Registered Insurance Brokers of Ontario v. Sandhu, 2026 ONRIBODC 2

File No: 6777

REGISTERED INSURANCE BROKERS OF ONTARIO

DISCIPLINE COMMITTEE

Between:

THE REGISTERED INSURANCE BROKERS OF ONTARIO

and

KULDIP SANDHU (Registration No.14454)

Heard: January 22, 2026

PANEL MEMBERS:

• Rose Cavaliere, Chair
• Darren Hamilton, Broker
• Paul C. Armstrong Broker
• Mario Laria, Broker
• Josephine Atri, Public Member

IN ATTENDANCE:

• Alex Smith, Counsel for RIBO
• Kuldip S. Sandhu, Licensee
• Heather Vaughan, Discipline Committee Independent Legal Counsel

DECISION AND REASONS

INTRODUCTION:

1This matter was referred to the Discipline Committee (the “Panel”) by the Complaints Committee in accordance with the Registered Insurance Brokers Act section 18.

2This matter was convened and heard virtually on January 22, 2026 pursuant to the Registered Insurance Brokers Act, R.S.O. 1990, c. R.19, (RIBA) and the Statutory Powers Procedure Act, R.S.O. 1990, c. S.22 and regulations thereunder and was governed by the Rules of Procedure of the Discipline Committee of the Registered Insurance Brokers of Ontario (RIBO).

3The hearing proceeded by way of an Agreed Statement of Facts (ASF) and a Joint Submission on Penalty (JSP) proposed by the parties.

ALLEGATIONS OF MISCONDUCT:

4The allegations of misconduct as stated in the Notice of Hearing dated the 5^th day of January 2026, were as follows:

1. That Kuldip S. Sandhu (hereinafter “Licensee”) may be guilty of misconduct pursuant to Ontario Regulation 991, section 15(1) paragraphs 11 and 14 which provide that misconduct includes:

Section 15(1) 11- Being convicted, after the first date of October 1981, of a criminal offence or an offence under the Insurance Act, whether or not the offence was committed before the 1^st day of October 1981.

Section 15(1) 14- Providing false or misleading information to the Corporation.

5The Notice of Hearing dated January 5, 2026 was marked as Exhibit 1. The Panel confirmed proper service of these documents in accordance with the RIBA and Rules of Procedure.

THE LICENSEE’S PLEA:

6The Licensee pled guilty to the allegations set out in paragraphs 15(1) 11 and 14 of the Notice of Hearing. The Panel conducted an oral plea inquiry and was satisfied that this guilty plea was free and voluntary.

AGREED STATEMENT OF FACTS:

7RIBO and the Licensee advised the Panel that an agreement had been reached on the facts and filed an ASF which was accepted by the panel and filed as Exhibit 2. The relevant facts in the ASF provide as follows:

Background

1. Kuldip S. Sandhu (“Mr. Sandhu” or the “Broker”) was registered with the Registered Insurance Brokers of Ontario (“RIBO”) in or around 1993.

2. The Broker’s registration number with RIBO is R14454. The Broker’s current licence status with RIBO is as a Level 1 broker.

3. At the material time the Broker was a registered insurance broker in the employ of JSP Insurance and Financial Services.

4. Up until June 5, 2019, Mr. Sandhu was also a registered insurance agent under the Insurance Act, R.S.O. 1990, c.I.8 (“Insurance Act”).

Key Facts

5. Upon review of the Canadian Insurance Services Regulatory Organizations website in late 2019 it came to RIBO’s attention that the Financial Services Tribunal (“FST”) had revoked the Broker’s insurance agent license.

6. Mr. Sandhu did not report the discipline proceedings or conviction under the Insurance Act, as required by Section 15(1).11 of Ontario Regulation 991 (the “Regulation”), made under the Registered Insurance Brokers Act, R.S.O. 1990,c. R-19 (the “Act”). Instead he indicated on his RIBO renewal that he was not subject to any discipline proceedings, thus providing false information to RIBO contrary to Section 15(1).14 of the Regulation.

FST Proceeding

7. The issue before the FST was whether Mr. Sandhu had provided fraudulent certificates of Continuing Education Credits to the Financial Services Commission of Ontario (“FSCO”), as it was then. The allegation was that Mr. Sandhu had not completed the required continuing education, but instead had paid a retired Continuing Education instructor to provide the continuing education certificates without actually taking the courses.

8. On July 5, 2018, the Superintendent of Financial Services issued a Notice of Proposal to Revoke Mr. Sandhu’s licence.

9. Mr. Sandhu requested a hearing. The hearing before the FST was held on April 12, 2019. Mr. Sandhu did not attend the Hearing.

10. On April 24, 2019, the FST issued its Reasons for Decision ordering the revocation of Mr. Sandhu’s licence. The FST found Mr. Sandhu had committed the alleged acts set out in paragraph 7 above.

11. Mr. Sandhu did not appeal the decision of the FST.

Failure to Disclose to RIBO

12. On his 2019/2020 renewal, Mr. Sandhu indicated “No” to the question of whether he was subject to “any Disciplinary action with respect to any licence”.

