Guideline on Complaint-Handling Procedures for Banks and Authorized Foreign Banks
Date: January 27, 2022
Revised date: June 23, 2026 (previous versions)
Effective date: June 23, 2027
I. Introduction
1. The Financial Consumer Agency of Canada (FCAC) has developed a Guideline on Complaint-Handling Procedures for Banks and Authorized Foreign Banks (Guideline) to set out its expectations with respect to Banks’ (including federal credit unions) and Authorized Foreign Banks’ (Banks) implementation of the complaint-handling provisions in the Bank Act and the Financial Consumer Protection Framework Regulations.
2. Part XII.2 of the Bank Act establishes the provisions that apply to Banks for dealing with complaintsFootnote 1 by any personFootnote 2 who is an actual or potential customer of that Bank (Consumer).
3. FCAC encourages other federally regulated financial entities, such as trust and loan companies and insurance companies, to review this Guideline to develop and improve their policies and procedures (Policies and Procedures).
4. A Bank is responsible for ensuring it meets the requirements established in the Bank Act and that its complaint-handling Policies and Procedures are satisfactory to the Commissioner.Footnote 3
5. A Bank, and any parties subject to the requirements in s. 627.15 of the Bank Act (Third Parties), must ensure that Consumers have access to the Bank’s complaint-handling Policies and Procedures.
6. FCAC recognizes that Banks may tailor their complaint-handling Policies and Procedures to align with the nature, size and complexity of their business, distribution channels (for example, in branch, online, or over the phone), and products and services.
7. This Guideline should be read in conjunction with all applicable legislation and regulations.
II. Key Principles
8. A Bank’s senior management and the committee of the board responsible for the Bank’s compliance with Consumer provisions—or, in the case of an Authorized Foreign Bank, its senior management—should oversee the establishment and implementation of complaint-handling Policies and Procedures.
9. FCAC expects a Bank to establish and implement effective complaint-handling Policies and Procedures that adhere to the following principles:
Effectiveness
A Bank’s complaint-handling Policies and Procedures are comprehensive and implemented to deal with Consumer complaints in a fair and consistent manner.
Timeliness
A Bank’s complaint-handling Policies and Procedures ensure that complaints are dealt with promptly, without unnecessary delays.
Accessibility
A Bank’s complaint-handling Policies and Procedures are easy for Consumers to locate, navigate and understand.
III. Effective complaint-handling Policies and Procedures
10. FCAC expects a Bank’s complaint-handling Policies and Procedures to support consistency in decision-making, with redress and remediation provided as appropriate.
11. FCAC expects a Bank’s complaint-handling Policies and Procedures to ensure that all complaints are dealt with in a fair, consistent, timely, and objective manner at all stages of the complaint-handling process.
12. A Bank seeking to incorporate, or to continue to operate as a Bank, must provide a copy of its complaint-handling Policies and Procedures to FCAC within the timelines specified during the application process.
13. When a Bank amends its complaint-handling Policies and Procedures, FCAC expects the amended version of the Policies and Procedures to be submitted to FCAC as soon as the amendments are approved through the Bank's internal governance process.
14. FCAC expects a Bank to allocate sufficient operational, technological and human resources to ensure the effectiveness of its complaint-handling policies and procedures, allowing Consumers consistent access to timely and responsive services.
Designating Employees
15. A Bank must designate 1 officer or employee (Employee) in Canada to have overall responsibility and accountability for the implementation of its complaint-handling Policies and Procedures.Footnote 4
16. A Bank must also designate 1 or more Employees in Canada to receive and deal with complaintsFootnote 5 (Designated Employees). A Bank may designate any Employee whom it deems appropriate.
17. The Employee whom a Bank designates to be responsible for implementing its complaint-handling Policies and Procedures and the Designated Employee who holds the most senior position for dealing with complaints (the Senior Designated Employee) can be the same Employee.Footnote 6
17.1. The title and responsibilities of any Designated Employee should reflect that the position deals with complaints on a regular basis.
17.2. All Designated Employees should have the experience, competencies and authority required to deal with complaints, including providing redress and remediation, where applicable.
