The Financial Services Regulatory Authority of Ontario (FSRA) has issued compliance orders against Assureway Protection Corporation and its sole officer and director, Shiraz Hussain, after finding they carried on the business of insurance without a license and engaged in unfair or deceptive acts or practices.
FSRA determined that Assureway Protection and Hussain acted as an insurer or engaged in acts constituting the business of insurance without a license, contrary to Ontario's Insurance Act. The regulator also found they engaged in an unfair or deceptive act or practice (UDAP).
“FSRA will not tolerate conduct that places consumers at risk or undermines confidence in Ontario's insurance market,” said Elissa Sinha, director of litigation and enforcement at FSRA. “This compliance order protects consumers, requires corrective steps, and reinforces that past undertakings and regulatory commitments must be respected.”
Assureway Protection and Hussain did not request a hearing or contest the regulator’s proposal, and the orders were imposed on that basis.
The case follows earlier concerns around a product associated with Assureway.
Lloyd’s has issued a public advisory stating that a product marketed as “TruGap Protection – AssureWay” is being linked to Lloyd’s, but that Lloyd’s has provided no capacity for that product and has had no involvement with any coverage associated with it since 2020. The advisory directs any policyholders with concerns about the product’s legitimacy to contact FSRA to submit a complaint or seek guidance.
The combination of an unlicensed entity holding itself out as an insurer and the suggestion of Lloyd’s backing where none exists illustrates the type of conduct FSRA is targeting under its UDAP regime, particularly around misrepresentation of capacity and regulatory status.
FSRA’s reliance on Authority Rule 2020‑002 underlines the growing importance of the UDAP framework in Ontario insurance enforcement. The rule, which took effect on April 1, 2022, replaced the previous UDAP regulation and gives FSRA direct rule‑making authority to define and enforce unfair or deceptive practices under the Insurance Act.
Unlike the older, more prescriptive regulation, the UDAP rule is outcomes‑focused and applies across life, health, P&C and other insurance segments. It captures a wide range of conduct, including misrepresentation of products or capacity, misleading advertising, inadequate disclosure of coverage limits and exclusions, and abusive sales or claims practices.
Since its creation in 2019, FSRA has made visible enforcement and consumer‑facing transparency a priority, maintaining an online registry of enforcement actions and issuing regular warnings about unlicensed entities. It has also signaled a tougher stance on conduct risk through thematic reviews, including work on life and health MGAs and “tiered‑recruitment” distribution models, where it has identified weaknesses in controls designed to ensure fair treatment of customers.
The Assureway orders highlight several points of regulatory focus. Products suggesting backing from well‑known markets such as Lloyd’s, when no actual capacity is in place, are likely to attract scrutiny. Carriers and coverholders will need to monitor how their names and brands are used by distributors and third parties to avoid being associated with unauthorized offerings.
The case also reinforces FSRA’s attention to the licensing perimeter. The regulator continues to focus on entities that appear to be “in the business of insurance,” whether by underwriting, issuing contracts, collecting premiums or otherwise assuming risk without authorization. Firms that blur the line between service provision and insurance can expect increased regulatory interest.
More broadly, the UDAP rule means even licensed entities may face enforcement if their distribution, marketing or claims practices lead to consumer harm or reasonable confusion. Recent FSRA guidance stressed that the authority will look at outcomes for customers, not just formal compliance with narrow technical rules.
