Build a position letter on BC RIA 2027.

Manual draft

[Store Name]
[Letter Date]

To the Insurance Council of British Columbia, the BC Financial Services Authority, and other recipients listed below:

Re: Restricted Insurance Agent Licence Regulation, B.C. Reg. 245/2025 (OIC 598/2025) - operator response from [Store Name]

We are writing as a motor-vehicle dealership operating in British Columbia that will be directly affected by the Restricted Insurance Agent Licence Regulation, B.C. Reg. 245/2025, enacted by Order in Council 598/2025 on December 18, 2025, and coming into force January 1, 2027. This draft distinguishes enacted statute and regulation from proposed consultation materials, final Council Rules that still require current-source confirmation, and dealer operating evidence. We support the principle of clear consumer disclosure in optional-insurance distribution. We are writing because implementation details will affect how we operate the F&I desk, and those details need to be clear enough for dealers to build training, disclosure, authorization, and recordkeeping controls before the regime starts.

1. Final-rule-status argument.

As of the source review date used for this draft (May 23, 2026), we understand that OIC 598/2025 and B.C. Reg. 245/2025 establish the January 1, 2027 RIA framework, while the post-consultation Council Rules, forms, and operational guidance still require current-source confirmation before a dealer can lock the workflow. We ask the Insurance Council to publish a single implementation source that distinguishes enacted statute and regulation, current Council Rules, proposed consultation wording, final adopted Council Rules, application forms, fee schedules, and training requirements. We also ask for a redline or change table showing what changed from the proposed RIA materials to final text. {STORE_NAME} operates {PRODUCT_COUNT_ON_MENU} F&I products on its current menu, with an estimated annual F&I revenue scale of {ANNUAL_FI_REVENUE_ESTIMATE}.

2. Training-availability argument.

The Insurance Council has indicated that training-accreditation submissions are expected in July 2026 and RIA licence applications are expected in November 2026. The regime starts January 1, 2027. {STORE_NAME} employs approximately {FI_SELLER_HEADCOUNT} sales representatives who may require training before being authorized to sell under the agency licence. If the accredited training catalogue, course providers, completion standard, and dealer-side cost information are not available before applications open, dealers will be asked to implement a mandatory seller gate without enough operating lead time. We respectfully request a dated implementation table that identifies training availability, who must take each course, whether a transition seller can sell while training is pending, and what evidence the dealership must retain.

3. Product-boundary argument.

BCFSA Regulatory Statement 24-008 distinguishes vehicle warranty insurance tied to mechanical failure from automobile insurance tied to theft, glass, paint, accident, or other fortuitous motor vehicle loss or damage. The Restricted Insurance Agent Licence Regulation lists credit protection insurance, guaranteed asset protection insurance, and vehicle warranty insurance for motor vehicle dealers. We ask the Council and BCFSA to publish practical product-boundary examples before final implementation, including examples of products that are RIA-listed, products that require separate automobile-insurance or other class review, and products that are outside insurance. Without that boundary, dealers may either over-remove products that could be sold under the correct path or keep products on the menu that require a different authority.

4. DR and E&O clarity argument.

The regulation requires a Designated Representative approved by Council and ICoBC public materials describe E&O insurance as part of the licence path. At {STORE_NAME}, the dealer principal is {DEALER_PRINCIPAL_NAME} and the F&I director is {FI_DIRECTOR_NAME}. We ask the Council to clarify who may serve as Designated Representative in a dealership operating chart, what qualifications or corporate role are required, how day-to-day F&I oversight can be delegated or supervised, and what records will prove that E&O coverage, seller training, insurer authorization, and disclosure oversight were in place at the time of sale.

5. Gross-vs-net compensation argument.

ICoBC proposed Rule 7(25) would require disclosure of direct or indirect commission, compensation, inducement, or benefit paid as a result of the insurance transaction if the amount exceeds 30 percent of the price paid by the client for the insurance product. We treat that wording as proposed unless final Council Rules confirm it. If the final rule preserves the trigger, we respectfully ask the Council to clarify whether the figure anchors to gross transaction compensation or to net contribution after chargebacks, cancellations, and reserve true-up. F&I gross compensation and F&I net contribution are materially different numbers. At {STORE_NAME}, the average chargeback rate across our F&I products is in the range of {CHARGEBACK_RATE_AVERAGE}. Dealers need a measurement window and reconciliation method so the same transaction is not handled differently from store to store.

6. Provincial economic-impact argument.

The motor-vehicle dealer subsector contributes materially to British Columbia's economy through operating revenue, employment, payroll, and provincial-tax remittance. The RIA implementation will create licence, training, disclosure, recordkeeping, product-review, and provider-transition costs whose effect will differ by store size and product mix. We respectfully request that the Ministry of Finance, the Insurance Council, and BCFSA publish an implementation-cost methodology and invite anonymized dealer operating evidence before final operating expectations are locked. Any public economic estimate should identify its data sources, assumptions, product classes, and limits so dealers can test the impact against their own records.

We are available to provide further operating detail on any of the points above. We are sending this letter in our individual operating capacity. We have copied the other recipients listed at the foot of this letter so they have visibility into the dealer-side operating implications of the regulation.

Sincerely,

[Dealer Principal Name]
Dealer Principal, [Store Name]

cc:
  - Insurance Council of British Columbia
  - BC Financial Services Authority (BCFSA)
  - Your MLA
  - BC Chamber of Commerce
  - Vancouver Board of Trade (Greater Vancouver Board of Trade)
  - New Car Dealers Association of BC (NCDA)
  - RVDA of BC