AND WHEREAS the Examination found that Sovereign had developed and implemented some controls to prevent unlawful and improper sales of supplemental automobile insurance products but that these controls were insufficient or absent in all areas under review; AND WHEREAS the Superintendent of Financial Institutions (the "Superintendent") is of the opinion, based on the Examination, that Sovereign sold vehicle warranty insurance in B.C. without being authorized to do so under the FIA, thereby contravening sections 75 and 159(1) of the FIA; AND WHEREAS the Superintendent is of the opinion, based on the Examination, that Sovereign failed to comply with section 91 of the FIA by not disclosing its identity consistently in all public facing materials; AND WHEREAS the Superintendent is of the opinion, based on the Examination, that Sovereign failed to comply with section 93 of the FIA, as a result of its intermediary providing unfair, misleading, or deceptive documents in the B.C. marketplace; AND WHEREAS Sovereign acknowledges that there were deficiencies in its oversight and controls over the distribution of supplemental automobile insurance products in B.C., and Sovereign is and will continue taking remedial actions to address the concerns and recommendations included in the Report; THEREFORE, the Superintendent considers it appropriate to enter into a Voluntary Compliance Agreement with Sovereign, pursuant to sections 158(1) and 244(2) of the FIA; ACCORDINGLY, by October 30, 2024, Sovereign undertakes the following: 1. To review and strengthen its internal controls to ensure it complies with legislative requirements set out in the FIA and other relevant regulations in place in B.C. 2. To establish monitoring and oversight controls over intermediaries that ensure outsourced functions are managed effectively and customers are treated fairly throughout the product lifecycle, including but not limited to: Outsourcing agreements are comprehensive and have clear, enforceable roles and responsibilities for each party; If any intermediaries are assigned the responsibility to train distributors, intermediaries are proactively monitored to ensure they fulfill delegated responsibilities;
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