BrokerExamSurjeet Singh wrote the RIBO Level 1 entry-level broker exam in a virtually proctored sitting on November 25, 2022, received a passing mark and was licensed as a registered insurance broker. His exam service provider, the Insurance Institute of Canada, later nullified the pass “following exam administration audits conducted due to a potential breach of exam security,” and told him so on April 3, 2023. After a hearing on June 21, 2023, the Qualification and Registration Committee of the Registered Insurance Brokers of Ontario (RIBO) found that he “does not currently meet the requirements for licensing” and directed him to complete a full Level 1 licensing course and pass an in-person exam. RIBO publishes the decision as a PDF, Qualification and Registration Committee decision, Surjeet Singh.
A licensing committee
The decision comes from RIBO’s Qualification and Registration Committee, not its Discipline Committee. Under s. 13 (2) of the Registered Insurance Brokers Act, that committee determines whether applicants are eligible for certificates and may require further examinations or training, and under subsection (4) of the same section it may review the qualifications of any member. The ground in this case was a qualification in s. 5 (1) (a) (v) of O. Reg. 991: that the individual “satisfies the educational and experience requirements established by the Qualification and Registration Committee.” Two other decisions of the same committee, in which it proposed to refuse applicants on the good character ground, one of them over breaches of the exam rules, are in Good character and the RIBO licence: two decisions.
The decision records the nullification as the Institute’s, following exam administration audits it does not attribute, and it names the Data Forensics process as one the Institute uses. It does not describe what the audits found about his sitting.
April 2023
On April 4, 2023, RIBO told him that passing a licensing exam is a requirement to act as an insurance broker, and that his matter had gone to the committee for its meeting on April 12. He was offered a free rewrite in person. The decision records a recommendation that he voluntarily stop dealing with the public until he passed an in-person exam and gave RIBO proof, or until the committee decided, whichever came first, and he stopped at that time.
He wrote the in-person exam on April 12, 2023 and failed it. The same day the committee accepted RIBO’s recommendation and suspended his registration immediately, on the ground that he did not meet that educational and experience requirement. The suspension was to last until he completed a two-week training course from the Insurance Institute of Ontario or the Insurance Brokers Association of Ontario (IBAO), and rewrote and passed an in-person Level 1 exam with the Insurance Institute. RIBO emailed him the decision on April 13, 2023 and told him he could ask for a hearing.
What the committee ordered
At the hearing the committee accepted RIBO’s evidence and heard testimony from RIBO staff, from Institute staff and from Mr. Singh. It found that he did not, at the time of the hearing, meet that requirement, and directed that to be licensed he:
- complete a full Level 1 licensing course from the Institute or IBAO;
- write and pass an in-person Level 1 licensing exam from the Institute, without the eight-month wait in RIBO’s rewrite policy, on this one occasion;
- if that in-person exam is unsuccessful, wait eight months from it before writing any further exam.
The panel’s reasons
The panel accepted RIBO’s submissions on “the accuracy and validity of the Data Forensics process” the Institute uses to protect the integrity of the examination, and said all available technology should be used to keep examinations free from any disrepute. It was sympathetic to his sense that the time between the first exam and its nullification was unfair.
It did not accept his submission that he failed the second attempt because he had lost knowledge while working only with automobile insurance between the first exam and the notice of his suspension. The knowledge the Level 1 exam tests, it wrote, “is the baseline standard that all Registered Insurance Brokers are expected to maintain for the duration of their employment,” whatever area of practice a broker pursues. It accepted that he had not worked with the public since the suspension, and thanked him for his “prompt and complete cooperation.”
The rules on RIBO’s site now
RIBO’s current Exam Rules were last updated January 15, 2025, after this decision. Several speak to what happened here:
- Rule 2.15: exams are routinely reviewed for irregularities and breaches of the rules, the exam service provider may nullify an exam that shows them, and a nullified exam forfeits its fee.
- Rules 5.3 and 5.4: technical data such as an IP address and a device ID may be collected, and a virtually proctored sitting is recorded on video and audio.
- Rule 7.3: irregularities or breaches may lead to suspension of exam privileges, refusal of a registration application, suspension of a registration, or a review by the Qualification and Registration Committee that may end in revocation of the licence.
- Rule 2.20: two attempts per exam provider, then an eight-month wait after a second failure with the same provider.
The Exam Administration and Academic Integrity Policy on RIBO’s Examinations page adds that a nullified exam counts as an attempt, and that a candidate with a nullified exam may be approved to register again as long as every future exam is written in person. For a licensee, it says, a nullified qualifying exam means suspension under By-Law No. 3 until they pass and the suspension is confirmed lifted.