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Financial Services Regulatory Authority of Ontario

IN THE MATTER OF the Insurance Act, R.S.O. 1990, c.I.8, as amended (the “Act”), and in particular section 441;

AND IN THE MATTER OF Greatway Financial Inc. (“Greatway”);

AND IN THE MATTER OF an Order of the Director, Litigation and Enforcement (the “Director”), by delegated authority from the Chief Executive Officer (the “CEO”) of the Financial Services Regulatory Authority of Ontario (“FSRA”);


WHEREAS Greatway is a Managing General Agency licensed as a corporate insurance agency in Ontario (license #34631M);

AND WHEREAS Greatway contracts with life insurance companies and acts as an intermediary between the insurers and licensed life & health insurance agents in Ontario (the “Agents”);

AND WHEREAS Greatway requires each of its Agents, including all new licensees, to complete mandatory training, in connection with the sale of Universal Life insurance, which training FSRA has reviewed (the “Training”);

AND WHEREAS FSRA identified alleged deficiencies and errors in the Training that, in the Director’s opinion, might reasonably be expected to result in breaches of the Act;

AND WHEREAS the Director issued a Notice of Proposal (the “NOP”) dated October 14, 2022, with respect to the Training;

AND WHEREAS Greatway requested in writing that the Financial Services Tribunal hold a hearing regarding the NOP (the “RFH”);

AND WHEREAS Greatway disagrees with some of the allegations in the NOP but wishes to cooperate with FSRA to address the alleged deficiencies in the Training;

AND WHEREAS Greatway has revised its Training in response to the NOP (the “Revised Training”);

AND WHEREAS Greatway provides the life insurance companies to which it submits Universal Life business the opportunity to provide input on the Revised Training, and Greatway considers such input in the development of the Revised Training;

AND WHEREAS the Director has given notice to Greatway of the information it is relying on in making this Order, as required under subsection 441(2)(a) of the Act;

AND WHEREAS Greatway consents to the making of this Order, will withdraw its RFH within two days of the making of this Order, and waives its right to appeal this Order to the Financial Services Tribunal (pursuant to subsection 441(10) of the Act);


  1. Greatway shall direct all its Agents to return or destroy all copies of the Training, or any part thereof, that may be in the possession of such person, and shall request that all of its Agents confirm that they have done so within 30 days of the Greatway direction;

  2. Greatway shall, by no later than January 31, 2023, have made the Revised Training available to its Agents, either in person or on the Greatway advisor training portal which Revised Training shall include modules, quizzes, and additional supports (such as phone and email support for its Agents), as are appropriate;

  3. Greatway shall inform each of its Agents that they must complete the Revised Training by no later than March 31, 2023;

  4. Greatway shall suspend any Agent who has not confirmed that they have returned or destroyed the Training, as required under paragraph 1, or who has not completed the Revised Training, as required under paragraph 3, such that any such Agent cannot submit new business through Greatway until they have completed the Revised Training and/or confirmed return or deletion of the Training, or any part thereof, as applicable;

  5. Greatway shall, by January 31, 2023, mail to Ontario holders of Universal Life policies sold by an Agent and in force on the date of this Order, a letter setting out appropriate information to inform and assist them in assessing the nature of the Universal Life policy and the Insured Retirement Plan strategy and the appropriateness of it for their circumstances (the “Letter”);

  6. After mailing of the Letter, should an Ontario holder of a Universal Life policy sold by an Agent express a concern about their policy to Greatway, to the extent Greatway cannot resolve the concern, Greatway shall facilitate communication about the concern between the policyholder and the appropriate insurance company and, as appropriate, support the policyholder in the resolution of their concerns, including any contractual or equitable remedies;

  7. Greatway shall retain an external consultant (the “Consultant”), approved in advance by the Director, who shall confirm in writing that the Consultant is reasonably satisfied that:

    1. The Revised Training, to the extent that it is followed and adhered to, cannot reasonably be expected to result in an unfair or deceptive act or practice, as contemplated by subsection 2(1) of the UDAP Rule;

    2. The Revised Training is available to Agents in such a way, and with such supports and resources in place, that it is reasonably likely to be followed and adhered to by Agents;

    3. Greatway has conducted the activities required of it under paragraphs 1, 2, 3, and 5 of this Order; and

    4. Greatway has implemented, by no later than January 31, 2023, the measures described in paragraph 9, for consumers who purchased new Universal Life policies after such implementation date;

  8. Greatway will not allow a new Ontario agent, being an agent not licensed and under contract with Greatway as of the date of this Order (a “New Agent”), to place business or recruit and contract other Ontario agents until the New Agent has completed the Revised Training and the Consultant has provided the confirmation specified in paragraphs 7(i) and (ii) of this Order;

  9. Until March 31, 2023, Greatway shall take additional measures that are reasonably designed to ensure that consumers who purchase Universal Life policies in Ontario are provided with information and advice that is appropriate and accurate regarding the terms, benefits or advantages of Universal Life policies.

DATED at Toronto, this 16 day of December, 2022.

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

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