THE QUESTIONS THE RECORD SHOULD BE ABLE TO ANSWER
The rebuilt docket carries forward the detailed questions that were easy to lose in the redesign: problem definition, impact studies, enforcement, product terms, 30% calibration, jobs, consumer outcomes, costs and competitive effects.
AUDITED CROSS-EXAMINATION
These questions pre-specify calibration, outcome, counterfactual and falsification issues before post-2027 results are known.
FCNB publicly identifies compensation above 30% as a significant inducement. What empirical, behavioural, legal-comparative or supervisory analysis calibrated 30% as the breakpoint rather than 20%, 25%, 35% or 40%?
This asks for the calibration behind a published policy rationale; it does not assert that no rationale exists.Is success expected to mean lower prices, fewer complaints, lower denial rates, improved rescission or refund compliance, better understanding, more alternative shopping, or some combination - and by how much?
An intervention is easier to evaluate when its success criteria are defined before the post-period is observed.What measurable post-implementation result would weaken the case that the intervention achieved its intended objective?
A useful evaluation needs a falsification condition, not only a list of possible successes.If dealer remuneration falls, is the intended mechanism a lower customer price, a lower financed balance, insurer or administrator retention, another distribution channel, or reduced product uptake - and how will that be measured?
Dealer loss, consumer saving and insurer retention are different economic outcomes.Why are RIR-specific product price, penetration, remuneration, complaints, cancellations, claims or denials, and dealer-economic outcomes not visible in the public annual reporting reviewed?
The public record can establish the regime and regulator activity without establishing the dealer or consumer treatment effect.Those figures are RIR firm licences produced, not dealership counts or active insurance transaction volumes. What is the active auto, RV and marine subset, and how did it change?
A licence-production series needs a business-type denominator before it can describe a dealer channel.How many B.C. businesses, branches and individual sellers are expected in each class, and how will actual uptake, suspensions, cancellations and non-renewals be published?
Without the denominator, licence activity cannot be translated into market coverage.What are the final licence, E&O, designated-representative, training, systems and staff-time assumptions by business size once the Council program is final?
Direct compliance expense should be measured separately from behavioural effects on product sales or compensation.Can 2024-2025 and 2026 consumer and dealer metrics be defined and published before post-treatment outcomes are known?
Because consultation and implementation guidance are already public, 2026 should be treated as a possible anticipation period rather than a pristine untreated year.Existing motor dealers can remain under transitional treatment after January 1, 2027. Will evaluation use actual application, licensing and training dates rather than a single provincial switch?
Actual exposure dates matter to an event study when transition is staggered.Québec dealer and consumer-credit VSPED channels differ in context. Which product, borrower and insurer variables are required before treating their refusal-rate gap as evidence about distribution-channel effects?
A published descriptive comparison is not automatically a matched causal comparison.Will future public reporting identify whether figures are self-reported, audited, reconciled or regulator-validated?
AMF explicitly says the insurer-supplied data in its 2020-2022 analysis were not independently verified.B.C. says proposed disclosures align with other restricted regimes. Which jurisdictions, provisions and analyses were used in drafting, and is there a documented model-rule or harmonization chain?
Chronology can show an older antecedent without proving direct copying.If a credible controlled study found measurable consumer benefits with no material dealer or labour harm, what material-harm claim would be weakened?
The study should be able to disconfirm a large dealer-harm hypothesis.If compliance costs or dealer and labour effects were material while measurable consumer outcomes did not improve, what review or adjustment criteria would apply?
The study should be able to disconfirm a large consumer-benefit hypothesis as well.How many complaints, investigations, substantiated findings, restitution orders or enforcement matters involving dealer-distributed insurance were used to define the policy problem, broken out by product, year and transaction volume?
Aggregate insurance complaint activity cannot establish the incidence of a dealership-specific problem without a dealership and transaction denominator.Of the identified dealership matters, how many involved qualifying compensation above 30% of the client price, and how many involved a different issue such as disclosure wording, claims handling, cancellation, refund or product suitability?
This is required to connect the selected threshold to the problem population rather than to insurance complaints generally.What is the expected effect on financed principal, lender advance ratios, payment bands, approval tiers, exceptions, lender reserve and product-financing allowances if affected products are repriced, removed or moved to another channel?
