Purpose of the policy

The purpose of a consumer complaint and dispute resolution policy is to establish a fair and free process to resolve complaints. This policy provides a framework for receiving complaints, sending the acknowledgment of receipt and the notice to the complainant, creating the complaint file, sending the complaint file to the Autorité des marchés financiers (“AMF”) (if the complainant so requests) and compiling complaints in order to create an annual report and send it to the AMF.

Person responsible

The person responsible for applying the policy is Christie Geiss. She is the contact person for the complainant and the AMF. The person responsible ensures that employees receive the appropriate training and transmits the information required to ensure compliance with this policy. The person responsible receives and examines consumer complaints with impartiality, and provides the appropriate responses.

Definition of a complaint

A complaint is the expression of at least one of the elements listed below where an issue has not been resolved in the regular course of business:
– A reproach against the representative or firm in question
– The identification of a potential or actual prejudice the complainant has suffered or could suffer
– The corrective measure claimed

All complaints, not only those related to a potential violation of the law, must be examined by the person responsible.

Lodging a complaint

When a client lodges an initial complaint, either verbally or in writing, the firm holds the operational staff responsible for following up with the client.  If the complaint is resolved to the client’s satisfaction, no written complaint is required and the initial complaint is not entered in the consumer complaints and disputes register.

Where the complainant remains dissatisfied:
– The firm’s employee who is informed of the client’s dissatisfaction shall inform the client of the existence of a complaint resolution mechanism and refer him or her to the responsible person.
– If the client lodges his or her complaint by phone, the person responsible shall ask him or her to make the complaint in writing. The person responsible may help the client to formulate the complaint in writing if he or she has difficulty doing so.

IMPORTANT

Informal steps to rectify a specific issue in the regular course of business do not constitute a complaint.

Receiving a complaint

To be admissible, a complaint must be made in writing (letter, email or fax).

The complaint must also contain the following information:
– The reproach against the representative or firm in question
– A description specifying the potential or actual prejudice suffered
– The corrective measure requested

The complaint must be signed.  Consumers who wish to make a complaint must do so in writing to the following address:

Christie Geiss
Cove Continuity Advisors Inc.
270 – 2255 Dollarton Hwy
NorthVancouver, BC, V7H 3B1
Telephone: 778.655.6221
Fax: 604.924.9153
christie@coveadvisors.com

Procedure for resolving complaints against the firm or its affiliated representatives.

Once a written complaint has been received from a client, the person responsible shall:
– Send an acknowledgment of receipt and the Notice to Complainant, and include a copy of this Policy within five business days of receiving the complaint
– Provide a copy of the complaint to the affiliated representative to inform him or her of the complaint
– Advise the firm’s responsible manager of the complaint.

The person responsible shall also process the complaint within 30 days of receiving all information required to examine the complaint. For this purpose, he or she shall:
– Contact the affiliated representative to obtain his or her version of the facts in writing.
– Contact the complainant in writing in order to complete the file and determine the nature of the complaint and the desired reparation. The complainant must provide any missing information in writing.

The person responsible shall offer solutions to resolve the dispute.
Once the file is completed, the person responsible shall provide to the firm’s responsible manager a summary of the complaint and his or her recommendations, and provide to the complainant a response in writing with reasons.  The firm’s responsible manager shall decide whether the responsible insurer needs to be advised of the complaint.

The manager shall decide what action to take with respect to affiliated representative, including:
– Recommended corrective measures
– Reprimand

Opening a complaint file

The person responsible shall open a file for each complaint against the firm or its affiliated representatives. This same file shall be provided to the AMF at the complainant’s request.

The file shall contain the following:
– The complainant’s written request
– The result of the complaint resolution process (analysis and supporting documents from the person responsible)
– The firm’s final response in writing with reasons, which has been provided to the complainant

Registering complaints

All complaints as defined in this Policy shall be entered in the “Complaints and disputes register.”

Obligation to provide the complaint file to the AMF

The firm shall send the complete complaint file to the Autorité des Marchés Financiers at the complainant’s request where the complainant is dissatisfied with the way in which his or her complaint was handled or with the response received.  The transferred file shall contain all documents relevant to the complaint.  The complainant may only exercise his or her right to request the transfer of the complaint file to the AMF once the prescribed period for obtaining the final response has expired. However, the complainant must exercise this right within one year of receiving the final response.

Obligation to provide a semi-annual report to the AMF

Twice a year, the person responsible shall provide a report regarding complaints received with respect to the firm and/or its affiliated representatives.  The firm must declare all complaints received within the last six months. The report must also list all legal proceedings related to complaints as well as files transferred to the AMF.

The report shall be submitted no later than:
– July 30 for information gathered between January 1 and June 30
– January 30 for information gathered between July 1 and December 31

Information to be provided to an insurer affected by a complaint with respect to a product or the underwriting method used for a product.  Where a complaint is made specifically with respect to a product or the underwriting method used for a product, the person responsible shall inform the insurer in question.