If we do not fix the current fundamentals, would adding more guidelines, rules and regulations onto brokers and agents bring us a better insurance industry, and also for consumers?
People have been talking about change, disruption and transformation of insurance business and the industry. These are just like “scratching the itchy leg from outside the leather boot”! (隔靴搔癢) I think, what the industry needs is a long-overdue revolution!

Also attention: xxxxx xxxxxxxx, Chief Executive Officer, and xxxx xxx xxxxxx, Investigations, Professional Conduct

Dear Sirs,

The old xxxxxxx communication per https://www.insurancecouncilofbc.com/news/articles/2021/june/cisro-principles/ on "Canadian Regulators Seek Input to New Conduct Principles for Intermediaries", and similar related motions from your office, refer.

The xxxxxxxxx xxxxxxx xx xxxx as an insurance regulator and as part of the Canadian insurance establishment want to enhance and make additional rules and guidelines for governing insurance licencees they directly regulate, with the purpose of demanding "more integrity" and perhaps also more "competence" from them, so to speak, aiming for fair treatment of the insurance public and customers!

However, the fact of the matter is, insurance brokers and agents (intermediaries) can only act and behave within what they are allowed to do or not allowed to do by their principals, that means insurers and insurance providers, in procuring and doing their business, not counting also as a result of competitions and influences from fellow market "peers", and also other market competition forces and stakeholders, maybe even from nowhere and unknown sometimes, yet rather than leading and controlling adequately the said "all others" so involved, simultaneously and more directly, the approach seems to be just adding even more and new regulatory controls on us brokers and agents (intermediaries) instead!

Don't you think there are enough rules and regulations and guidelines in place already, so much so that, if absolute and full compliance of them to the letter, not to speak of their execution that are always only subject to interpretation and discretion by your office anyway, and that, together, will end up with no smooth and proper doing of insurance business can actually be carried out or done at all, and might even add and become even more detriments to the insurance public and consumers you say you want to protect?! Practically, we (brokers and agents), and often the consumers too, are actually being put between a rock and a hard place instead!

I have been collecting observations to substantiate my above observations since the above communication from your office was received, and even before that!

The situation is getting more harsh and severe, in face of the current insurance market and industry organization by which brokers and agents, on behalf of and together with their customers, are being treated almost as an eternal and immortal cash cow or milking cow for the already deformed and sometimes merciless investment industry, on national and international basis, as they "invest" in the insurance industry, and not merely from just the principals! They all want to see profits and more profits, and also beyond profits! They constantly and insatiably want more investment and equity returns (money), but definitely not more risks and more claims arising from the business they do !

The first immediate phenomenon or development is, as always, the xxxxxxxxx xxxxxxx xx xxxx just works on and regulates us, the brokers and agents, to complement and fully coordinate in such purposes! And very rarely could we or would we complain against anybody or can do anything about it, irrespective of all the unreasoning and unreasonableness as manifested, and maybe even shenanigans, seen or unseen, applied and even just implied! We have to be licensed by your office anyway, after all !

We cannot discount some peers’ unacceptable and unprofessional behaviors, but in fact who and what made them, or how they are being made and even allowed to act and behave as such in the first place? If nobody complains, everything seems fine, and all is just swept under the carpets, as if nothing happens!

At the end, we brokers and agents, at the bottom end and last mile of the insurance food chain, actually have no legislative or executive power to protect ourselves whatsoever, but have to just bear it all, like a scapegoat, or simply just have to give up, or get out of business, irrespective of the actual facts and truths, as described and as happened, and simply have to swallow all the blames and consequences as put onto us, by way of and through all and even more rules and regulations and guidelines made, all in the name of "for the benefits of consumer public", but who generally don't really even know what is going on, even when and if something happens! Just wonder, did the brokers, especially those big brokers, local and international, ever say anything? Definitely not. Except only when their "interests" are being jeopardized or concerned! It won’t even happen, because their "interests" are usually always well considered first, and juggled prior to any "action" or anything, anyway! They are the dominant market competition forces in all markets, and not just the xxxx market or the Canadian market! Who made and allowed such to happen?

With the unreasonable and questionable abundancy of inadequately trained or educated insurance practitioners becoming insurers and intermediaries, both inexperienced and sometimes also irresponsible, as produced by the xxxxxxxxx xxxxxxxxx xx xxxxxx, and other agencies and institutions relating thereto, flooding the industry in running the said same old multi-twisted traditional insurance business model and system, in selling products which often they don't even know what they are selling, and to deliver to buyers (consumer public) who also don't know what they are buying either, but only being forced to, mandated to or influenced to buy, so what will be the compounding outcomes and end results of all these? On top of the fact that all those insurance "product", both policies and wordings, are all "legally and purposely" "well designed" fine print, approved and permitted! So, would more rules, regulations and guidelines being added onto brokers and agents (intermediaries) "tie things together" and fix the situation, if not actually just worsen the situation and the market further? Is that how insurance business and the industry supposed to and intended to work?

