BrokerExamRIBO’s Discipline Committee reprimanded Frank Peragine and fined him $2,500 at a hearing on February 26, 2026, and its reasons say the panel “struggled with” a penalty that small. The facts he admitted began with an “Insurance Program” flyer he handed to taxi drivers in August 2019. It told them coverage was available provided they paid the brokerage and, on top of that, paid him. The cheques made out to him went into his personal bank account. Two brokerages complained to RIBO within eight months of each other, RIBO investigated both, and the panel heard the two files together. The decision, dated March 26, 2026, is published on CanLII as Frank Peragine, 2026 ONRIBODC 4 (CanLII).
What happened
The agreed statement of facts runs two files. The first came from Clover Insurance Brokers, which complained to RIBO on February 13, 2020. Clover had not seen or approved the flyer (agreed facts, paragraph 6). Between August and September 2019, Mr. Peragine accepted cheques from taxi drivers and taxi fleets and deposited them into his personal bank account. Those payments were in addition to the policy premiums the drivers paid to Clover (agreed facts, paragraph 7). When Clover learned that he had asked clients to pay him directly, he told Clover that only one cheque had been made out to him personally, which the agreed facts describe as a false and misleading statement (agreed facts, paragraph 8).
The second file came from Cowan Insurance Group Ltd., which complained on September 30, 2020. On February 5, 2020, a taxi driver told Cowan he had been forced to pay Mr. Peragine $1,000 for insurance. The driver had been given an “Insurance Program” flyer that prominently displayed Cowan’s logo, along with Mr. Peragine’s name, his RIBO registration number and his cell phone number. It said drivers renewing their policies had to pay Cowan and also write a cheque to him. Cowan had not authorized it (agreed facts, paragraph 9). Asked about the flyer, he said he had no knowledge of it and had not created it (agreed facts, paragraph 10).
Cowan suspended him with pay and reviewed his laptop. The agreed facts list what it found (agreed facts, paragraph 11):
- work information, including private and confidential client information, sent to his wife, who was not authorized to receive it;
- a certificate issued to a policyholder with the wrong term, policy number, broker and insurer;
- Facility liability certificates issued under the name of RSA Inc. only, so that the vehicles would appear to be insured in the voluntary market;
- no evidence that four clients were told about a gap in coverage from January 31, 2020 to February 5, 7, 8 and 9, 2020;
- certificates of insurance handed to a client with the advice that someone in the client’s office could amend them on his behalf; and
- a request to change a letter of experience so that it showed coverage to January 31, 2020 rather than July 31, 2019, with no evidence a policy was bound for that period.
The Complaints Committee referred both investigations to the Discipline Committee on May 26, 2025 (agreed facts, paragraph 5). The hearing proceeded on an agreed statement of facts and a joint submission on penalty, and he pleaded guilty (paragraph [6]).
The provisions he breached
The notice of hearing charged misconduct under paragraph 9 of s. 15 (1) of O. Reg. 991, failure to comply with the Act, the regulation and RIBO’s by-laws, by acting contrary to s. 12 (1) and to a run of paragraphs in the Code of Conduct in s. 14 (paragraph [4]). The decision’s own list of those paragraphs is not consistent. The notice, the admission and the finding each read “14(1), 14(2), 14(3), 14(4), 14(5), 14(6), 14(7.1), 14(8), 14 (9), 14(10), 14(11), 14(12), 14(13) and 14(4)”, which names Code paragraph 4 twice and never names Code paragraph 14, although the notice sets out Code paragraph 14’s text (paragraphs [4], [9] and [11]). The plea as recorded ends “14(13), and 14(14)” (paragraph [6]). Read together, the provisions in play are s. 12 (1) and Code paragraphs 1 to 6, 7.1 and 8 to 14, with the finding at [11] worded on the shorter list.
Section 12 (1) is the fee-disclosure rule. Where a member proposes to charge a fee for service on top of retaining part of the premium, the member must disclose, before placing the insurance, “the amount of the fee, the portion of the premium retained and the total remuneration on the transaction.” The decision does not assign facts to sections. The extra cheques made out to Mr. Peragine are the facts this section describes.
The Code of Conduct paragraphs cover integrity (para. 1), competence (para. 2), conscientious and diligent service (para. 3), candour and honesty with the client (para. 4), confidentiality of client information (para. 5), care of client property (para. 6), written disclosure of conflicts of interest (para. 7.1), fees that are fully disclosed and not unconscionable (para. 8), public respect for the vocation, efficient and convenient service, the integrity of the vocation and preventing its unauthorized practice (paras. 9 to 12), courtesy and good faith (para. 13), and cooperation in a RIBO investigation (para. 14). He admitted the breaches (paragraph [9]), and the panel found him guilty of misconduct on that record (paragraph [11]).
The penalty
The parties jointly asked for a reprimand and a fine of $2,500 payable to the Minister of Finance. The panel accepted the joint submission and made the order effective the day of the hearing (paragraph [14]).
The reasons set out the panel’s view of that figure. It described the allegations as “numerous, serious, and contained elements of ethical failings, including misleading consumers and providing false and misleading statements to two employers during their investigations of complaints,” and said the payments into a personal account indicated “financial impropriety” (paragraph [18]). It “struggled with the penalty of only a reprimand and a fine of $2,500.00 for this conduct” (paragraph [22]).
The panel found the submission “was not so unhinged from the circumstances that it brought the administration of justice into disrepute” (paragraph [23]), the test for rejecting a joint submission set in R. v. Anthony-Cook, 2016 SCC 43, which applies to this tribunal through Bradley v. Ontario College of Teachers, 2021 ONSC 2303 (paragraph [24]). It noted the conduct dated from 2019 and 2020, that no discipline history was alleged, and that the guilty plea spared RIBO, witnesses from two brokerages and multiple consumers “what would likely have been a very lengthy hearing” (paragraphs [20] and [21]). His counsel told the panel he had been licensed since 2014, no longer writes automobile policies, and works part time at a media company (paragraph [19]).
Paying the fine
After the order was made, Mr. Peragine asked for time to pay, and the panel gave him 30 days (paragraph [16]). It added that it expects fines to be paid the day they are ordered, “particularly when the penalty is negotiated ahead of the hearing,” and that a licensee who wants payment terms on an agreed penalty should have them written into the joint submission (paragraph [15]).