Consumer complaints must be processed and reported to the AMF in accordance with the complaint processing framework applicable in Québec. The requirements of this framework apply to the following persons:

  • Financial intermediaries:
    • Firms, independent representatives and independent partnerships
    • Securities or derivatives dealers and advisersBusinesses that act exclusively as investment fund managers are not subject to this obligation.
  • Financial institutions:
    • insurers
    • deposit institutions
    • financial services cooperatives
    • trust companies
  • Credit assessment agents

Businesses must also submit a complaints report to the AMF every year.

Complaint processing framework

Financial intermediaries must process client complaints in accordance with the requirements established under the following laws:

  • Act respecting the distribution of financial products and services for firms, independent partnerships and independent representatives;
  • Securities Act and Derivatives Act for securities or derivatives dealers and advisers

Financial institutions must adhere to sound commercial practices in accordance with the laws governing them and the expectations set out in the Sound Commercial Practices Guideline (pdf - 1 MB)This link will open in a new windowNovember 2022 and the Governance Guideline (pdf - 1 MB)This link will open in a new windowApril 2021, including with respect to the fair treatment of clients, the fair processing of client complaints and the adoption of a complaint processing and dispute resolution policy. These requirements can be found in the following laws:

  • Insurers Act
  • Act respecting financial services cooperatives
  • Deposit Institutions and Deposit Protection Act
  • Trust Companies and Savings Companies Act

Credit assessment agents must also adhere to sound commercial practices in accordance with the Act respecting credit assessment agents This link will open in a new window and the expectations set out in the Guideline applicable to credit assessment agents (pdf - 461 KB)This link will open in a new windowUpdated on February 2, 2023Guideline, credit assessment agents, including with respect to the fair treatment of any persons concerned whose record the agent holds, the fair processing of their complaints and the adoption of a complaint processing and dispute resolution policy.

Effective July 1, 2025Consult Framework for processing complaints effective until June 30, 2025, complaints from consumers of financial products and services must also to be processed in accordance with the rules and practices specified in the Regulation respecting complaint processing and dispute resolution in the financial sector (pdf - 198 KB)This link will open in a new windowLast amendment in force on July 1, 2025 (“Regulation”)Investment dealer, derivative dealer and mutual fund dealer members of the Canadian Investment Regulatory Organization are temporarily exempted, subject to conditions established by blanket order (pdf - 137 KB)This link will open in a new windowUpdated on January 31, 2025Translation of the DECISION NO. 2025-PDG-0010: Blanket order regarding exemption from certain requirements set out in the Regulation respecting complaint processing and dispute resolution in the financial sector for Canadian Investment Regulatory Organization dealer members. from certain requirements set out in the Regulation. Frequently asked questions on the temporary exemption from certain  obligations of AMF complaint processing Regulation for CIRO dealer members (pdf - 196 KB)This link will open in a new windowUpdated on June 30, 2025.

Complaint definition

Financial intermediaries, financial institutions and credit assessment agents (“businesses”) will be required to review their complaint processing and dispute resolution process to ensure compliance with the complaint definition and new rules and practices set out in the Regulation.

The Regulation defines the complaints that must be processed by the businesses in accordance with the rules and practices set out in legislation and Regulation (s. 3 of the Regulation).

Complaint regarding a financial intermediary or financial institution

A communication that meets the following conditions is considered a complaint regarding a financial institution or financial intermediary:

  • It expresses a reproach or dissatisfaction in respect of a service or product offered by the financial intermediary or financial institution.
  • It is communicated by a person who is a member of the clientele of the financial institution or financial intermediary (“consumer”).
  • It expresses an expectation, explicit or not, that action be taken by the financial intermediary or financial institution to address the situation.

Examples

  • A consumer reproaches their representative for failing to clearly explain the fees the representative’s business is charging them for its services and asks for the fees to be cancelled.
  • A consumer is dissatisfied with how long it took their financial institution to process their request to transfer their account balance to another business and asks for the interest lost during that time to be reimbursed.

Complaint regarding a credit assessment agent

A communication that meets the following conditions is considered a complaint regarding a credit assessment agent:

  • It expresses a reproach or dissatisfaction in respect of a practice of the credit assessment agent.
  • It is communicated by a person concerned by a credit record held by the credit assessment agent.
  • It expresses an expectation, explicit or not, that action be taken by the agent to address the situation.

Examples

  • A consumer has noticed that their credit score has gone down and wants to know why. After several futile attempts to get answers from the credit assessment agent, the consumer, dissatisfied with the customer service provided by the agent, asks to have another person contact them with the explanation.
  • A consumer informs a credit assessment agent that they are unable to register on-line to access their credit report because of an authentication error on the credit assessment agent’s end. They ask for the issue to be resolved so they can access their credit report.

The following are not considered complaints:

Types of request or communication Examples

A comment or feedback

  • A client contacts the business to say they are finding its website hard to use and are having trouble locating the business’s mailing address.
  • A client complains about the long wait to get through to a customer service agent.

A request for information or materials regarding a product or service

  • A client contacts their insurer to understand why the premium on renewal of their auto insurance contract is higher and inquires about the reasons for the increase.
  • A client wants clarification regarding the fees charged for the services provided by their representative.
  • A client requests a copy of the summary of the business’s complaint processing policy.

A claim for an indemnity or an insurance claim

  • A client asks their insurer to review its decision to deny their claim following a loss.
  • A client contacts their insurer for an update on the status of their disability claim because they feel it is taking too long to process.

A request for access or rectification of personal information concerning a client. Such requests must be processed in accordance with the Act respecting the protection of personal information in the private sector This link will open in a new window.

  • A client requests a copy of their record from the business.
  • A consumer asks the credit assessment agent to rectify information in their credit report.

A request for correction of a clerical error

  • A client asks their representative to rectify a clerical error in their mailing address.
  • A client notifies the business that their representative has made an error in calculating the fees payable for services provided. The representative is claiming payment of $210 for 3 hours’ work at an hourly rate of $65. The client asks the business to correct the calculation error so they can know how exact amount that they actually owe.

Important! When the error giving rise to a correction request has further consequences for the client or one or more other clients, the request must be considered a complaint.

Examples:

  • An employee inputs an incorrect bank account number in the client’s record, causing a payment default in a contract. The client asks the business to correct the input error in their banking information and rectify the situation involving the contract.
  • The error exposes a calculation issue in the business’s computer system that is affecting a number of other clients.