Who actually are being covered and protected here? It can only blind all stakeholders from the true objective of insurance and insurance business! Of course, not if the actual end game of insurance business is in fact to take no risk and to pay no claim! All just relying on consumers’ inelasticity to buy, as created, in dealing with their risks and risk requirements, often also created! And as a consequence, actually making buying insurance become the biggest risk of all! Ends up just making the whole set up become a global involuntary and unfair subsidizing game in name of insurance business! It all boils down to, people just want more money, but don’t want risks or claims, or maybe don’t even want to work and money will come! So intermediaries, brokers and agents, at the last mile are responsible and to bear it all? By way of all the rules, regulations, and guidelines, and add even more, when and if needed? Has anybody ever considered the consequences thereof when people (the insurance public and consumers) simply see, learn, copy and do the same? What will happen? Proofs and Evidence are already everywhere and in all sectors and segments of the society!

I have come across numerous examples of unreasonableness and unreasoning in this industry, often very weird and treacherous, such as those "Letter of Brokerage" procedures and related games, in "soliciting" business or "competing" for business, frequent inconsistencies, and many phenomena, like those "computer related" matters, like automatic "inflation factors", and even like the "guaranteed replacement calculations", with formula and computer based, and all the frequent change in wordings and fine print ……………, all as a result of the current old traditional and already twisted Insurance Business Model itself, also with its internal and external cultures so formed and adapted, by which your office is part of its organization and set up, as designed! Actually I can even use my own case involving the xxxxxxx 20 years ago as an example to prove: xxxxxxxxxx xxxx xxxxxxxxx xx xxxxxx-x/xxxxxxx (xxxxxxxxx xxx xxxxxx, xxx xxxxxxxxx xxxxxxx xx xxxxxx, xxx xxxxxx xxxxxx, xxxxxxxxx xxxxxxxx xx xxx xxxxxxx, xxx xxxxxx, xx xxx xxxx)!

Although it has been such a long time and I have no intention to revisit the case, yet what happened was, 4 years ago x xxxx x xxxxxx xxxxxxx xx xxxx xxxx, xxx xx xxxxxxxxxxxx xxxx xxxxxxx xxxxxxx xx xxx xxxxx xxx xxxxxxx x xxxx xxx, xx xx xxxxxxxx, xxxxxxxx xxxxx xx xxxxx xxx xxxxx xxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxx xxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxx

To cut the story short, in my case, I was "reprimanded", as recorded, for having not reported to the company management of xxxxxxxxx xxxxxxx on what their senior underwriter did while the abnormal incident was in fact proximately due to her reluctance, delay, laziness or even unwillingness to work on the file in question, and perhaps because of some kind of her inability at the time, or for whatever reason(s) unknown to me, yet instead it was decided by your xxxxxxx and its peer members who sat on my case, as it happened and decided, that it was proximately and wholly due to my not reporting the incident, which while if it were reported, its consequence would have become my difficulties in continuing and placing of business, that means no more business for me further! And so it would all just come back onto me anyway! In reality, simply end up going out of business or being forced out of business! So, what those rules and regulations and guidelines are for? What could it achieve when the real proximate cause was simply sidelined and ignored, and all put onto me as the broker to be reprimanded and fined instead? That cost me my business reputation and credibility! Even up to this point. And all due to people’s ignorance and schadenfreude! I don't even want to identify and mention all those hidden instigators and collaborators who initiated the case against my company and me! Nothing I want to say further, except that the experience on the investigation enhanced my relentless perseverance to go against "the tide" of all the unreasonableness, unfairness, unreasoning, and shenanigans I saw happened but should not even have happened on my case and in this industry!

Based on my circumstances at the time, I did not put up a fight, because, despite all, I minded about the underwriter's job and career, and also my employees and my company! I even begged for leniency (xx xxxxxx xxxxxx) from the pressure of the investigation just because of that! And because of the incident, including the investigation, as a result, I have many difficult situations and unusual consequences I had to deal with thereafter, including even up to now, including……………, and as far as from xxxx xxxx!

So, what are the actual real motives, principles and business philosophy from those who made all the rules and regulations and guidelines in the first place? What is the proximate cause of all these? Really to protect the insurance public and consumers? A better intermediary (brokers and agents) group? Or actually to distract attention, to point finger, and to cover tail? Probably nobody cares anyway! In a way, just don’t mind, don’t care, and don’t know, for that matter! While people are suffering, including consumer public, who are supposed to be protected! Just think of the insurance market on condos, apartment units and buildings nowadays, and also weeding out of competitions and markets availability and supplies so as to make "things" happen, which could all explain! Can these be sustained forever? I don’t even want to mention the multi layers of additional taxes relating and arising therefrom! Whose benefits are being deprived, and also gouged? And whose interests and benefits are being protected actually? Perhaps, we really need to smoke some high grade legal Canadian Cannabis to quiet, distract and fog up our minds!

Frankly, hope something can be done before Canada reduces itself to become a Third World country! Proximately, all because of its insurance system and wrong organizational setup, as a whole, that no one seems to care or dare to change!

People have been talking about change, disruption and transformation of insurance business and the industry. These are just like "scratching the itchy leg from outside the leather boot"! (隔靴搔癢) I think, what the industry needs is a long-overdue revolution! Not more rules, guidelines and regulations, and compounding!

Thanks for your kind attention and consideration.