Gap
Photo by Brett Jordan on Unsplash

Jeff Cait’s diagnosis is accurate. The in-force servicing gap is structural. Grace’s story — 45 years of premiums, a tax consequence nobody explained, four options nobody was required to find — is a predictable consequence of how the system was designed.

His prescription falls short.

Voluntary practice standards don’t work when economic incentives run the other way. When compensation is earned at the point of sale and nothing is paid for lifetime servicing, professionalism fills the gap only at the margins. Admirable. Not scalable. Not a consumer protection framework.

The gap Cait identifies requires binding regulatory standards. Canada’s regulatory architecture — federal oversight of insurers, provincial oversight of market conduct — has never resolved who is responsible for what happens to a policyholder after the sale.

Nobody is required to call when the interest rate environment shifts and the policy math changes. Nobody is required to read the contract when a tax slip arrives. The result is a system that regulates distribution and ignores post-sale servicing entirely.

Cait’s policy contract review framework is the right template for what a mandatory standard should require. The question is not whether advisors should adopt it. The question is whether Canadian regulators will ever demand it.