General Terms

Complaints Handling Policy

English translation of the French policy provided by Karine Gosselin.

Preamble

This policy governs compliance by the independent representative Karine Gosselin. It must be applied rigorously and used as a tool to support independent mortgage brokers and firms in meeting the requirements of the Autorité des marchés financiers (hereinafter the “AMF”).

Objectives

1. Provide a fair, free procedure for handling complaints from clients, meaning people with an interest in a product or service distributed by the representative, and for resolving disputes;
2. Manage the entire complaints-handling process objectively, taking the complainant’s interests into account;
3. Ensure that complaints are handled simply, free of charge and diligently;
4. Develop an overall understanding of the complaints received to identify common causes and resolve the issues raised.

Definitions

For the purposes of this policy, a complaint is any reproach or expression of dissatisfaction concerning a service or product offered by the independent representative, communicated by a client, for which a final response is expected. A final response is expected, in particular, when the complainant’s communication expressly or implicitly indicates that steps must be taken to remedy the situation.

The following requests or communications do not constitute a complaint:

• A request for information or documents concerning a product or service offered;
• A request for access or rectification made under the Act respecting the protection of personal information in the private sector;
• A request for compensation or any other insurance claim;
• A request to correct a calculation or clerical error; and
• A comment or feedback.

Notwithstanding the above, a request to correct a calculation or clerical error constitutes a complaint when additional measures are needed to remedy the consequences of the error for a client.

1. Roles and responsibilities

The compliance officer, Ms. Karine Gosselin, is responsible for implementing this policy. The officer must provide staff with all information necessary to comply with it.

A summary of this policy must be available on the independent representative’s website, where applicable. At a minimum, the summary must contain:

• A description of the procedure for submitting a complaint and the assistance available to help the complainant formulate it;
• A description of the different stages of complaint handling;
• A statement that a complaint may validly be submitted using the complaint form available on the AMF’s website, with a reference to that form;
• The ways to obtain information about complaint handling; and
• The expected processing time.

2. Creating a complaints register

The compliance officer must ensure that a complaints register is created and that every complaint file is entered in it.

The officer is also responsible for managing the register, including filing the report through the online system as provided in section 5 of this policy.

3. Handling a complaint

3.1 Receiving a complaint

Any consumer who wishes to make a complaint must do so in writing at the following address:

When a complaint is expressed, we assist the complainant in clearly formulating it so that we understand its elements and the client’s expectations regarding its resolution. If a complaint involves several entities, the complainant must be informed and given their contact information. At any time during the complaints process, the complainant may contact the person responsible for information about the status of the file.

3.2 Opening a file

When a complaint is reported in any form, whether written or verbal, the compliance officer must open a file and record the date of receipt in the complaints register. The person receiving the complaint must invite the complainant to submit it in writing or record all its details in writing.

An example of a complaints register appears in Appendix A.

If someone other than the compliance officer receives the complaint, that employee must notify the compliance officer without delay.

A copy of the written complaint, or the recorded version of a verbal complaint, must be placed in the file.

3.3 Acknowledgement of receipt

Upon receiving the complaint, the compliance officer must initiate the complaints-handling process.

The compliance officer must send an acknowledgement of receipt to the complainant without delay or, failing that, within ten (10) days of receiving the complaint.

The acknowledgement must contain the following information:

• The complaint file’s identification code;
• The date the complaint was received, if different from the date entered in the register;
• Contact information for enquiries about the procedure and the progress of complaint handling;
• The expected processing time and the date by which the final response must be provided;
• A link to the summary of this policy or a copy of it; and
• A notice informing the complainant of the right to request an AMF review of the complaint at any time and/or if dissatisfied with the final position or the handling of the complaint.

An example of an acknowledgement template appears in Appendix B.

If the complaint file is transferred, the transferred file includes all information relating to the complaint.

Compliance with personal information protection rules remains the mortgage broker’s responsibility.

3.4 Analysing the complaint

The person analysing the complaint must obtain all information essential to handling it, including by contacting the client for additional information or relevant documents needed to complete the analysis.

Complaints received by the independent representative are handled using one of the following three (3) methods:

(a) Standard handling

The independent representative provides a final written response to the complainant no later than the 60th day after receiving the complaint.

(b) Extended handling (exceptional circumstances)

Where exceptional circumstances or circumstances beyond the independent representative’s control justify it, the final response may be provided no later than the 90th day after receipt. In this case, the officer must send the complainant written notice no later than the 60th day, setting out:

• The circumstances justifying the exceptional time limit;
• The date by which the final response will be provided;
• The complainant’s right to request an AMF review of the file and how to do so.

(c) Simplified handling

Where a complaint can be handled within 20 days of receipt, the independent representative may, after completing the analysis, communicate the following to the complainant verbally or in writing:

• The reasoned conclusion of the analysis and the outcome of the handling process;
• Where applicable, the period within which the complainant may accept an offer.

If the complaint cannot be resolved to the complainant’s satisfaction within 20 days of receipt, for example because dissatisfaction persists or an offer is refused, the officer sends written notice containing the information required in an acknowledgement of receipt no later than the 20th day after receipt. Handling then continues under the standard process.

Once the complainant requests an AMF review, the independent representative has fifteen (15) days to transfer the complaint file.

3.5 Response

Once the complaints-handling process is complete, the officer must provide a final written response containing:

• A statement that it is a final response;
• A summary of the complaint received;
• The reasoned conclusion of the analysis and the outcome of the handling process;
• The complainant’s right to request an AMF review of the file, with an explanation of how to do so;
• The business contact information and signature of the person who handled the complaint.

Where the independent representative makes an offer to resolve the complaint following the analysis, the representative must:

• Allow the complainant a reasonable time to assess the offer and, if desired, obtain advice to make an informed decision;
• Give effect to the agreement no later than the 30th day after the offer is accepted or, where justified by the complainant’s interests, within another period agreed with the complainant.

The independent representative cannot make an offer conditional on preventing the complainant from exercising the right to an AMF review, requiring the withdrawal of another complaint, or preventing communication with the AMF or any competent self-regulatory organization.

3.6 Complaint file

The complaint file must be up to date, accurate, documented and understandable, and contain:

• The complainant’s written complaint;
• A copy of the acknowledgement of receipt;
• The outcome of the handling process, including the analysis and supporting documents;
• A copy of any settlement offer;
• The final response to the complainant;
• Correspondence with the complainant and any document relating to the complaint.

The complaint file must be retained for the same period as the client file.

4. Professional liability insurance

Where applicable, the compliance officer or the mortgage broker concerned by the complaint must notify their professional liability insurer without delay.

5. Reporting to the AMF

Between March 1 and May 1 each year, the compliance officer must submit to the AMF, through its online services for businesses (SEL), a report on the number and nature of complaints received from January 1 to December 31 of the year preceding the reporting period.

6. General provisions

The compliance officer must review this policy annually and prepare a document describing that review.

The document must address, in particular, whether changes to the policy are appropriate, any proposed changes, and the reasons for them.

If an external audit takes place during the year, the report’s recommendations must be incorporated into the policy where applicable.

This compliance policy has been in effect since December 17, 2020, and was updated on April 22, 2025, and May 7, 2026.

The appendices referenced in this policy are not included in the supplied document. Contact Karine Gosselin to obtain the applicable documents.