BrokerExamOn March 26, 2026, a panel of RIBO’s Discipline Committee found former broker Josephine Bourre guilty of misconduct for collecting client premium payments into her personal bank account and issuing false liability slips for coverage that did not exist. The panel accepted her undertaking never to apply for registration with RIBO again and ordered a reprimand. The decision is published on CanLII as Josephine Bourre, 2026 ONRIBODC 6 (CanLII).
What happened
The agreed statement of facts describes conduct that ran for years before it surfaced. Ms. Bourre worked as a broker at BrokerLink in Mount Elgin, Ontario. One client, identified as Client A, had been sending her monthly e-transfers since January 2019 to pay for automobile insurance with Aviva. The transfers went into Ms. Bourre’s personal bank account, and in exchange the client received thirty-day temporary liability slips. In January 2022, Client A contacted Aviva and was told the insurer had no record of her policy. The slips were false, and there was no coverage (paragraphs 11 to 16 of the agreed facts).
Ms. Bourre also admitted to collecting funds from several other clients, depositing the funds into her own account, and issuing false slips without binding coverage, including $1,012.00 collected from one client (paragraph 18 of the agreed facts). BrokerLink’s principal broker complained to RIBO on February 11, 2022, and Ms. Bourre admitted the allegations during the investigation.
Her registration lapsed in October 2022 for non-renewal and non-payment of fees. That did not end the matter. The Discipline Committee retains continuing jurisdiction over former members, and the case proceeded to a hearing with an agreed statement of facts and a guilty plea.
The provisions she breached
The panel found breaches on two fronts, both from O. Reg. 991, the general regulation under the Registered Insurance Brokers Act.
The first is the Code of Conduct in s. 14: integrity in dealings with clients, the public, fellow members and insurers (para. 1), conscientious and diligent service (para. 3), and candour and honesty when advising a client (para. 4).
The second is the trust-money rule in s. 16 (4). Premium money a broker receives is trust money. Under s. 16 (4) paragraph 2, a member must not knowingly fail to make the trust deposit or investment paragraph 1 requires within three banking days after the day the money is received, and under paragraph 4, money held in trust may only be disbursed or withdrawn in accordance with the terms under which it was received. A member who routes a client’s premium into a personal account and never makes the trust deposit fails the paragraph 2 requirement once that window closes. On this site, both provisions are tested in the general practice section.
The penalty, and why there was no fine
The parties filed a joint submission: a reprimand, plus an undertaking never to seek registration with RIBO again. The panel accepted it, and its reasons set out why. The panel called the conduct “one of the most egregious examples of a breach of trust that an insurance broker could perpetrate on their clients” (paragraph [15]) and stated that had the Licensee “not resigned her license”, the conduct would have resulted in revocation (paragraph [16]).
The panel also said it “would have expected to see a substantial fine levied for this conduct” (paragraph [20]). It accepted the fine-free joint submission on mitigating factors that included cooperation with the investigation and her admissions, participation in the hearing, the negotiated agreed facts and joint submission, and the undertaking (paragraph [17]). The other reason is the high bar R. v. Anthony-Cook, 2016 SCC 43 sets for rejecting a joint submission, which the Divisional Court has applied to Ontario discipline tribunals. The undertaking never to reapply, the panel noted, “is akin to an order of revocation” (paragraph [23]).
The panel closed on general deterrence: the public decision “is a reminder to the broker community regarding unacceptable conduct and the associated significant penalties” (paragraph [24]). Ms. Bourre’s registration had lapsed more than three years before the hearing. The Committee heard the case under its continuing jurisdiction, and the undertaking it accepted binds her never to seek registration with RIBO again.