BrokerExam
An insurer decided it would no longer insure a standalone rental property and mailed the client a non-renewal notice on December 9, 2020, giving a termination time of 12:01 a.m. on January 30, 2021. The brokerage had a copy by December 16. It was scanned into the broker management system on January 22, 2021, more than a month later. The broker on the file, Ryan David Myers, then sent the client a registered letter. It did not go out until January 29 and did not arrive until February 8, and the client learned of the lapse three days after his coverage ended. Mr. Myers pleaded guilty to misconduct, and by an order effective September 4, 2025, RIBO’s Discipline Committee reprimanded him and fined him $1,500. The decision is published on CanLII as Ryan David Myers, 2025 CanLII 147382 (ON RIBODC). RIBO’s own citation for it is 2025 ONRIBODC 4.
What the agreed facts say
The client complained to RIBO on February 8, 2021, about the non-renewal of the policy on his rental property (agreed facts, paragraph 2). Royal and Sun Alliance Insurance Company of Canada had mailed its notice by regular mail rather than registered mail, because it was giving more than 30 days’ notice before the policy expired (agreed facts, paragraph 5). The notice went to the wrong address and was delivered to a neighbour who was in Florida, so the client did not see it until the property had been without coverage for three days (agreed facts, paragraphs 6 and 8).
Mr. Myers’ own letter was dated January 22, 2021, eight days before termination. It was not sent until January 29, one day before termination, “due to the brokerage’s rotating schedule as a result of the pandemic.” It reached the client on February 8, after the policy had ended (agreed facts, paragraph 7). When the client spoke to him on February 3, he said he would try to extend the insurance. The client spoke to someone else at the brokerage the next day and was told there was nothing further they could do and that it was his problem (agreed facts, paragraph 9).
The brokerage’s procedure was to review, compare and check renewals 30 to 45 days in advance. Mr. Myers had assumed the insurer sent its notice by registered mail and discovered on February 3 that it had not. He asked the underwriter for a 30-day extension and was refused (agreed facts, paragraph 10).
The provision he breached
The plea and the finding rest on a single paragraph of the Code of Conduct. Paragraph 3 of s. 14 of O. Reg. 991 requires a member to “serve the member’s client in a conscientious, diligent and efficient manner and shall provide a quality of service at least equal to that which members would generally expect of a member in a like situation.” Failure to comply with the regulation is misconduct under paragraph 9 of s. 15 (1). He pleaded guilty on that basis (paragraph [6]), and the panel found him guilty (paragraph [16]).
One oddity in the record: the notice of hearing describes the charge as “failing to provide supervision for onboarding their unlicensed new hires” (paragraph [4]), wording that does not match the agreed facts, which are entirely about the non-renewal. The plea was entered to the charge as worded (paragraph [6]); the finding and the reasons proceed on the non-renewal facts.
What the panel expected instead
The panel accepted that staffing was disrupted by the pandemic, but “a broker has a positive obligation to immediately address the ramifications of an insurer’s notification to their client of the non-renewal of a policy of insurance” (paragraph [9]). Failure to do so “can result in clients becoming uninsured and their assets unprotected, which occurred for a period of time in this case” (paragraph [9]).
The month between December 16 and January 22, during which the notice sat unscanned, was “very concerning to this panel” (paragraph [10]). Once Mr. Myers knew of it on January 22 he still had eight days “to confirm the client was aware of the insurer’s position and to arrange to find alternative coverage for the rental property if directed by the client” (paragraph [11]). The situation “warranted attempts at immediate contact by phone or e-mail, documented in the broker management system, rather than sending another letter which was not treated as urgent by brokerage staff and did not reach the client until coverage had lapsed” (paragraph [12]).
Some panel members thought a 30-to-45-day renewal review window was too short to deal with problems that surface at renewal (paragraph [13]), and there was no evidence that Mr. Myers did the review in this case (paragraph [14]). There was also no evidence the client suffered any uninsured loss while the property was uninsured (paragraph [15]).
The penalty
The joint submission was a reprimand and a $1,500 fine payable to the Minister of Finance. No discipline history was alleged (paragraph [21]). The panel noted the test for declining a joint submission in R. v. Anthony-Cook, 2016 SCC 43, as applied to Ontario discipline bodies by Bradley v. Ontario College of Teachers, 2021 ONSC 2303 (paragraph [22]), accepted the submission, and made the order effective September 4, 2025 (paragraph [19]).