Breaches of periodic or continuing obligations are ones to
which the principle has been applied.
 CNR submits this situation is different. From 2003
onward, Cora’s claim has been consistently rejected by the CNR
because of the 1992 divorce. CNR has relied on rule 6(6)
throughout. Its position has never wavered or changed. In this
case, there has not been — nor could there be — any new fact
which could have affected either party’s legal position. I agree.
 In Richards v. Sun Life Assurance Co. of Canada, 
O.J. No. 4574, 2016 ONSC 5492 (S.C.J.), the insurer paid short-
term disability benefits but required further information before
paying anything more. When the inquiry was not answered, the
insurer closed its file. The insured commenced an action about
three years later. The claim was met with a limitation defence.
The insurer asked the court to dismiss the action summarily. In
rejecting the insured’s argument that a rolling limitation period
applied, Bale J. wrote in part, at para. 26:
A rolling limitation period may apply to claims for periodic payments, in
cases where the issue is whether certain payments to which the plaintiff is
entitled have been made . . . as opposed to cases where the issue is whether
the plaintiff was entitled to the periodic payments in the first place. In the
former . . . the material facts will have arisen on a periodic basis, and it will
not be unfair to require a defendant to litigate those facts during the appli-
cable limitation period following the date upon which an individual payment
became due. However, in the latter . . . the material facts will have arisen at
the time the plaintiff alleges . . . she first became entitled to periodic pay-
ments, and it would be unfair to require the defendant to litigate those facts,
for a potentially unlimited period of time.
 The British Columbia Court of Appeal reached the same
conclusion in Balzer v. Sun Life Assurance Co. of Canada, 
B.C.J. No. 1170, 2003 BCCA 306. The court held that the statu-
tory clock for the commencement of actions starts the moment
a party clearly and unequivocally denies the claimant has any
contractual entitlement. At para. 40, Huddart J.A. explained:
It is at denial of coverage or termination of benefits that an insured would
have reason to sue the insurer. That is when a limitation period should
begin to run, not while benefits are being received, not on some later date
when an insured decides to file a proof of loss or commence an action.
 A conclusion that Cora’s claim is too late is consistent
with the objectives of statutes establishing limitation periods.
They aim “to balance the right of claimants to sue with the right
of defendants to have some certainty and finality in managing
their affairs”: York Condominium Corp. No. 382 v. Jay-M Holdings Ltd. (2007), 84 O.R. (3d) 414,  O.J. No. 240 (C.A.), at
para. 2. The documentary record in this case demonstrates that
the administrator of the plan denied overtures made in 2003,