven insurance activities or advice, including online advice that leads to the purchase of an insurance policy; or consumer insurance risk-sharing networks and organizations, and the platforms that support them.

Entities can use the Advisory Hub to engage with Canadian regulators and obtain the information they need to get started.  To do so the inquiring entity will need to provide:

  • List of jurisdiction(s) it would like to conduct business in;
  • High-level overview of the proposed innovative insurance product, service or technology; and
  • Whether it is registered/licensed to conduct insurance business in any jurisdictions (within or outside of Canada).

The Advisory Hub will connect the entity with the appropriate regulators so it may begin receiving direct guidance on Canadian registration/licensing and regulatory requirements. However, the Advisory Hub will not offer pre-market testing, exemptive relief from regulatory/licensing requirements, financial support, or binding advice. This is an important distinction from the Canadian Securities Administrators regulatory sandbox, which allows innovative Fintech businesses to be granted relief from certain securities law regulatory requirements to permit them to test their products and services throughout the Canadian market.  (See our blog post on the regulatory sandbox here)  In essence, the Advisory Hub will serve as an information portal and guide directing the entity to the appropriate regulators after which it can chart its own course.

Takeaway

The Advisory Hub is an important development for actors in the Fintech/Insurtech sectors who are interested in the Canadian market. However, we note that the Advisory Hub is an information portal and does not reflect an attempt by insurance regulators to harmonize legislation, especially provincial legislation governing the distribution of insurance products and services. Entities wishing to consult the Advisory Hub may be interested in engaging counsel to assist with framing questions or structuring submissions to regulators and the Advisory Hub, obtaining independent advice, and structuring their business operations, as well as in navigating and interpreting any guidance received.

For more information about our firm’s insurance and Fintech expertise, please see our  Insurance & Reinsurance group’s page and our Fintech group’s page.

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