Is it permissible to supervise a probationary period remotely?

In order to limit physical contact and thereby slow the spread of the virus, the government is asking everyone who can work remotely from home to do so. In light of this, the AMF is allowing trainees to be supervised remotely. However, since trainees’ and supervisors’ obligations are unchanged, remote supervision will have to be carried out in such a way as to enable all parties involved to continue to fulfil their obligations.

How to proceed:

• Clearly indicate in the trainee's file that the probationary period was supervised remotely.

You are reminded that the probationary period is an opportunity to incorporate, in a real but supervised setting, the knowledge and skills required to practise professionally, while ensuring that consumers are protected.

Specifically, the supervisor must supervise the trainee when he or she meets with clients or collects information from them, approve the products and services offered by the trainee before they are recommended to the client (for insurance of persons) or within 24 hours of the transaction (for damage insurance), ensure the products or services meet the client’s needs, enter this approval in the client record and countersign, if applicable, any proposal or form, including notices for purposes of policy replacement.

The AMF may, particularly during inspections, ask to see evidence of meetings with the trainee (in person or by telephone) as well as evidence that the supervisor reviewed the trainee’s work or supervised the collection of information. If the computer system allows it, the supervisor’s approval may be entered electronically in the client’s file. Alternatively, the transaction may be approved by means of a clear and detailed e-mail exchange, a conversation recorded between the trainee and the supervisor, or an electronic signature.

However, the supervisor must have reviewed the entire client file as well as the proposal recommended by the trainee. Regardless of the form the approval takes, a record of it must be entered in the client’s file and the approval must be accessible upon request.

In addition, at least once a week, the supervisor must evaluate and review the tasks carried out by the trainee. The supervisor may exercise closer supervision if he or she deems it necessary. Meetings may be held via teleconference, provided the supervisor is able to have access to the client files and assess the quality of the trainee's work. However, the AMF believes that supervision, to be effective, cannot rely solely on summaries of the trainee’s meetings with the supervisor.

The supervisor must open a file for each trainee and enter, in particular, the tasks the trainee carries out, a summary of the supervisor’s meetings with the trainee and notes concerning the trainee’s progress during the probationary period. Please note that the record must be retained for a five year period, from the successful completion of the probationary period or its abandonment, by the firm or independent partnership for which the supervisor works or by the supervisor, if serving as an independent representative.

Difficulty for the trainee in completing the 28-hour-per-week probationary period

• To provide the trainee with every opportunity for quality learning, the probationary period for a sector may be staggered over a period of 18 weeks, provided that 336 hours are completed during that period.
• For a probationary period relating to a class of sectors, the probationary period may be staggered over a period of 11 weeks, provided that 168 hours are completed during that period.

How to proceed:

• No form needs be completed in order to notify the AMF.
• However, the “Supervisor’s recommendation related to representative’s certificate” form that will be sent to us at the end of the extended probationary must clearly specify how the probationary period was staggered.