13. This was not correct as Mr. Sandhu had been subject to disciplinary proceedings and sanction by the FST.

Time Between FST and RIBO Proceeding

14. Due to complications and issues created by the COVID-19 pandemic the investigation of this matter was completed in the summer of 2021 and this matter was referred to the Discipline Committee by the Complaints Committee in October of 2022. A Pre-Hearing Conference in this matter was held in July 2024.

15. Since early 2023, both before and after the Pre-Hearing Conference, the parties have engaged in numerous communications in an effort to resolve this matter by way of agreement.

16. This Agreed Statement of Facts is the result of those ongoing communications.

Issues Before the Discipline Committee

17. Whether Mr. Sandhu submitted false continuing education certificates to FSCO is not an issue before the Discipline Committee.

18. The issues before the Discipline Committee are:

(a) Was Mr. Sandhu convicted of an offence under the Insurance Act?

(b) Did Mr. Sandhu provide false and/or misleading information to RIBO?

Admissions of the Broker

19. In accordance with Section 15(1).11 of the Regulation, professional misconduct includes: “Being convicted, after the 1st day of October 1981, of a criminal offence or an offence under the Insurance Act, whether or not the offence was committed before the 1st day of October, 1981.”

20. If the Broker were to testify he would state that he did not knowingly provide FSCO with false educational certificates.

21. The Broker admits and acknowledges, however, that he was convicted of an offence under the Insurance Act.

22. The Broker admits and acknowledges that he breached Section 15(1).11 of the Regulation.

23. In accordance with Section 15(1).14 of the Regulation, “Providing false or misleading information to the Corporation”, constitutes misconduct.

24. If the Broker were to testify he would state that he did not intend to mislead RIBO and that his failure to acknowledge the FST proceeding and its outcome was an oversight.

25. The Broker admits and acknowledges, however, that he did fail to report the FST proceeding to RIBO and that this constitutes a breach of Section 15(1).14 of the Regulation.

26. The Broker is a member in good standing with RIBO and does not have a record of any past complaints or discipline.

SUBMISSIONS OF THE PARTIES

8RIBO counsel and Licensee both agreed that there was a breach of the code of conduct expected of Licensees. The parties submitted that there was sufficient evidence before the panel to make a finding that the licensee was guilty of misconduct for breach of sections 15(1) paragraphs 11 and 14 of RIBA General Regulation 991.

FINDINGS AND REASONS FOR DECISION:

9The panel agrees with the submissions of the parties that there is sufficient evidence in the ASF to support the finding of guilt and we find the Licensee guilty of misconduct for the breach of sections 15(1) paragraphs 11 and 14 of Regulation 991 of RIBA.

JOINT SUBMISSION ON ORDER:

10The Panel was advised that the parties had agreed on the appropriate Order in this case and the parties filed a Joint Submission on Penalty (JSP) which was marked as Exhibit 3.

11The Registered Insurance Brokers (“RIBO”) and Kuldip S. Sandhu (the “Broker”) jointly request that the Panel of the Discipline Committee impose the following penalty:

1. The Broker will be reprimanded.

2. Within six (6) months of the date of the order of the Discipline Committee, the Broker shall complete two hours of RIBO accredited ethics education. This requirement is in addition to the annual Continuing Education obligations of the Broker.

3. The Broker shall report completion of the educational requirement set out at paragraph 2 above to the RIBO’s Compliance Administrator by way of email to zhina@ribo.com.

PENALTY ORDER MADE:

12The panel accepted the JSO of the parties and accordingly makes an Order that the member be reprimanded, that within six (6) months of the date of the order of the Discipline Committee, the Broker shall complete two hours of RIBO accredited ethics education. This requirement is in addition to the annual Continuing Education obligations of the Broker.

13The Broker shall report completion of the educational requirement set out at paragraph 2 above to the RIBO’s Compliance Administrator by way of email.

REASONS FOR PENALTY:

14The Registered Insurance Brokers of Ontario (RIBO) is a self-governing organization that regulates the licensing, professional competence, ethical conduct and insurance related financial obligations of all independent general insurance brokers in the province of Ontario to ensure the public is served and protected accordingly.

15In accepting the proposed penalty, the Committee considered the severity and nature of the misconduct alleged, the mitigating and aggravating factors, rehabilitation of the licensee and specific and general deterrence.

16The Panel was concerned regarding the seriousness of the underlying conduct regarding the submission of false continuing education certificates to FSCO but accepts that this was not an issue before this Discipline Committee. The only issues under consideration was whether Mr. Sandu was convicted of an offence under the Insurance Act and whether Mr. Sandhu provided false and misleading information to RIBO.

17Providing timely, accurate and complete information to a regulatory body is an essential duty of regulated professionals. RIBO, like other regulators, relies on the candor of information provided by its licensees for effective regulation and should not be required to review the public decisions of other regulators to identify reporting failures as they did in this case.

18The goal of specific deterrence is served by the reprimand and educational requirements which will educate and rehabilitate the Licensee and deter further conduct of this nature by this Licensee.

19The goal of general deterrence is met by this public decision which is a reminder to the broker community at large that they must cooperate fully with their regulator and provide accurate information during their annual renewal.

Rose Cavaliere, Discipline Committee Chair January 26, 2026