The AMF and Bill 141 — Brokerage at risk; consumers aggrieved

September marked the end of the AMF’s consultations regarding the proposed Damage Insurance Brokerage Regulation. Following the numerous articles and memoranda criticizing Bill 141, we consider it important as an independent brokerage firm to also elaborate on our position towards these new regulations, which neglect the consumer’s interest and threaten the future of brokerage in Quebec.

The bill prepared by the AMF wishes to “improve the supervision of the financial sector, the protection of cash deposits and the financial institutions operating regime”. However, several problematics arise under the regulations proposed by the Autorité des marchés financiers concerning the brokerage, including the creation of hybrid agencies and the disclosure of investment percentage.

hybrid agencies

As a matter of fact, the creation of hybrid agencies, in which brokers and agents can now coexist, will only increase consumer confusion. This confusion is due to the fact that, from now on, direct insurers will be able to corner these types of agencies and monopolize the market, narrowing the boundaries between the insurer and the broker. While the initial goal was to better differentiate the respective roles of agents and insurance brokers, the introduction of such entities may confuse the client with what distinguishes the two professions.

investment percentages

Moreover, we believe that to oblige brokers to disclose investment percentages to their clients is not a measure that really defends the interests of the consumer. We support the AMF in its desire to promote the extension role of the damage insurance broker. In fact, consumer skepticism about insurance can only dissolve if, as brokers, we take the time to explain all possible subtleties. However, we do not believe that our investment percentages are relevant information to the client, whether an individual or a business. This addition of information does not lead, in any case, the consumer towards a more informed choice. On the contrary, the client and broker experience would be more burdensome.

Finally, being an independent brokerage firm, objectivity is the very essence of our work to which we attach an utmost importance. We would like to welcome the new regulations supervising the number of quotes for individual brokers. The effort of impartiality must be the mandate of all in the consumer’s first interest so that the latter receives a most complete offer.


In light of that, we desire a reassessment of the proposed measures by the AMF in order to, on one hand, ensure a balance between brokers and, on the other hand, better protect the consumer’s interest, for which we are committed to offering a personalized and impartial service.

If you have any questions about the Bill 141, send us an email.

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