BrokerExamStephen Philips, a broker at Best Buy Insurance Brokers Inc., admitted to RIBO’s Discipline Committee that he delegated or ceded client communications and tasks to a referral source who was not licensed at the time. The communications ran through much of 2020. In May 2020 he let the referrer handle the signing of a client’s application, which reached him afterwards by email. The referrer was a former broker, registered from December 2000 until he resigned in September 2009, and registered again in April 2021. On March 26, 2026, a panel accepted Mr. Philips’ guilty plea to breaching three paragraphs of the Code of Conduct and ordered a reprimand and three hours of ethics education. The decision is published on CanLII as Stephen Philips, 2026 ONRIBODC 5 (CanLII).
What happened
Best Buy terminated Mr. Philips’ employment in January 2021, and on March 8, 2021, its principal broker complained to RIBO, alleging that while employed he had been sharing confidential information entrusted to Best Buy with an unlicensed individual and sending policy change requests on that individual’s instructions (agreed facts, paragraphs 4 to 6). He had been registered with RIBO in or around September 1997, and the agreed facts filed at the hearing record his registration status as Level 1 (agreed facts, paragraphs 1 and 2).
The referrer was a source of client referrals for Best Buy, which did not object to them on the assumption that Mr. Philips was doing the work of a licensed broker and handling all communications, applications and advice himself (agreed facts, paragraphs 10 and 11). The referrer also dealt with other Best Buy employees, including the managing partner and a sales executive, in exchanges that “went beyond simple referrals and discussed particulars of various files/clients” (agreed facts, paragraphs 12 and 13). Best Buy had firsthand knowledge of the communications between the two men. Mr. Philips was cautioned against taking instructions from the referrer on behalf of clients and reminded that every task required of a licensed broker was his to do (agreed facts, paragraphs 15 and 16).
Mr. Philips’ account is recorded in the agreed facts as what he would say if he testified. He would say that he communicated directly with every referred client, and that when the referrer was on the phone during those conversations it was with the clients’ consent. The clients, on his account, had consented to him discussing their files with the referrer. He would also acknowledge that on certain occasions the referrer relayed information from a client to him (agreed facts, paragraphs 17 to 19). RIBO’s investigation report has no evidence either way on whether consent was formally obtained, though some emails show clients copied alongside both men (agreed facts, paragraphs 20 and 21). None of the referred clients complained to RIBO about him, and no complaint has been made to RIBO against the referrer or any other Best Buy employee over the referral relationship (agreed facts, paragraphs 24 and 25).
He acknowledged one incident outright. In May 2020 he was not present at a meeting where a client signed an application in front of the referrer, who then forwarded it to him by email. The managing partner knew of it and cautioned him (agreed facts, paragraphs 22 and 23).
The provisions he breached, and the one withdrawn
The allegation was misconduct as defined by paragraph 8 of s. 15 (1) of O. Reg. 991, failure to carry on business in a manner consistent with the Code of Conduct, and it named four paragraphs of s. 14 (paragraph [4]). RIBO withdrew the confidentiality allegation under Code paragraph 5 at the hearing, telling the panel there was insufficient evidence to proceed on it, and the panel ordered it withdrawn (paragraph [5]). The gap was the consent evidence described above (agreed facts, paragraphs 26 and 27).
He pleaded guilty to the remaining three (paragraph [6]): integrity in discharging a member’s duties (Code paragraph 1), service that is conscientious, diligent and efficient (Code paragraph 3), and the safekeeping of client property (Code paragraph 6). The last of these tells a member to observe all relevant rules and laws on preserving and safeguarding client property entrusted to the member and, when there are none or the member is in doubt, to take “the same care of such property as a careful and prudent person would take of the person’s own property of like description.” He admitted that by delegating or ceding communications and tasks to the referrer he breached the integrity duty and failed to serve at least one client conscientiously (agreed facts, paragraph 29). He also admitted that by letting the referrer handle the signing of an application he did not take appropriate steps to safeguard it (agreed facts, paragraphs 30 to 32). The panel found him guilty of misconduct on those three paragraphs and permitted RIBO to withdraw the fourth (paragraph [12]).
The decision makes no misconduct finding about the referrer, who is now registered again, and it does not cite the registration requirement in s. 2 (1) of the Registered Insurance Brokers Act. What it decides is the licensee’s side of the arrangement. A licensee “has an obligation not to use unlicensed intermediaries to carry out work that is properly within the scope of the insurance broker,” and that obligation “is particularly important at the time of the formation of the insurance contract, which starts with the signing of an application” (paragraph [19]).
The penalty
The parties jointly proposed a reprimand, three hours of RIBO-accredited ethics education to be completed within six months in addition to his annual continuing education, and an email to RIBO’s compliance administrator confirming completion. The order went into effect at the hearing on those terms (paragraphs [14] and [15]).
There was no evidence of any consumer complaint or risk resulting from the delegation, which the panel counted as mitigating (paragraph [21]). The evidence indicated it was done with client consent and without malicious purpose or fraudulent intent (paragraph [22]). The panel accepted that he likely did not intend to breach the Code, was remorseful, cooperated with the investigation and agreed the facts (paragraph [23]). The panel also noted that the referral arrangement “appeared to be known at Best Buy” (paragraph [18]).
Client consent did not settle the question. “The evidence suggests that this arrangement proceeded with client consent but even with the client’s consent it is incumbent upon the Licensee to ensure that he is effectively performing all of the work that is within the scope of an insurance broker” (paragraph [20]).