The Unlicensed Quoter
Priya is a newly licensed Level 1 broker at a three-person brokerage in Mississauga. In March the principal broker, Mr. Chen, left abruptly; the brokerage now relies on a temporary principal broker who works remotely from Ottawa. The owner, Dino, tells Priya to start 'training' his nephew Marco, who has no RIBO licence, by letting Marco answer incoming calls, quote auto premiums in the rating software, and email certificates of insurance to clients. Dino says Marco is 'just helping out' and that Priya's name and licence number can appear on the documents. Priya also notices that the brokerage trust account has not been reconciled since January and that Dino has used it to pay office rent. Dino asks Priya to sign a backdated supervision log showing he supervised Marco every day since April.
1. Identify the RIBO licensing and regulatory problems in Dino's instructions and explain which of them Priya may lawfully carry out, if any.
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Unlicensed activity. Under RIBO's licensing framework, only a licensed broker or agent may solicit, negotiate, or transact insurance. Quoting a premium and emailing a certificate of insurance are not clerical acts; they are the business of insurance. Marco may do only back-office work that does not involve advising, quoting, or binding. Priya may not lend her name or licence number to Marco; that is 'fronting' and exposes both of them to unlicensed-activity sanctions.
Principal broker and supervision. Every brokerage must have a principal broker accountable for supervision and compliance. A remote temporary principal broker may be permitted only if RIBO has approved the arrangement, but supervision cannot be fictional. A backdated supervision log is a false record; signing it would be professional misconduct.
Trust account. Premiums held for insurers are trust funds. Paying office rent from the trust account is misappropriation, not a timing issue, and the missing monthly reconciliations are a separate breach.
None of Dino's instructions can lawfully be carried out by Priya.
2. What should Priya do to comply with her professional obligations and protect herself, and what are the likely consequences if she follows Dino's instructions?
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Priya should refuse each instruction in writing, keep copies, and escalate. First, she should tell Dino and the temporary principal broker that she will not permit Marco to quote, bind, or issue certificates, will not lend her licence, and will not sign a backdated log. Second, she should ask for a written remediation plan for the trust account and, if the principal broker is complicit or absent, report the trust shortage and unlicensed activity to RIBO. RIBO's Code of Ethics requires brokers to act with integrity and to report conduct that harms the public. Third, she should not touch the trust account and should preserve records.
If she complies, she risks licence suspension or revocation, fines, personal liability, denial of E&O coverage for intentional or dishonest acts, and possible criminal charges for trust misappropriation. Reporting is also the best protection for her own licence.