Policy on Complaint Handling and Dispute Resolution

1. Purpose of the Policy 

As a financial services firm, Finandicap is responsible for handling complaints filed against its representatives who are formally affiliated with it under the law.
Consequently, this policy applies to all employees of the firm. The purpose of a complaint handling and dispute resolution policy is to establish a fair and free procedure for handling complaints received by a representative.
It aims to frame the reception of complaints, the transmission of acknowledgment of receipt and notices to the complainant, the creation of the complaint file, the transmission of this file to the Autorité des marchés financiers (hereinafter referred to as “the Authority”), and the compilation of complaints for the preparation and transmission of a semi-annual report to the Authority.

2. The Responsible Person 

The General Manager of the firm, Mathieu Harrisson, is responsible for the application of the policy and acts as the liaison with the Authority. He oversees the training of staff and representatives and, more specifically, provides them with the necessary information to comply with this policy.
The responsible person also has the following functions:

  • Send an acknowledgment of receipt to the complainant;
  • Transmit the required notices to the complainant;
  • Transmit the file to the Authority, at the request of the complainant;
  • Maintain a register of complaints;
  • Transmit a semi-annual report to the Authority.

3. Complaint 

For the purposes of the policy, a complaint constitutes the expression of at least one of the following three elements:

  • A reproach against a registered representative;
  • The identification of a potential or actual harm that a consumer has suffered or may suffer;
  • The claim for a corrective measure.

An informal approach aimed at correcting a particular problem does not constitute a complaint, as long as the problem is addressed in the course of the registered representative’s regular activities and without the consumer filing a complaint.
To be admissible, a complaint must be made in writing by the complainant.

4. Reception of the Complaint 

A consumer who wishes to file a complaint must do so in writing to the following address:

  • Finandicap Inc.
  • General Management
  • 1600, Ch. Sainte-Foy
  • Québec, QC, G1S 2P4 
  • [email protected]


Any person who receives a complaint must forward it, upon receipt, to the person responsible for the application of this policy. If the representative receives a written complaint from a consumer at their office, they must immediately and without delay forward it to the firm’s manager.

The responsible person must acknowledge receipt of the complaint within five (5) business days of receiving the complaint, informing the consumer that a review of the file will be conducted within 90 days.

The acknowledgment of receipt must at least contain the following information:

  • A description of the complaint received specifying the harm suffered or potential, the reproach made to the registered representative, and the request for a corrective measure;
  • The name and contact details of the person responsible for handling the complaint;
  • In the case of an incomplete complaint, a notice requesting additional information to which the complainant must respond within 15 days, failing which the complaint will be deemed abandoned;
  • A copy of the complaint handling and dispute resolution policy;
  • A notice informing the complainant of their right to request, if they are not satisfied with the result of the complaint handling or the handling process itself, at the expiration of the 90-day period set for obtaining the final response from the registered representative, without exceeding a period of one year from the receipt of this response, the transfer of their file to the Authority. The notice must also mention that the Authority may offer mediation if it deems it appropriate and if the parties consent;
  • A notice reminding the complainant that mediation is an amicable settlement process in which a third party (the mediator) intervenes with the parties to help them reach a satisfactory agreement;
  • A notice informing the complainant that filing a complaint with the Authority does not interrupt the prescription of their remedies against the registered representative before the civil courts.

5. Creation of the Complaint File 

Each complaint must be the subject of a separate file.

The file must include the following elements:

  • The written complaint from the complainant, including the three elements of the complaint (the reproach against the registered representative, the actual or potential harm, and the requested corrective measure);
  • The result of the complaint handling process (the analysis and supporting documents);
  • A copy of the final written and reasoned response from the registered representative, which was sent to the complainant.
  • The complaint file is kept at the firm’s business address.

6. Handling a Complaint 

Upon receipt of a complaint, the person responsible for the application of this policy must conduct an investigation to seek the factual elements related to the alleged facts.
The responsible person must handle any complaint received fairly and impartially and must provide an adequate response based on the particularity of the situation.
The complaint handling must be carried out within a reasonable time following the receipt of all the necessary information for its review.
At the end of the investigation, the responsible person must send the complainant a final written and reasoned response.

7. Transmission of the File to the Authority

If the complainant is not satisfied with the result of the complaint handling or the handling process itself, they may request that the firm transfer their file to the Autorité des marchés financiers (AMF).

This right can only be exercised by the complainant at the expiration of the period provided for obtaining a final response, without exceeding a period of one year from the date of receipt of this response.

The transferred file consists of all the documents related to the complaint.

Compliance with personal data protection rules remains the responsibility of the firm’s manager and its employees.

8. Creation and Maintenance of a Register

A complaints register must be created for the application of the policy.
Its update will be the responsibility of the responsible person, i.e., the firm’s manager.
Any complaint corresponding to the definition of this term must be recorded in the register, and more specifically:

  • Any written complaint, regardless of the level of intervention involved in handling this complaint;
  • Any legal action covered by the definition of the word complaint.

9. Annual Report 

The responsible person sends a report to the Autorité des Marchés Financiers detailing the number and nature of complaints received, according to the categories listed in the register of the subject between March 1 and May 1 of each year for the period from January 1 to December 31 preceding their transmission.

10. The Representative’s Obligations 

When a consumer verbally expresses a complaint to the representative (and not simply dissatisfaction), the representative must suggest that the consumer write their complaint and provide them with the contact details of the responsible manager so that the consumer can send their complaint.


From the moment a representative is the subject of a written complaint from a consumer, they must avoid making statements to the complaining consumer to evade their responsibility or admit their responsibility.


Upon receipt of a written complaint from a consumer at their office, the representative must immediately and without delay forward this complaint to the responsible manager of the firm.

As part of the investigation that the responsible manager will conduct, the representative is obliged to cooperate with the investigation process and must, upon request, provide the responsible manager with any required document or information. They must also respond promptly to requests made by the responsible manager. For this reason, the representative must provide the requested information or documents within 10 days of a request to this effect.

As soon as the representative is the subject of a consumer complaint, they must immediately contact their professional liability insurer to inform them. It is not the firm’s responsibility to notify the representative’s liability insurer.

11. Control Measures and Sanctions 

If Finandicap is informed that one of its employees fails to comply with these rules, Finandicap may request clarification from the representative concerned or any other person and reserves the right to suspend the handling of any file submitted by this representative. Finandicap may also take disciplinary measures against a representative, which may include termination of their representative contract, with the sanction being proportional to the fault committed and taking into account the severity of the fault, if applicable.