Posted February 26, 2025
RIBO’s Take-All-Comers (TAC) report and the Financial Regulatory Authority of Ontario (FSRA)’s TAC review revealed non-compliant practices involving filters found within third party web-based quoting systems/aggregator to screen out certain customer leads. Such filters can be referred to as Unfair and Deceptive Filters (UD Filters).
RIBO advises all licensees that the use of UD filters in the quoting process is prohibited, whether it originates from a brokerage’s Broker Management System, through a third-party aggregator website, or other means. This is because it results in customers seeing limited or biased results.
A UD Filter is any screening technique that inappropriately treats some customers differently than others. The filter may screen, or sort quote leads based on customer data, including data that is subjective or arbitrary or that bears little or no relationship to the risk.
Some examples of unacceptable actions taken based on such filters for automobile insurance include:
RIBO Spot Checks have been updated to include reviews of filter use. If licensees are found to use UD filters or permit the use of UD filters on their behalf by third-party aggregators, licensees face possible disciplinary action.
Licensees are required to act honestly, fairly and with integrity toward customers.
Licensees should review their use of filters to ensure such usage complies with the Registered Insurance Brokers Act, regulations, by-laws, the Fair Treatment of Customers guidance, as well as applicable sections of the Insurance Act, Compulsory Auto Insurance Act, and applicable FSRA rules including the Take-All-Comers Rule, and other applicable legislation and guidelines.
Licensees are responsible for any outsourced broker services including sales marketing and lead generation, as well as any information provided to customers or leads by the third-party providers.
Specifically, licensees are expected to review all outsourced activities, contracts, agreements, and any relationships with third parties including aggregators, online quoters, and BMS providers to verify that UD filters are not being used. Licensees must also seek written confirmation that UD filters are not being used.
If as a licensee, you become aware of the use of UD filters within a brokerage, you should report it to RIBO. Licensees can submit a complaint to RIBO using the online Complaint Form. You cannot submit complaints anonymously. Please note that RIBO is limited in what actions can be taken if the complaint is reported anonymously.
If an insurer asks for or requires the implementation of a UD filter, licensees must report it to FSRA. Similarly, should you discover that an insurer has engaged in the practice of using UD filters, you should report this to FSRA.
As a reminder, FSRA’s Whistleblower Program allows licensees to report instances of misconduct anonymously. It offers protection from reprisals from these reports. You can also see their Complaints webpage for more information on reporting non-compliance.
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