The Registered Insurance Brokers of Ontario v. Josephine Bourre, 2026 ONRIBODC 6

REGISTERED INSURANCE BROKERS OF ONTARIO DISCIPLINE COMMITTEE

File No: 6968 Heard: March 26, 2026

Between: THE REGISTERED INSURANCE BROKERS OF ONTARIO and JOSEPHINE BOURRE (Registration No.28672)

Panel Members:

• Rose Cavaliere, Broker and Chair
• Mario Laraia, Broker
• Darren Hamilton, Broker
• Paul Armstrong, Broker
• Frances Kordyback, Public Member

In Attendance:

• Alex Smith, Counsel for RIBO
• Josephine Bourre, 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 March 26, 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. Ms. Bourre was not represented by counsel in this proceeding.

ALLEGATIONS OF MISCONDUCT:

4The allegations of misconduct as stated in the Notice of Hearing dated March 10, 2026, marked as Exhibit #1 to the hearing, were as follows:

1. That Josephine Bourre (hereinafter, the “Licensee”) may be guilty of misconduct as defined by paragraph 8 of Subsection 1 of Section 15 of Ontario Regulation 991, for failure to carry on business in a manner consistent with the provisions of Paragraphs 1, 3, and 4 of the Code of Conduct in Section 14 of Ontario Regulation 991, which provide:

s. 14.1. A member shall discharge the member’s duties to clients, members of the public, fellow members and insurers with integrity.

s. 14.3. A member shall serve the member’s client in a conscientious, diligent and efficient manner and shall provide a quality of service at least equal to that which members would generally expect of a member in a like situation.

s. 14.4. A member shall be both candid and honest when advising the member’s client.

2. That the Licensee may further be guilty of misconduct as defined by paragraph 9 of subsection (1) of section 15, for failure to comply with the provisions of paragraphs 2 and 4 as defined by subsection (4) of section 16 of Ontario Regulation 991, which provide:

s. 16(4)2. The member shall not knowingly fail to make the deposit or investment referred to in paragraph 1 within three banking days after the day the trust money is received.

s. 16(4)4. Subject to paragraph 5, the member shall not, except in accordance with the terms and conditions under which the money was received, I. disburse any money held in trust or the proceeds from any investment in which trust money was invested, or II. withdraw any money from a trust account.

THE LICENSEE’S PLEA:

5The Licensee pled guilty to the allegations set out in paragraphs 1 and 2 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:

6RIBO 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. Josephine Bourre (“Ms. Bourre”) was registered with the Registered Insurance Brokers of Ontario (“RIBO”) in or around May 2006.

2. Ms. Bourre’s registration number with RIBO was R28672. Ms. Bourre is no longer registered with RIBO. Her registration lapsed due to non-renewal and non-payment of fees in October 2022.

3. In accordance with section 5.1 of the Registered Insurance Brokers of Act the Discipline Committee retains continuing jurisdiction over Ms. Bourre.

The Complaint

4. On February 11, 2022, RIBO received a complaint from Mr. Steven Parry, Principal Broker of BrokerLink Inc. (“BrokerLink”) about Ms. Bourre. Mr. Barry alleged that Ms. Bourre received email transfers of premiums payments ("etransfers") from clients of BrokerLink and deposited those payments into Ms. Bourre's personal bank account without placing insurance coverage for these clients.

5. The Complaint was investigated by a RIBO investigator. During the course of the investigation Ms. Bourre admitted to the allegations against her.

Complaints Committee Decision

6. Upon review, the Complaints Committee referred the allegations to the Discipline Committee on December 13, 2022.

7. The specifics of the allegations as referred by the Complaints Committee to the Discipline Committee are that Ms. Bourre may have committed misconduct by breaching the Code of Conduct as follows:

a. Instructing some customers of BrokerLink to submit premium payments to Ms. Bourre’s work and personal email addresses for deposit to her personal bank account;

b. Collecting the premium from some customers of BrokerLink and producing false evidence of insurance;

c. Failing to forward the premium to the brokerage or to the underwriter.

8. It is alleged that in committing the acts described at paragraph 7 above, Ms. Bourre committed misconduct by breaching the following provisions of the Code of Conduct:

14.1: A member shall discharge the member’s duties to clients, members of the public, fellow members and insurers with integrity;

14.3: A member shall serve the member’s client in a conscientious, diligent, and efficient manner and shall provide a quality of service at least equal to that which members would generally expect of a member in a like situation;

14.4: A member shall be both candid and honest when advising the member’s client.

9. It is also alleged that, in committing the acts described at paragraph 7 above, Ms. Bourre committed misconduct by failing to comply with the provisions of paragraphs 2 and 4 of section 16 of Ontario Regulation 991, which are as follows:

10. A Member shall ensure that all trust money he or she receives, whether by cash, cheque or otherwise, is dealt with in accordance with the following:

11. The member shall not knowingly fail to make the deposit or investment referred to in paragraph 1 within three banking days after the day the trust money is received.

12. Subject to paragraph 5, the member shall not, except in accordance with the terms of conditions under which the money was received, i. disburse any money held in trust or the proceeds from any investment in which trust must was invested, or; ii. withdraw any money from a trust account.

Actions of Ms. Bourre

10. At the material time of the incidents described below, Ms. Bourre was an insurance broker conducting business in the hamlet of Mount Elgin, Ontario as an employee of BrokerLink.

