Client File in Ontario
This is your operational checklist for ensuring that your life insurance client records in Ontario are compliant with FSRA's requirements.
📋 Phase 1: Relationship Initiation (Before Analysis)
Advisor Disclosure: Provided to the client in writing prior to any collection of sensitive data.
List of insurers: Clear identification of all the companies you represent.
Conflict of Interest Statement: A disclosure signed by the client if a situation of real or apparent influence exists.
Method of compensation: Explicit mention of commission compensation and potential incentives.
📋 Phase 2: Needs Analysis and Recommendation
Financial Needs Analysis (FNA): A comprehensive written analysis that is timed and aligned with the client's current financial situation.
Risk Tolerance Profile: Documented assessment (particularly if the product is linked to segregated funds).
Solution Rationale: Written note explaining why the chosen life insurance product meets the client's objectives.
LIRD Form (if applicable): A completed and signed insurance replacement form if an old policy is cancelled.
📋 Phase 3: Identity Verification and Financial Crime
FINTRAC Compliance: Verification of client identity (valid identification, photo, date of birth).
Determination of beneficial ownership: Identification of the person who actually controls the policy (if a corporate entity).
Source of funds: Documentation of the source of the money used to pay the premiums (required for large amounts).
📋 Phase 4: Follow-up and Contemporary Notes (The Logbook)
Dated Discussion Notes: Written records of each call, email or meeting (physical or virtual).
Client Refusal: Written proof that the client has declined coverage or an option that you recommended.
Proof of delivery of the policy: Receipt signed by the customer confirming receipt of the insurance contract.