30% is a disclosure trigger, not a compensation cap.
Québec s.431 requires disclosure when distributor remuneration exceeds 30% of the product sale price. The historical note traces the provision to the 1998 enactment.
AUDITED CASE FILE · SEPTEMBER 16, 2026
21 questions.
One rule: show the evidence.
The public record is strong enough to establish the legal architecture and several descriptive facts. It is not strong enough to answer every economic question. These are the questions that should become measurable before the post-2027 story is written.
00 / BEFORE THE QUESTIONS
What the audit already changed.
The red team did not simply make the case louder. It narrowed claims where the evidence was weaker and sharpened questions where the public record was stronger.
New Brunswick does publish a rationale for the 30% threshold.
FCNB describes compensation above 30% as a significant inducement and says disclosure supports informed decisions and consumer protection. The unresolved question is what evidence calibrated 30% as the breakpoint.
Québec remuneration stayed materially above 30% in the reported products.
AMF reports dealer remuneration of 53-54% of premium for VSPED and 45-46% for F.P.Q. No. 5 in 2020-2022. AMF also states that the underlying insurer submissions were not independently verified.
New Brunswick does not yet answer the central dealer-economics question in the reviewed public record.
Public reporting shows licensing and compliance activity, but not a dealer-level series for F&I PVR, affected-product penetration, payroll/FTE, pretax profit or consumer price pass-through.
01 / THE CROSS-EXAMINATION
Questions the record should be able to answer.
Not talking points. Not a yes/no scorecard. Each one is designed to produce a document, a denominator, a baseline, a method or a falsifiable result.
01
Calibration & purpose
01
Why 30%?
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.
02
What is the pre-specified consumer outcome?
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.
03
What would count as evidence that the intervention did not work?
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.
04
Where should the displaced dollar go?
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.
02
New Brunswick evidence
05
What does New Brunswick actually show?
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.
06
How should the public interpret 361 / 410 / 409?
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.
03
B.C. implementation
07
What is the implementation denominator?
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.
08
What is the final compliance-cost budget?
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.
09
Why not freeze the B.C. baseline before transition?
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.
10
How will transition be evaluated?
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.
04
Comparability & auditability
11
How will cross-channel comparability be handled?
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.
12
How will source quality be labelled?
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.
13
What explains the 30% lineage?
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.
05
Symmetric falsification
14
What evidence would change the dealer side’s view?
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.
15
What evidence would change the regulator side’s view?
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.
06
Consumer-harm denominator
16
How many dealership cases actually defined the problem?
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.
17
How many of those cases involved compensation above 30%?
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.
07
Credit & affordability
18
What happens to financing approvals and lender capacity?
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.
08
Tax & fiscal incidence
19
Which tax base is actually expected to move?
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.
S12 · B.C. Reg. 245/2025 - Restricted Insurance Agent Licence RegulationS19 · Canada Revenue Agency - Luxury tax consideration and retail valueS20 · B.C. Ministry of Finance - PST Bulletin 116: Motor Vehicle Dealers and Leasing CompaniesS21 · B.C. Ministry of Finance - PST Bulletin 303: Warranties, Service Contracts and Maintenance AgreementsS22 · B.C. Ministry of Finance - Licensed insurance taxesS25 · B.C. Ministry of Finance - PST Tax Interpretation Manual, vehicle purchase-price inclusions and exclusions
09
Programme funding & enforcement
20
What will the RIA programme collect and what will it cost to run?
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.
21
Who is actually deployed when something goes wrong?
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.
02 / THE DISCIPLINE
The questions only work if both sides can lose an argument.
What would weaken it?
If credible controlled evidence finds meaningful consumer improvement and no material divergence in affected-product economics, F&I payroll/FTE or dealer profitability, a large dealer-harm claim should weaken.
What would weaken it?
If compliance costs or dealer/labour effects are material while price, complaints, denials, refunds or access do not improve against a credible counterfactual, a large consumer-benefit claim should weaken.
03 / OPEN THE WORKINGS
The pressure comes from the audit trail.
See the claim gate, treatment-timing corrections, source-quality labels, proposed study design and evidence-acquisition plan behind these questions.