11. Client A was a client of BrokerLink. She sought the assistance of Ms. Bourre to arrange for automobile insurance coverage with Aviva Insurance.

12. Client A sent Ms. Bourre multiple etransfers in respect of the premium for the automobile insurance policy. Those etransfers were deposited directly to Ms. Bourre's personal bank account.

13. Ms. Bourre emailed Client A a thirty-day temporary liability slips in relation to each etransfer.

14. In January 2022, Client A contacted Aviva Insurance and was informed that Aviva had no record of Client A’s automobile insurance policy.

15. On January 25, 2022, Client A contacted BrokerLink with regard to the insurance coverage that was to have been arranged by Ms. Bourre.

16. It was subsequently discovered that Client A had been e-transferring Ms. Bourre money on a monthly basis since January 2019 in exchange for temporary liability slips. These temporary liability slips were false and there was no coverage.

Other Clients

17. Over the course of RIBO’s investigation into the allegations surrounding the false liability slips provided to Client A, Ms. Bourre admitted that she collected premiums from a number of other clients and deposited the funds into her personal accounts and/or provided clients with false liability slips.

18. Ms. Bourre admitted to the following:

a) Ms. Bourre collected $1,012.00 from Client B and deposited those funds in her personal account.

b) Ms. Bourre collected funds from Clients C and D, deposited those funds in her personal account, provided the clients with false liability slips and did not bind insurance coverage.

c) Ms. Bourre collected funds from Clients E and F, deposited those funds in her personal account, provided the clients with false liability slips and did not bind insurance coverage.

d) Ms. Bourre provided false liability slips to Clients G and H, and did not bind insurance coverage.

e) Ms. Bourre collected funds from Client I, deposited the funds in her personal account, issued a false liability slip and did not bind coverage.

Admissions and Acknowledgments of Ms. Bourre

19. Ms. Bourre admits and acknowledges she committed the acts set out above.

20. Ms. Bourre further admits and acknowledges that in committing the acts described above she breached sections 14.1, 14.3, and 14.4 of the Code of Conduct and the requirements of paragraphs 2 and 4 of section 16(4) of Regulation 991.

7RIBO counsel 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. The Licensee did not make any further submissions.

FINDINGS AND REASONS FOR DECISION:

8The panel finds 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 14.1, 14.3 and 14.4 of the Code of Conduct, and breach of section 16(4)2 and 16(4)4 of Regulation 991 of RIBA.

JOINT SUBMISSION ON ORDER:

9The Panel was advised that the parties had agreed on the appropriate Penalty in this case and the parties filed a Joint Submission on Penalty (JSP) which was marked as Exhibit 2.

10The Registered Insurance Brokers (“RIBO”) and Josephine Bourre (the “Broker”) jointly request that the Panel of the Discipline Committee impose the penalty of a reprimand as well as Ms. Bourre executing an undertaking prohibiting her from applying for registration with RIBO in the future.

PENALTY ORDER MADE:

11The panel accepted Ms. Bourre’s undertaking to never again seek registration with RIBO as an insurance broker and further orders a reprimand Ms. Bourre for her misconduct.

REASONS FOR PENALTY:

12The 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.

13Based on the agreed statement of facts, Ms. Bourre defrauded clients by taking money into her personal account and issuing fraudulent liability insurance slips where no insurance existed. While there was no evidence in this case of uninsured losses, her clients were left completely unprotected and their assets were at risk.

14In accepting the proposed penalty, the panel considered the severity and nature of the misconduct alleged, the mitigating and aggravating factors, and specific and general deterrence.

15This conduct is one of the most egregious examples of a breach of trust that an insurance broker could perpetrate on their clients and multiple clients were impacted, both of which are aggravating factors.

16The panel agrees with the submissions of RIBO that had the Licensee not resigned her license, the conduct would have resulted in a revocation of her license to act as an Insurance broker in Ontario.

17In terms of mitigating factors, the panel notes that Ms. Bourre cooperated with the RIBO investigation and admitted her conduct, participated in this hearing, negotiating an ASF and JSP, she did not reregister with RIBO and undertook to never reapply to RIBO for licensure in order to conclude this matter.

18In doing so, she spared RIBO and her impacted clients the time and expense of a lengthy contested hearing.

19No discipline history was alleged in this case.

20The panel would have expected to see a substantial fine levied for this conduct, however, the panel is mindful of the mitigating factors and the high bar set by the Supreme Court of Canada in R. v. Anthony-Cook, 2016 SCC 43, to reject a joint submission.

21The Anthony-Cook decision applies to disciplinary bodies in Ontario, pursuant to the Ontario Divisional Court’s decision in Bradley v. Ontario College of Teachers, 2021 ONSC 2303, and this tribunal’s prior decisions accepting its application.

22The panel finds in this case that the failure to include a fine does not bring the administration of justice into disrepute and would not be found to be contrary to the public interest and accepts the Joint Submission on Penalty accordingly.

23The undertaking never to reapply for membership, which is akin to an order of revocation, is a form of specific deterrence and sufficiently protects the public from further misconduct by this former Licensee.

24The goal of general deterrence is met by this public decision which is a reminder to the broker community regarding unacceptable conduct and the associated significant penalties.

Rose Cavaliere, Discipline Committee Chair March 26, 2026