Quebec Regulation respecting complaint processing and dispute resolution in the financial sector – CIRO Dealer Member Exemptions

Members should be aware that the Quebec legislation dealing with complaint handling (Regulation respecting complaint processing and dispute resolution in the financial sector) (the “legislation”) published on February 14, 2024, will be effective July 1, 2025.

The legislation applies to Dealer Members operating in Quebec as described in paragraph 2 of the legislation (the “affected Dealer Members”).

Currently, all CIRO Dealer Members are subject to the complaint handling requirements detailed in the Investment Dealer and Partially Consolidated Rule 3700, Reporting, Internal Investigation and Client Complaint Requirements, Mutual Fund Dealer Rule 300, Complaint Handling, Supervisory Investigations, and Internal Discipline and Mutual Fund Dealer Rule 600 Information Reporting Requirements.

On January 27, 2025, the Autorité des marchés financiers (AMF) published Blanket Order 2025-PDG-0010, Blanket order regarding exemption from certain requirements set out in the Regulation respecting complaint processing and dispute resolution in the financial sector for Canadian Investment Regulatory Organization dealer members”. The Blanket Order details the application and exemptions to which CIRO affected Dealer Members are subject.

In response to questions about the practical application of the exemptions in the Blanket Order, the AMF published an FAQ on June 30, 2025. The FAQ addresses various matters including AMF expectations regarding compliance, and clarifications regarding how to file complaints with CIRO.

We remind affected Dealer Members that under section 14(4) of the legislation, they must provide complainants with a final response in respect of their complaint, not later than the 60^th day following receipt of the complaint. Under section 14(5), this timeline may be extended to 90 days where there are exceptional circumstances, or circumstances beyond the affected Dealer Member’s control.

Dealer Members should closely review the legislation and the Blanket Order to ensure that their policies and procedures account for any other non-exempted provisions of the legislation. Questions regarding the application of the legislation and Blanket Order should be referred to:

M^e Cindy Côté
Senior Policy Analyst
Direction des pratiques de distribution et des OAR
418-525-0337, ext. 4814
Toll-free: 1-800-525-0337
cindy.cote@lautorite.qc.ca