The direction is not predetermined: lower principal may improve some affordability metrics while lender-specific programme thresholds can create different effects.For each affected product class, what change is expected in PST, insurance-premium tax, federal luxury tax, GST/HST, taxable dealer income and payroll, and what taxable base supports each estimate?
A reduction in dealer compensation is not automatically a reduction in every tax head. Product classification and the actual taxable base control.What are the expected application, annual, training and late-fee receipts by business tier, and what portion of programme spending is allocated to licensing, supervision, investigation, enforcement, technology, practice support and broader Council infrastructure?
Published fee rationale says the programme is intended to fund licensing, administration, oversight and practice support; a programme-specific budget and expected collections are needed to test cost recovery.Which body receives a complaint, investigates it, obtains transaction records, disciplines the agency or representative, coordinates with the VSA or BCFSA, and pursues unauthorized insurance activity? What staffing and escalation model has been budgeted?
The legal and operational stack should be visible to the public so existing and new oversight roles can be distinguished rather than assumed to be duplicative.QUESTIONS RECOVERED FROM THE ORIGINAL CASE FILE
These questions survived the source audit and are carried forward here rather than being stranded in a data module.
The official materials cited on this page describe the framework and consultation, but do not supply a quantified B.C.-specific harm assessment. Publish any needs analysis, impact model and alternatives assessment used in the design.
Consultation materials propose a maximum $1,000 application fee, a tiered annual fee model and a maximum $500 late fee, while the Council Q&A says final amounts are still being determined. No final approved per-rooftop total, DR-course fee, seller-training price or E&O quote is established here.
The Council's accreditation page says sales representatives must complete accredited product training and anticipated applications for provider accreditation in fall 2026. This briefing has not verified a current list of accredited RIA courses, course duration, learner price or seat capacity.
Partly answered by the Council: every RIA business must appoint a Designated Representative, an officer, director, partner or sole proprietor, who takes a mandatory DR course and owns compliance. A short-term provision lets reps sell while accredited training catches up; its final conditions aren't published.
No published upstream cost figure is cited here. Publish the expected fee, training, oversight and insurance costs, and identify which parties are legally responsible for them.
Appearance, glass, theft, tire, key and similar products remain classification-sensitive with no definitive list.
Proposed Rule 7(25) applies to restricted insurance agencies. Reviewed sources do not establish a blanket OEM exemption. Publish examples covering factory-branded, third-party, captive-finance and referral structures so equivalent transactions can be compared.
No reviewed B.C. source requires one-year creditor-life, disability or critical-illness terms. If any regulator or insurer proposes a term change, publish the exact before-and-after wording and consumer continuity analysis.
The founder reports off-site binding and referral compensation for some products. Publish the legal classification, compensation disclosure, product access and consumer-service effects for each proposed structure before extrapolating that observation across the menu.
The legal result depends on the insurance class, seller category and product wording. Publish worked examples for automotive, electronics, appliance and other warranty channels so differences can be understood from the governing text.
Confirmed by the Council: businesses require E&O insurance for their insurance activities. The dealer principal-level DR is accountable for an F&I office they may not run day-to-day. What E&O costs once providers price that new exposure is the open number.
The prescribed unlicensed-agent contravention carries administrative maxima of $50,000 for a corporation and $25,000 for an individual. Publish the responsible bodies, staffing, service levels, investigation process and penalty guidance for the new regime.
The NCDA/MNP study estimates $775M in annual government revenue from B.C. new-car retail using 2022 data. This briefing cites no comparable cross-sector model for the RIA regime. Ask the Ministry to publish its fiscal, sector-tax and workforce assumptions, if prepared.
THE AUDITED CASE FILE · 23 QUESTIONS · 10 SUBJECTS
Open a subject to see what the reviewed public record shows, what is still missing, who owes the answer and the document to ask for. This is a different list from the recovered questions in section 02.
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
Sources in the public record
An integrated whole-economy impact analysis covering dealer F&I, employment, families, lenders, consumers, tax bases, product access, aggregate compliance cost, and competitive structure was not located in the named public record reviewed as of September 4, 2026. This does not prove no internal or unindexed analysis exists.
IMPLEMENTATION / ENFORCEMENT
Implementation mechanics are economic facts too. Systems, monitoring, procurement, staffing and data access belong in the public record.
The letter builder remains editable. It does not send anything automatically and does not require a reader to adopt a political conclusion.
