Continuing Education: Just Do It! For Real!

November 8, 2019 Paul Emile Trudelle Continuing Legal Education Tags: , 0 Comments

Most professions require their members to complete a certain amount of continuing education. For example, lawyers in Ontario are required to complete 12 hours of Continuing Professional Development, with a minimum of 3 hours of Continuing Professional Development having certain “professionalism” content.

Failure to complete the required continuing education can lead to suspension. Often, professionals scramble at the last minute to complete their continuing education requirements.

In recent disciplinary proceedings, insurance agents had their insurance agent licences revoked where they did not complete the required continuing education, and submitted fraudulent continuing education certificates

In both D’Mello v. Ontario (CEO of FSRA),  2019 ONFST 20 and Sohi and Sandhu v. Ontario (Superintendant Financial Services), 2019 ONFST 9, insurance agents purchased continuing education certificates from a Mr. Rutledge, a continuing education teacher. The certificates confirmed that the agents received 30 hours of continuing education. However, the teacher did not provide the agents with any training or educational materials. The agents paid the teacher $100 for the certificates.

In the Sohi and Sandhu proceeding, the Financial Services Tribunal refers to the evidence of Mr. Rutledge. It is said that while he was at one point a continuing education teacher, he stopped teaching long before the incidents in question. When contacted by a former student or person referred by a former student, he would “help” them with their licence renewals by selling them the false continuing education certificates for courses they did not actually study for or take.

The Tribunal held that the agents knowingly submitted false continuing education certificates and intentionally misled the Financial Services Commission of Ontario. Their licences as insurance agents (all three had been agents for 20 years or more) were revoked.

The moral of the story is obvious: complete your continuing education. Actually complete it!

Also, complete it early. As stated in the D’Mello decision, while failing to complete your continuing education does not automatically constitute incompetence, leaving it to the last minute constitutes “brinksmanship”: in the case of the insurance agents, “leaving 30 hours of CE compliance to late in the two year cycle would seem to demonstrate a lack of good planning”.

For our blog from 2010 on the introduction of Continuing Legal Education requirements, see here.

Thank you for reading.

Paul Trudelle

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