COMPLAINT HANDLING –

POLICIES & PROCEDURES

The Compliance Officer is the person in charge and responsible to:

 Act as the respondent with the AMF
 Deliver an acknowledgement of receipt and notice to the complainant
 Review every complaint in an equitable manner and respond
 Transfer the file to the AMF at the complainant’s request
 Prepare and send a complaint file report biannually to the Autorité des marchésfinanciers (AMF) using the Complaint Reporting System (CRS)
 Train staff/advisors annually

Section 1:

Objective:

To ensure complaints are resolved in a fair, equitable and timely manner.

Complaint definition:

A complaint is the verbal or written expression of one of the following three elements:
 a reproach against the firm;
 the identification of real or potential harm that a consumer has sustained or may sustain;
 a request for remedial action.

Minor issues related to normal business activities that can be resolved with informal steps are
not considered a complaint unless the consumer has filed a formal complaint.

Creation of complaint file:

A separate complaint file must be created for each complaint and contain the following:
 written complaint – If a complaint is received verbally, the complainant is requested to
submit it in written format. If the complainant is unwilling to provide the complaint in
writing, the person handling the complaint must document it for filing purposes.
 documents sent by the complainant
 acknowledgment letter
 ongoing communications (i.e. request for more information)
 outcome of the complaint examination process (i.e. the analysis and the supporting
documents)
 final written response to the complainant with justifying reasons
 evidence of escalation to AMF, if applicable.

Complaint Handling Process:

Step 1:

Acknowledge and notice to complainant:

The person in charge will acknowledge receipt of the complaint by letter to the complainant
within 48 hours of receiving it using the template in Complaint Handling – Appendix A, that
includes the following information:
 A description of the complaint, specifying the real or potential harm, the complaint against
the firm and the requested remedial action;
 The name and contact information of the person examining complaints;
 In the case of an incomplete complaint, a notice requesting more information to which the
complainant must respond within a set deadline, failing which the complaint will be
deemed to have been abandoned;
 Timeframes that will be followed;
 A copy of the firm’s examination policy (Section 1 of Complaint Handling – Policies &
Procedures);
 A notice stating that if not satisfied with the outcome or with the examination of the
complaint, the complainant can request that the complaint file be transferred to the AMF
and that the AMF may offer dispute resolution services, if deemed appropriate;
 A reminder to the complainant that filing a complaint with the AMF does not interrupt the
prescriptive period for civil remedies against the registrant.

A copy of the acknowledgement letter is retained in the complaint file.

Step 2:

Compliant examination:

The complaint must be examined by the person in charge and a final response provided with
justifying reasons, within 30 days of receiving all of the information necessary for the
examination.

A copy of the response is retained in the complaint file.

Step 3:

Transfer/escalation of file to the AMF:

If not satisfied with the outcome or with the examination of the complaint, the complainant may
ask the person in charge, at any time, to transfer the complaint file to the AMF. The client must
complete the ‘Request transfer of file to AMF’.

The transferred file must include all the information related to the complaint. The person in
charge is responsible to comply with the rules governing the protection of personal information.

Reporting to AMF:

The person in charge is required to ensure the firm is enrolled with the AMF’s electronic
Complaint Reporting System (CRS) to report electronically. Once enrolled, the AMF provides an
identifier number and password.

The person in charge must use CRS to file a report as outlined below.

 A firm of one representative files semi-annually only if a complaint has been received.
 A firm of two or more representatives is required to file a report semi-annually regardless
of whether any complaints were received.

The reporting periods:
 no later than July 30, for data collected between January 1 and June 30;
 no later than January 30, for data collected between July 1 and December 31.

Contact information for enrollment:
 by email, contact account administrators at: [email protected], or
 call an AMF Information Centre agent.