File No: 262344

REGISTERED INSURANCE BROKERS OF ONTARIO DISCIPLINE COMMITTEE

Between:

THE REGISTERED INSURANCE BROKERS OF ONTARIO

and

TITILAYO “LUCIA” OWANUBI (Registration No. 47446 - INACTIVE)

Heard: APRIL 23, 2026 PANEL MEMBERS:

• Rose Caveliere, Broker and Chair

• Mario Laraia, Broker

• Mike Moyer, Broker

• Darren Hamilton, Broker

• Josephine Atri, Public Member

IN ATTENDANCE:

• Alex Smith, Counsel for RIBO

• Titilayo “Lucia” Owanubi, 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 April 23, 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 Titilayo Lucia Owanubi and counsel for RIBO.

ALLEGATIONS OF MISCONDUCT:

4The allegations of misconduct as stated in the Notice of Hearing, which was made Exhibit #1, dated the 15^th^ day of April 2026, were as follows:

1. That Titilayo Lucia Owanubi (hereinafter, the Licensee”) may be guilty of misconduct pursuant to Ontario Regulation 991 Code of Conduct, section 15(1)(9) – failure to comply with the provisions of the Act, the Regulation, and the By-Laws of the Corporation for failing to act with integrity in accordance with section 14(1) of the Code of Conduct by submitting false health claims under her employer’s benefits plan.

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

THE LICENSEE’S PLEA:

5The Licensee pled guilty to the allegations set out in paragraph 1 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

2. Titilayo Lucia Owanubi (the “Broker”) was registered with the Registered Insurance Brokers of Ontario (“RIBO”) in or around January 2020.

3. The Broker’s registration number with RIBO is 47446. The Broker’s current license status with RIBO is as a Level 1 broker.

4. On November 7, 2024, RIBO received a complaint (the “Complaint”) from Pamela Derkson (the “Complainant”), Licensee and Principal Broker at NFP Canada Corp. (“NFP”) regarding the Broker. The Broker was an employee of NFP at the material time.

Key Facts

5. On October 25, 2024, NFP was notified by Sun Life Insurance Company (“Sun Life”), their group benefits provider, that after a preliminary investigation, they had concerns that the Broker may have submitted false health claims under NFP’s group benefits plan.

6. As set out in letters to the Broker dated October 22, 2024 and November 6, 2024, Sun Life found that the Broker submitted 39 false claims to her workplace benefits plan between February 20, 2024 and June 20, 2024. Sun Life verified this by contacting the service providers, who confirmed that they did not provide the services claimed. Sun Life advised the Broker that it had paid her a total of $4,799.47 for these false claims and that this amount must be repaid in full.

7. In an email to Sun Life dated October 24, 2024, the Broker expressed remorse for her actions, acknowledged that she did not have proof for the claims she submitted, and stated that she wished to pay the money back to Sun Life.

8. In emails exchanged on November 6, 2024, the Broker and Sun Life worked together to establish an agreeable re-payment plan.

Response to RIBO Investigation

9. The Broker fully cooperated with RIBO’s investigation and acknowledged her wrong doing early in the investigation process.

10. In an email dated December 9, 2024, the Broker confirmed to the RIBO Investigator that she did not have proof of treatment for the claimed health benefits. The Broker explained that her judgment was severely affected at the time she made the false claims, as she had been experiencing significant family and financial challenges. The Broker expressed remorse and assured the RIBO Investigator that she would not commit such acts in the future.

Admissions of the Broker

11. Section 14(1) of Regulation 991 to the Registered Insurance Brokers Act states: “A member shall discharge the member’s duties to clients, members of the public, fellow members and insurers with integrity.”

12. The Broker admits and acknowledges that by submitting false health claims under her employer’s benefits plan, she did not discharge her duty to members of the public, fellow members or insurers with integrity.

13. The Broker admits and acknowledges that her actions, as described above, were contrary to Reg. 991, s. 14(1).

14. If the Broker were to testify, she would state that she is remorseful for her actions and has learned from them.

15. The Broker is a member in good standing with RIBO and has no record of any past complaints or discipline.

SUBMISSIONS OF THE PARTIES

7RIBO counsel submitted that the facts agreed to provided sufficient evidence for the Panel to make a finding that the Licensee was guilty of misconduct for breach of sections 14(1) RIBA General Regulation 991 and that a finding of misconduct under section 15(1)(9) be made.

8The Licensee did not provide any submissions.

FINDINGS AND REASONS FOR DECISION:

9The Panel agrees with the submissions of RIBO Counsel that there is sufficient evidence in the ASF to support the finding of guilt and we find the Licensee guilty of misconduct under section 15(1)(9) for breach of section 14.1 of the Code of Conduct in RRO 991.

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 Titilayo Lucia Owanubi (the “Broker”) jointly request that the Panel of the Discipline Committee impose the following penalty:

1. The Broker will be reprimanded;

2. The Broker shall be suspended for a period of one (1) month from the date of the order of the Discipline Committee;

3. Within six (6) months of the date of the order of the Discipline Committee, the Broker shall complete three (3) hours of RIBO accredited ethics education. This requirement is in addition to the annual Continuing Education obligations of the Broker; and

4. The Broker shall report completion of the educational requirement set out at paragraph 3 above to RIBO’s Compliance Administrator email.

PENALTY ORDER MADE:

12The Panel accepted the JSP of the parties and accordingly makes an Order, effective today, as follows;

1. The Broker will be reprimanded;

2. The Broker shall be suspended for a period of one (1) month from the date of the order of the Discipline Committee;

3. Within six (6) months of the date of the order of the Discipline Committee, the Broker shall complete three (3) hours of RIBO accredited ethics education. This requirement is in addition to the annual Continuing Education obligations of the Broker; and

4. The Broker shall report completion of the educational requirement set out at paragraph 3 above to RIBO’s Compliance Administrator email.

REASONS FOR PENALTY:

13The 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.

14While the Panel was concerned with the penalty, it did not meet the high bar for rejection set by the Supreme Court of Canada in R. v. Anthony-Cook, 2016 SCC 43 which applies to disciplinary bodies in Ontario, including this one, pursuant to the Ontario Divisional Court’s decision in Bradley v. Ontario College of Teachers, 2021 ONSC 2303.

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

16The misconduct was very concerning to the Panel given the ethical issues the conduct raised. Registered Insurance Brokers are in a position of trust with their clients, often acting as a fiduciary for their clients, and they must act at all times with integrity and good faith.

17The conduct here did not involve a client transaction, however, while the broker’s primary responsibility is to their client, brokers are intermediaries and are required to act with integrity in dealings with insurance companies. The Licensee failed to do so repeatedly in this case. The repeated nature of the conduct was an aggravating factor in this case.

18The Licensee’s judgment appeared to be clouded by personal issues and she admitted the conduct early on in the investigation and arranged a re-payment plan to compensate the insurer for claims falsely submitted. This was a mitigating factor considered by the Panel.

19The reprimand, suspension and educational requirements serve to educate and rehabilitate the Licensee and deter further conduct of this nature.

20The goal of general deterrence is met by this public decision which is a reminder to the broker community at large that they must act with integrity in all dealings, including dealings in their own personal insurance matters.

Rose Caveliere, Discipline Committee Chair April 23, 2026