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The 2019/2020 RIBO renewal asked whether the licensee was subject to “any Disciplinary action with respect to any licence”. Kuldip Sandhu answered No. On April 24, 2019, the Financial Services Tribunal had revoked his insurance agent licence under the Insurance Act, finding he had obtained continuing education certificates without taking the courses. RIBO found out from a public regulatory website. On January 22, 2026, a panel of the Discipline Committee accepted his guilty plea to two heads of misconduct in O. Reg. 991 and ordered a reprimand and two hours of ethics education. The decision, signed January 26, 2026, is published on CanLII as Kuldip Sandhu, 2026 ONRIBODC 2 (CanLII).
Two licences, one regulator told
Mr. Sandhu had been registered with RIBO in or around 1993 and worked at JSP Insurance and Financial Services. Until June 5, 2019, he was also a registered insurance agent under the Insurance Act (agreed facts, paragraphs 1 to 4). That licence answered to the Financial Services Commission of Ontario, FSCO, as it then was (agreed facts, paragraph 7).
The tribunal’s file, as summarized in the agreed facts, concerned whether he had provided fraudulent continuing education certificates to FSCO. The allegation was that he had not completed the required continuing education and had instead paid a retired instructor to supply the certificates (agreed facts, paragraph 7). The Superintendent of Financial Services issued a notice of proposal to revoke his licence on July 5, 2018. He requested a hearing. It was held on April 12, 2019, and he did not attend. On April 24, 2019, the tribunal ordered his licence revoked, finding he had committed the alleged acts. He did not appeal (agreed facts, paragraphs 8 to 11).
RIBO learned of the revocation in late 2019 from the Canadian Insurance Services Regulatory Organizations website (agreed facts, paragraph 5). His 2019/2020 renewal carried the answer No to the disciplinary-action question, which the agreed facts say was not correct (agreed facts, paragraphs 12 and 13).
The two heads of misconduct
The notice of hearing relied on two paragraphs of s. 15 (1) of O. Reg. 991, the definition of misconduct (paragraph [4]). Paragraph 11 covers “Being convicted, after the 1st day of October, 1981, of a criminal offence or an offence under the Insurance Act, whether or not the offence was committed before the 1st day of October, 1981.” Paragraph 14 is “Providing false or misleading information to the Corporation.”
The agreed facts mark out what the panel was not deciding. Whether he submitted false certificates to FSCO “is not an issue before the Discipline Committee” (agreed facts, paragraph 17). If he testified he would say he did not knowingly give FSCO false certificates, and that his failure to acknowledge the tribunal proceeding on his renewal was an oversight, not an attempt to mislead (agreed facts, paragraphs 20 and 24). He admitted the two things that were before the panel: that he was convicted of an offence under the Insurance Act, and that he failed to report the tribunal proceeding to RIBO (agreed facts, paragraphs 21, 22 and 25). He had no prior complaint or discipline record (agreed facts, paragraph 26).
The panel found him guilty of misconduct under both paragraphs (paragraph [9]). Its reasons hold the same line: it “was concerned regarding the seriousness of the underlying conduct” at FSCO “but accepts that this was not an issue before this Discipline Committee” (paragraph [16]).
The decision does not cite RIBO’s by-laws, but the reporting duty has a by-law home as well. By-Law No. 3, s. 2.7 (a), in the March 2024 text this site carries, requires an individual licensee to notify RIBO’s CEO within ten calendar days of “any discipline by any financial sector regulator or any professional or occupational body.”
The penalty
The penalty is a reprimand and two hours of RIBO-accredited ethics education, due within six months and additional to his annual continuing education, with an email to RIBO’s compliance administrator confirming completion. The panel ordered it as jointly proposed (paragraphs [11] to [13]).
The reasons address the renewal answer. “Providing timely, accurate and complete information to a regulatory body is an essential duty of regulated professionals,” the panel wrote, and RIBO “should not be required to review the public decisions of other regulators to identify reporting failures as they did in this case” (paragraph [17]).
Six years and nine months
The agreed facts explain the gap between the April 2019 revocation and the January 2026 hearing. The pandemic delayed the investigation, which was completed in the summer of 2021. The Complaints Committee referred the matter to the Discipline Committee in October 2022. From early 2023, before and after a pre-hearing conference in July 2024, the parties worked toward the agreed statement of facts the hearing proceeded on (agreed facts, paragraphs 14 to 16). The agreed facts record him as a member in good standing with a current licence status of Level 1 (agreed facts, paragraphs 2 and 26).