In its submission to FSCO on its Draft Statement of Priorities and Strategic Directions, FAIR Canada urges FSCO to adopt a number of reforms to benefit financial consumers.  FSCO’s initiatives include performing a market conduct review of suitability of product recommendations for insurance, working with the Ministry of Finance to review major parts of the Insurance Act; and examining the Canadian Council of Insurance Regulators’ recommendations to reflect changes in distribution channels.  FAIR Canada advocates a new model of consumer protection where those who sell complex financial products have to ensure that the end consumer actually understands the product being sold and its risks and costs. 

FAIR Canada also recommends that FSCO consider setting out regulatory requirements for product suitability in a fashion similar to IIROC Dealer Member Rules and MFDA Rules in order to improve outcomes, as well as calling on FSCO to issue a consultation paper in 2011 on implementing a best interest of the client standard for all market intermediaries.  FAIR Canada has a number of suggested legislative changes to the Insurance Act and related legislation, including a best interests of the client standard and disclosure to consumers of the amount of compensation and incentives.  FAIR Canada would like to see a specific initiative to further the ways in which FSCO communicates with and is accountable to financial consumers.  One means to do this is through strengthening the Consumer Advisory Committee which FSCO created in 2001 so that it can provide more meaningful and publicly-transparent consumer input.