- This depends on whether the complaint or other event was received prior to July 4, 2026, and if the member is a mutual fund or an investment dealer.
- CIRO mutual fund dealers must file all Québec-based complaints and other reportable events under the Regulation respecting complaint processing and dispute resolution in the financial sector (AMF Regulation) received prior to July 4, 2026 directly with the Autorité des marchés financiers (AMF).
- Effective July 4, 2026, CIRO mutual fund dealers must file all Québec-based complaints and other reportable events reportable under AMF Regulation and CIRO rules in ComSet.
- Investment dealers must continue to file all Québec-based complaints and other reportable events under AMF Regulation and CIRO rules in ComSet.
- A Québec-based complaint is a complaint that relates to conduct by the dealer or registered representative which occurred in Québec. Commonly, this will be where the complainant is located in Québec but will also often include situations where the dealer allegedly failed to supervise or otherwise comply with its regulatory obligations with respect to a registered representative in Québec.
- The obligation to report all Québec-based complaints or events applies regardless of whether the complaints or events relate to the conduct of the dealer or its registered representatives.
- By September 30, 2026, CIRO mutual fund dealers must submit an annual report directly to the AMF about the Québec-based complaints and other reportable events reportable under AMF Regulation which were received between January 1 and July 3, 2026.
- CIRO mutual fund dealers must ensure that all complaints and other events reportable under AMF Regulation received between July 4 and December 31, 2026 are reported in ComSet before May 1, 2027 but are not required to submit an annual report to the AMF to report these complaints or events. CIRO will report these complaints and events to the AMF annually by May 1, 2027. In future years, CIRO will report all Québec-based complaints and events reportable under AMF Regulation to the AMF annually by May 1 of the following year.
- Investment dealers must ensure that all complaints and other events reportable under AMF Regulation received between January 1 and December 31 are reported in ComSet before May 1 of the following year. They are not required to submit an annual report to the AMF to report these complaints or events. CIRO reports these complaints and events to the AMF annually by May 1 of the following year.
- Both CIRO investment and mutual fund dealers are required to comply with Québec’s complaint handling requirements under the AMF Regulation when dealing with Quebec-based complaints. These requirements may be different than the requirements contained in CIRO rules.
- Yes, complaint reporting requirements under CIRO rules may be different than the AMF’s requirements.
- Both CIRO investment and mutual fund dealers are required by the AMF to report some complaints and other events on ComSet that are not subject to a reporting requirement under CIRO rules. This includes, for example, reporting certain service complaints that meet the definition of a complaint in Québec.
- To determine whether a complaint is reportable in ComSet under Québec’s complaint reporting requirements, dealer members should consider the AMF’s definition of a complaint. A complaint in Québec is “any reproach or dissatisfaction in respect of a service or product offered by a financial institution or a financial intermediary where the reproach or dissatisfaction is communicated by a person who is a member of the clientele of the financial institution or financial intermediary and a final response is expected.”
- If dealers have questions about their complaint handling and reporting obligations in Québec under AMF Regulation, they should review Complaint examination | AMF or contact the AMF.
- In all provinces, complaints (or any conduct the dealer is aware of) related to the banking or credit union activities of a mutual fund registered representative at a bank or credit union affiliated mutual fund dealer which are listed in MFD Rule 600, subparagraph 6.1(b) must be reported in ComSet. The mutual fund dealer should indicate in the ComSet event if the activities impacted a client of the bank or credit union affiliated mutual fund dealer.
- The AMF will continue to regulate the Québec-based conduct of mutual fund dealers in accordance with National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) and applicable securities legislation until CIRO Rules become applicable to these dealers. CIRO rules are expected to become applicable when CIRO’s new harmonized rules come into effect and as determined the AMF. Until CIRO rules apply, CIRO will refer Québec-based mutual dealer conduct identified through CIRO’s review of complaints and other events to the AMF where appropriate.
- CIRO will regulate the Québec-based conduct of mutual fund registered representatives in accordance with Regulation respecting the rules of ethics in the securities sector (CQLR, c. D-9.2, r. 7.1), NI 31-103 and applicable securities legislation. CIRO’s investigative and hearing rules (see mutual fund dealer Rules 6 and 7) apply to these registered representatives.
- All CIRO dealers (investment dealers and mutual fund dealers) operating in Québec are impacted by Québec’s complaint reporting and handling requirements.
- All CIRO dealers are required to comply with Québec’s complaint handling requirements under the AMF Regulation when dealing with Québec-based complaints. These requirements may be different than the requirements contained in CIRO rules.
- While CIRO investment dealers have always reported complaints and other reportable events relating to Québec on ComSet, the AMF has clarified its expectations that certain Québec-based complaints and events that should be reported in ComSet, such as service complaints that meet the definition of complaint in AMF Regulation.