Managing general agents in Canada operate under inconsistent rules depending on which province they're in, according to Brett Boadway (pictured centre left), executive director of the Canadian Association of Managing General Agents (CAMGA), speaking on a panel at a recent industry conference. And the case for fixing that isn't just coming from the MGAs themselves, it's coming from the insurers who rely on them too.
"One of the things I keep hearing is that MGAs are not regulated, and they are," Boadway said. The reality, she said, is closer to a patchwork than a system: whether an MGA firm needs to be registered, whether individual employees need a license, and whether the MGA needs a trust account or fidelity bond all vary significantly by province and territory.
"Sometimes it's at an agency level; sometimes, like in Saskatchewan and New Brunswick, there is actually an MGA registration as a firm, and in some cases, like PEI and Manitoba, the firm does not have to be registered at all as an MGA," Boadway said.
One jurisdiction stood out for a different reason, according to Boadway: Ontario doesn't require MGA licensing at all, which she said "does produce a gap in the oversight model." Despite that, nearly every MGA in the province gets licensed anyway, she said, because it signals to brokers and the wider market that they have been through proper diligence and can be trusted partners.
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That inconsistency has become significant enough that CAMGA has formally called for a national standard, Boadway said, laying out the case in a 55-page position paper the association has published. Her summary came down to a handful of core recommendations: a consistent national standard for MGA oversight, a defined standard for what qualifies someone as a designated individual with supervisory authority, consistent fidelity requirements across every province (including mandatory E&O insurance and trust accounts), and a single audit framework MGAs could use to satisfy every province at once rather than repeating the process province by province.
"It's time for a national standard for MGA oversight and regulation," Boadway said, noting that three provincial regulators have already signalled the issue is on their own strategic roadmaps. "If three of you are talking about it at the same time, then let's get together and all do the same thing."
Support for that push isn't limited to the MGA side of the table. Paul Jackson (pictured centre right), CEO of Zurich Canada, said the fragmented regulatory landscape creates a structural imbalance that goes beyond MGAs alone.
"Regulation in Canada is fragmented and inconsistent," Jackson said. He was careful to frame the issue as one of fairness rather than resentment toward MGAs themselves, and he described them as bringing genuine value to the market that wouldn't otherwise exist.
"I do think there needs to be a sort of level playing field when it comes to regulation," Jackson said. "The barriers to entry are much lower for MGAs, there's an abundance of capital, and there's a structural advantage that MGAs have over the primaries."
Jackson also pushed back on the idea that insurers themselves are positioned to fill the regulatory gap through their own oversight of delegated authority relationships.
"There's a supposed informal regulation in the relationship between the carrier and the MGA in the process of the authority delegation," Jackson said. "But it's not my job to regulate MGAs. My job is to protect the performance of my business and the balance sheet of my business. My job is not to regulate other entities."
Jackson's support for the idea came with a caveat: brokers are still licensed separately in each jurisdiction they operate in, he said.
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"I wouldn't want to create a situation where all of a sudden for MGAs we have a national approach and for the rest of us we're still in a fragmented regulatory approach," Jackson said. "I would love a situation where we don't have conflicting or different or inconsistent regulators across the markets in which we operate.”
Boadway's response was direct: start somewhere, and let MGAs be the test case for what a more consistent national approach could look like.
"We have to start somewhere. MGAs are a great place to start," Boadway said. "There already is a system that's not built for purpose. It's already a booming segment of the ecosystem. So if we're talking about changing that on a strategic roadmap, we'll go first. Let us show you how it can be done."