In the long-waited appeal decision from the Financial Services Commission of Ontario (“FSCO”), Delegate Evans in Perth v. Surani (FSCO Appeal P16-00022) confirmed that a self-employed insured’s post-accident business income is deductible from their income replacement benefits for the purposes of paragraph 7(3)(b) of the Statutory Accident Benefits Schedule – Effective September 1, 2010, O. Reg. 34/10 (“SABS”). Section 7(3)(b) provides that an insurer may deduct from an income replacement benefit: “70% of any income from self-employment earned by the insured person after the accident and during the period in which he or she is eligible to receive an income replacement benefit.”