Submissions and Letters


The Co-operators Group Submission to the Ontario Auto Insurance Anti-Fraud Task Force, August 29, 2012

The Co-operators provided our feedback on a number of recommendations in the Ontario Auto Insurance Anti-Fraud Task Force Steering Committee’s Status Update.

In September, 2010, the government introduced a series of changes designed to control costs while ensuring that motorists remain adequately protected. To address the serious problem of fraud, particularly in the Greater Toronto Area, it announced a new Auto Insurance Anti-Fraud Task Force in the 2011 Ontario Budget. The task force’s final report is expected in the fall of 2012.


The Co-operators Group Submission to the House of Commons Special Committee on Co-operatives (COOP), August 7, 2012

A House of Commons Special Committee on Co-operatives was formed as a result of a Liberal Motion. The co-op community was elated by this response (especially in light of the CDI Fund being cut, and further reductions to the Federal Co-op Secretariat). The Co-operators participated in the public hearings and also provided a written submission.


The Co-operators Group Written Submission to the Canadian Council of Insurance Regulators in Response to their Electronic Commerce in Insurance Products Discussion Paper, March 28, 2012.

The Co-operators is pleased to provide insight into our experiences and policies regarding consumer protection and whether or not consumers are better protected if the designation of beneficiaries and the termination of an insurance policy continue to be paper transactions.

While the distribution of insurance products via the Internet may offer many advantages to both providers and consumers alike, new ways of doing business can equally involve risks to both its initiators and its users.


The Co-operators Limited Written Submission to the Canadian Council of Insurance Regulators Credit Scoring Working Group, Monday, August 8, 2011.

The Co-operators was pleased to provide comments to CCIR’s issues paper “Use of Credit Scores by Insurers”, and insight into our experiences and policies regarding the use of credit score as a rating factor for home, auto and farm insurance.

Our submission hoped to address CCIR’s concerns that particular use and misuse of credit scores could impede marketplace outcomes such as fair treatment of consumers; disclosure of information to enable consumers to make informed choices; compliance with the law; and good corporate governance.


The Co-operators Group Limited Written Submission to the Department of Finance: “Developing a Framework for the Demutualization of Federally Regulated P&C Mutual Insurance Companies”, Wednesday, July 27, 2011.

The Co‑operators Group Limited was pleased to participate in the public consultations launched by the Minister of Finance to support the development of a framework for the orderly and equitable demutualization of federally regulated property and casualty (P&C) mutual insurance companies. 

In its issues paper, the Department of Finance set out specific questions for comment. We have provided our perspective accordingly and have also attached proposed regulations based on Can. Reg. 99-128 — Mutual Company (Life Insurance) Conversion Regulations within the submission.

The Co‑operators supports the position of the Canadian Association of Mutual Insurance Companies (CAMIC) that a small minority of policyholders, board members, senior management, brokers, and professional consultants should not receive windfall benefits from the demutualization of a property and casualty mutual insurance company.