The following is a summary of the firm's1 complaint and dispute handling policy. The full version is available upon request.
The purpose of this complaint and dispute handling policy is to establish a free, simple, and fair procedure to ensure complaints are acknowledged promptly and processed in a timely manner.
In particular, it aims to identify the person responsible for handling complaints, provide useful information for filing a complaint, govern the receipt and processing of complaints, and where applicable, the transfer of the file to the Autorité des marchés financiers, hereinafter referred to as the "Authority".
Furthermore, the policy applies regardless of the nature of the activities that give rise to a complaint or dispute, including but not limited to general management activities, distribution of insurance products or services, and the protection of personal information.
The person responsible for implementing this policy is Jennifer Bourre, Vice-President of Training and Compliance. Under this policy, her duties include, among others:
- Sending an acknowledgment of receipt to the complainant within 10 business days of receiving a complaint.
- Analyzing complaints and disputes within a reasonable timeframe (noting that the responsible person may delegate this task while maintaining oversight).
- Ruling on the conclusion of the analysis and informing the complainant.
- Transferring the file to the Authority, upon the complainant's request.
- Maintaining a complaint register.
- Reporting complaints to the Authority through the designated system.
Our complaints handling officer ensures that complaints we receive are handled fairly and that our policy is respected and implemented throughout the firm, specifically so that:
- Our management and staff are aware of and comply with our complaint handling policy.
- Our clients can easily obtain information on how we handle complaints or on the handling of their own complaints.
- Our staff carry out the necessary follow-ups to properly handle our clients' complaints.
- The person assigned to handle a complaint has the competencies required to handle that complaint.
- Each complaint is handled objectively and with the client's interests in mind.
A consumer or client who wishes to file a complaint may do so verbally or in writing, by contacting the responsible person or one of our representatives:
- By mail: 1955 ch. De La CĂ´te-de-Liesse, Suite 201, Saint-Laurent, QC H4N 3A8
- By phone: 514-333-4630
- By email: plaintes.complaints@lmbf.ca
The consumer or client may also use the form made available by the Authority:
https://lautorite.qc.ca/fileadmin/lautorite/formulaires/grand-public/GP-plainte_formulaire-plainte-an.pdf
If needed, the responsible person can offer assistance in formulating the complaint.
For the purposes of this policy, a complaint constitutes the verbal or written expression of any grievance or dissatisfaction regarding a service or product offered by the firm, communicated by a person who is part of its clientele and for which a final response is expected, including confirmation of the implementation of remedial measures.
The following requests and communications do not constitute a complaint:
1° A request for information or documents regarding a product or service offered.
2° A request for access or rectification made in accordance with the Act respecting the protection of personal information in the private sector (chapter P-39.1).
3° A claim for indemnity or any other insurance claim.
4° A request for the correction of a calculation or clerical error.
5° The communication of a comment or feedback.
An initial expression of dissatisfaction by the consumer, whether written or not, does not constitute a complaint when such dissatisfaction is resolved in the normal course of the registrant's activities.
However, as a guideline, if the consumer remains dissatisfied and their dissatisfaction must be handled by the person responsible for complaint handling, it then constitutes a complaint.
The complainant must provide their complete contact information, including:
- First and last name of the complainant
- Address
- Phone number
- Email address
Upon receipt of a complaint, the person responsible for complaint handling will send an acknowledgment of receipt to the complainant within 10 business days of receiving the complaint.
Any representative or employee of the firm who receives a complaint must forward it without delay to the persons responsible for handling complaints. They must cooperate in the handling of any complaint and provide any documents or information necessary for the processing of the complaint.
The person assigned to handle a complaint must not do so if they are unable to handle it objectively. They must ensure they have the necessary competencies or knowledge to handle the complaint and, if needed, seek support from persons who can assist them in processing the complaint.
We ensure that our policy is known to all our staff and that each person is informed of their responsibilities. We develop the procedures and implement the processes necessary for the handling of complaints we receive, and we ensure that our staff responsible for complaint handling are properly trained. We designate a complaints handling officer after ensuring they have the necessary competencies to fulfill their responsibilities. We ensure that our staff and management cooperate in the handling of complaints.
In the event that the complainant is not satisfied with the outcome of the handling of their complaint or with the handling process itself, they may request that the responsible person transfer their complaint file to the Authority.
Address to use for the transfer:
AUTORITÉ DES MARCHÉS FINANCIERS
Place de la Cité, tour Cominar
2640 boulevard Laurier, bureau 400
Québec (Québec) G1V 5C1
The file transferred to the Authority must include all documents related to the complaint.
The transfer must be made to the Authority within 153 days of the complainant's request.
Link to the Authority's form:
https://lautorite.qc.ca/fileadmin/lautorite/formulaires/grand-public/GP-plainte_formulaire-transfert-dossier-an.pdf
Date of last policy update: 06-2025
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