Rule Amendment Consultation

Licence Renewal

Creation of Rule 4(4)(b.1)
Amendment of Rule 4(4)(c), (d) 

Overview
This rule change would provide a mechanism so that a licensee cannot continue to practice without being aware of and meeting annual licence requirements. It also clarifies the parameters for licence cancellation and application of the late fee due to non-completion of the renewal process and aligns the language with commonly used terminology.

Current status

Initial stakeholder consultation on the proposed rule amendment was conducted between March 28-June 1, 2022.

In response to stakeholder feedback, the Insurance Council has revised the wording for this proposed rule amendment and is now consulting on this revision, as required by regulation.

Consultation is open until September 30, 2022. Comments may be submitted in writing to rules.consult@insurancecouncilofbc.com.

What’s changed and why?

During consultation, the Insurance Council heard stakeholder concerns regarding Rule 4(4)(b.1), that the proposed requirement for licensees to submit proof of having met continuing education (CE) requirements could be onerous, requiring considerable administrative effort.
 
In response, updates to the proposed Rule 4(4)(b.1) have been made to address these concerns, changing the rule wording from “proof” to “confirmation.” This revised wording reduces the effort needed to meet the reporting requirement; licensees would complete a declaration confirming their compliance with CE requirements rather than submitting course documents.
 
Revised wording for Rule 4(4)(b.1), (c) and (d) also clarifies that licensees will not be able to complete licence renewal if they do not provide their confirmation of CE and E&O insurance for the licence year.
 
These changes are responsive to stakeholder input and still meet the intended outcome of the rule change: to prevent inadvertent breaches of CE rules, and prevent licence renewal by individuals who have not met the CE and E&O requirements for licensure.
 

How to read the proposed wording changes to the Rules:

  • The revised wording for consultation is highlighted in grey. Other changes shown were previously consulted on. 
  • Bolded text represents the addition of proposed wording.

  • Text that has been struck out represents wording proposed for removal.

See the proposed Rule wording (.pdf)

About the Proposed Rule Amendments

The information below describes the rule amendments as originally proposed during the March 28-June 1 consultation.  (Published March 28, 2022)


What is the proposed change? 

This change expands on wording in Rule 4(4)(b) regarding licence renewal, which states that a licensee must submit “supporting documentation” as a part of the process. The addition of 4(4)(b.1) specifies that licensees must “submit annual proof of having met their continuing education (CE) requirements and annual confirmation of having met their errors and omissions (E&O) insurance requirements, in the form required by Council.” This annual proof of CE completion would consist of a log or a list of completed CE courses provided to the Insurance Council through online means (See proposed changes - “What’s changed and why”). The process for providing confirmation of E&O insurance through completing a declaration during the annual licence renewal process would remain unchanged. 

The change to Rule 4(4)(c) and (d) clarifies that the late fee for annual licence renewal applies to the entire licence renewal process, not just the payment of the fee.

The change to Rule 4(4)(d) also replaces the word “terminated” with “cancelled” in reference to licensure, which is aligned with the language in the Financial Institutions Act.
 

What is the rationale?

The existing Rule 4(4)(b)’s requirement for “supporting documentation” to be submitted for annual licence renewal lacks transparency regarding what type of documentation the Insurance Council requires licensees to submit to renew their licences on an annual basis. These proposed changes and additions provide more clarity.

Furthermore, under the Council Rules, licensees are required to complete CE and carry E&O insurance; however, on an annual basis, the Insurance Council finds that licensees often inadvertently breach Council Rules due to a lack of understanding about the requirements. Typically, these licensees are found to have an insufficient amount of CE credits for one or more years, and in some cases also do not have E&O insurance in place. Thus, can result in the licensee having to undergo the disciplinary process.

The requirements to carry E&O insurance and maintain professional competence by completing annual CE are in place to protect consumers. Requiring that licensees demonstrate that they have met the CE requirements as a part of licence renewal, benefits both public protection and licensees as it will reduce the number of licensees who inadvertently breach the rules due to a lack of awareness or understanding of these requirements. Licensees would not be able to continue to hold a licence without meeting these requirements.

Provide feedback about proposed changes to the Council Rules

Provide your input about the revised rule amendments to 4(4)(b), (c) and (d) by September 30, 2022.


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