BrokerExamNeither property on the policy carried a water damage coverage endorsement, and the couple who owned them were under the impression that water damage was covered. Their broker, William Derek Galloway of Urbshott-Galloway Insurance Brokers, never raised it with them. Aviva denied the water damage claim they filed on one of the properties in July 2024, because there was no such coverage. On June 25, 2026, on his guilty plea and an agreed statement of facts, a panel of the Discipline Committee of the Registered Insurance Brokers of Ontario (RIBO) found him guilty of misconduct and ordered a reprimand, a $2,000 fine and three hours of education on client communication. The decision is published on CanLII as William Derek Galloway, 2026 ONRIBODC 11 (CanLII).
The file
The agreed facts record that Mr. Galloway was registered with RIBO in or around March 1990 and that his licence status was Level 1 (agreed facts, paragraphs 1 and 2). At inception the policy, with Aviva, was in the wife’s name and covered one property, with no water damage coverage. In September 2023 he was told the couple were moving, needed a tenant’s policy for their new address and would rent out the original one (agreed facts, paragraphs 5 and 7). He made the changes effective October 1, 2023. His notes recorded that sewer backup coverage was not available because the property was in a high-risk area. He did not tell the clients, and he did not approach other markets for terms that might have included it (agreed facts, paragraph 9).
The clients produced nothing showing that they had specifically asked for water damage coverage (agreed facts, paragraph 5). He relied on them to ask about the coverages they needed, including the missing water cover, and did not offer it or point out that it was missing (agreed facts, paragraph 8). The claim was filed on July 16, 2024 and denied, and the husband complained to RIBO on August 16, 2024 (agreed facts, paragraphs 3 and 6). Afterwards, Mr. Galloway acknowledged to RIBO’s Complaints Officer that he should have been more up front in his communications (agreed facts, paragraph 10).
The provision he breached
The joint notice of hearing, dated June 23, 2026, alleged misconduct under paragraph 9 of s. 15 (1) of O. Reg. 991, failure to comply with the Act, the Regulation and the by-laws, by breaching Code paragraph 3 of s. 14 (paragraph [4]). That paragraph requires a broker to serve the client “in a conscientious, diligent and efficient manner” and at a quality of service “at least equal to that which members would generally expect of a member in a like situation.”
He admitted that by failing to communicate clearly and effectively about the lack of water damage coverage he fell short of that standard (agreed facts, paragraphs 13 and 14). The panel was satisfied the plea was voluntary, informed and understood, and found him guilty (paragraphs [7] and [10]).
The penalty
The parties made a joint submission on penalty, and the panel accepted it, effective the day of the hearing (paragraphs [11] to [13]):
- a reprimand;
- a $2,000 fine, paid within 30 days by a cheque to RIBO payable to the Minister of Finance;
- three hours of RIBO-accredited education on client communication within six months, on top of his annual continuing education, with completion reported to RIBO.
On mitigation, the panel weighed his full cooperation, his early admission, his acceptance of responsibility and his remorse, and noted no prior discipline history in his many years of registration (paragraphs [21] and [22]).
Water damage in the reasons for penalty
The panel called water damage “one of the costliest and most frequent claims for homeowners,” with coverage that “varies by region, carrier and type of loss,” and said Ontario consumers rely on brokers to explain it (paragraph [18]). In its reading, he knew water damage coverage was not available and had noted that sewer backup could not be obtained, yet did not clearly tell the clients it was absent (paragraph [19]). They held the mistaken belief that they were protected until the insurer denied their claim, which the panel treated as an aggravating factor in paragraph [20].