BrokerExamThe misconduct in this case never touched a client file. Titilayo “Lucia” Owanubi, a Level 1 broker whose registration is now listed as inactive, submitted 39 false health claims to Sun Life under her own employer’s group benefits plan, and RIBO’s Discipline Committee found her guilty of misconduct for it. The panel ordered a reprimand, a one-month suspension, and three hours of accredited ethics education. The matter was heard on April 23, 2026, and the decision is published on CanLII as Owanubi, 2026 ONRIBODC 8 (CanLII).
What happened
Ms. Owanubi was registered with RIBO in or around January 2020 and worked at NFP Canada Corp. Sun Life, NFP’s group benefits provider, wrote to her on October 22, 2024 and again on November 6, 2024, setting out its finding: 39 false claims submitted between February 20 and June 20, 2024, verified by contacting the service providers, who confirmed they had not provided the services claimed. Sun Life had paid out $4,799.47 and required repayment in full. On October 25, 2024, Sun Life notified the brokerage that its preliminary investigation had raised concerns about her claims (paragraphs 2 to 6 of the agreed facts).
She did not contest any of it. In an email to Sun Life two days after that first letter, she acknowledged she had no proof for the claims and asked to repay the money, and by early November 2024 a repayment plan was in place. NFP’s principal broker complained to RIBO on November 7, 2024 (paragraph 4 of the agreed facts). Ms. Owanubi cooperated with the investigation, acknowledged the conduct early, and told the investigator her judgment had been severely affected by family and financial challenges (paragraphs 7 to 10 of the agreed facts).
At the hearing she pled guilty on an agreed statement of facts, and the panel found her guilty of misconduct under s. 15 (1) paragraph 9 of O. Reg. 991 for breaching the integrity requirement in s. 14, para. 1 of the Code of Conduct: “A member shall discharge the member’s duties to clients, members of the public, fellow members and insurers with integrity.”
Why a personal matter drew professional discipline
The conduct “did not involve a client transaction”, the panel wrote, but “brokers are intermediaries and are required to act with integrity in dealings with insurance companies. The Licensee failed to do so repeatedly in this case.” The repeated nature of the conduct, 39 claims over four months, was an aggravating factor (paragraph [17]).
The mitigation ran the other way: early admission, the repayment plan, full cooperation, a clean discipline history, and the personal circumstances that the panel said appeared to have clouded her judgment (paragraph [18]; paragraphs 9 and 15 of the agreed facts).
The penalty
The parties filed a joint submission and the panel accepted it, ordering that Ms. Owanubi be reprimanded, suspended for one month, and required to complete three hours of RIBO-accredited ethics education within six months, on top of her annual continuing education obligations, with completion reported to RIBO’s Compliance Administrator (paragraph [12]).
The panel recorded that it “was concerned with the penalty” but that its concern did not meet the high bar for rejecting a joint submission set by R. v. Anthony-Cook, 2016 SCC 43, which applies to disciplinary bodies in Ontario under Bradley v. Ontario College of Teachers, 2021 ONSC 2303 (paragraph [14]).
On general deterrence, the panel wrote that the public decision reminds the broker community “that they must act with integrity in all dealings, including dealings in their own personal insurance matters” (paragraph [20]). That is the duty in s. 14, para. 1 of O. Reg. 991, and it covered this broker’s dealings with her employer’s insurer. On this site, s. 14, para. 1 is drilled in the general practice section.