CRA states that a no-cost endorsement to a life insurance policy to add benefits could be a disposition

CRA did not concede that an endorsement to provide a new benefit under an exempt life insurance policy for no cost and without any underwriting requirement, to a defined set of policyholders, would not constitute a disposition, and instead stated that whether there was a disposition turned on whether the changes made were “so fundamental as to go to the root of the policy” and that “[w]here a policy is silent with respect to a particular type of change, the amending of the policy, if a material change, could result in a disposition of the existing policy and the acquisition of a new policy at law.”

Neal Armstrong. Summary of 28 September 2023 CLHIA Roundtable Q. 1, 2023-0971701C6 under s. 148(9) – disposition.