18. To be effective, FCAC expects a Bank’s complaint-handling Policies and Procedures to:
18.1. establish clear roles, responsibilities and accountabilities for all Employees involved in complaint handling
18.2. provide for the monitoring of complaints, including those it receives from or in relation to Third Parties
18.3. include mechanisms for soliciting regular feedback from Consumers at all levels of the Bank’s complaint-handling process
18.4. include a process for monitoring and testing Policies and Procedures and updating them as required
18.5. ensure that all Employees who deal with complaints follow the same Policies and Procedures
18.6. include analysis of complaint data to identify recurring and systemic issuesFootnote 7 as well as opportunities to better serve Consumers and to strengthen compliance with market conduct obligationsFootnote 8
Training
19. FCAC expects a Bank’s complaint-handling Policies and Procedures to include:
19.1. initial and ongoing formal training on complaint-handling for all Employees who deal with complaints
19.2. a system for monitoring the status of Employee training
19.3. mechanisms to measure and test the effectiveness of training
19.4. timelines and processes for reviewing training on a regular basis to ensure effectiveness and for updating training in a timely fashion, as required, particularly in the event of changes to legal requirements or changes to internal complaint-handling Policies and Procedures
20. FCAC expects a Bank’s training for Designated Employees to reflect the Employees’ specific roles and responsibilities.
21. FCAC expects a Bank to allocate adequate operational, technological and human resources specifically to the development and ongoing delivery of a robust complaint-handling training program that supports an effective complaint handling process.
Recurring or systemic issues
22. FCAC expects a Bank’s complaint-handling Policies and Procedures to include mechanisms for identifying, remedying, and reporting any recurring or systemic issues by:
22.1. addressing the underlying reason behind the complaint and taking corrective action, where appropriate
22.2. tracking and analyzing the causes of individual complaints to identify the root causes that are common to various types of complaints
22.3. addressing whether such root causes may also affect other processes, products or services
22.4. addressing whether other Consumers may have potentially suffered financial or non-financial harm from such root causes
Redress and remediation policies
23. A Bank must have complaint‑handling Policies and Procedures that include a comprehensive redress policy that sets out how the Bank will provide redressFootnote 9 in a timely manner that is in keeping with, and based on, the circumstances of the complaints.
23.1. A Bank must outline in the policy how and when the Bank will provide redress to all affected Consumers where a recurring or systemic issue has been identified.
24. FCAC expects that a Bank’s complaint‑handling Policies and Procedures ensure that a Bank provide appropriate remediation to address financial or non-financial harm to a Consumer in a timely manner that is in keeping with, and based on, the circumstances of the complaints.
24.1. FCAC expects a Bank to include how and when a Bank will remediate all affected Consumers where a recurring or systemic issue has been identified.
IV. Timely complaint-handling Policies and Procedures
25. FCAC expects a Bank’s complaint-handling Policies and Procedures to include clear steps that ensure complaints are Resolved or Closed within the 56-day prescribed period for dealing with complaints.Footnote 10
26. FCAC expects a Bank’s complaint-handling Policies and Procedures to document the following two possible outcomes when dealing with a complaint:
26.1. the complaint is resolved; the Bank has dealt with the complaint to the satisfaction of the person who made it (Resolved)
26.2. the complaint is closed; the Bank has dealt with the complaint but not to the satisfaction of the person who made it (Closed)
27. FCAC expects a Bank’s complaint-handling Policies and Procedures to refer to the 56-day prescribed period for dealing with complaints and to clarify that the initial timeframe begins on the day the complaint is first communicated to the Bank, by any channel.
27.1. FCAC expects that the 56-day prescribed period will not be paused for any reason. If there are circumstances beyond a Bank’s control where the 56-day prescribed period is exceeded, FCAC expects a Bank to document and record the reason for the delay.
28. FCAC expects a Bank to review complaints promptly, in a manner that accounts for their nature and circumstances, and with particular attention to the length of time a Consumer may spend at each step in the complaint-handling process.
Period for dealing with complaints
29. FCAC expects a Bank to identify, in its complaint-handling Policies and Procedures, the timeframe for referring complaints that have not been Resolved or Closed to a Designated Employee in a timely manner.
30. To be considered timely, the timeframe for referral to a Designated Employee should not exceed 14 calendar days from the date on which the complaint is first communicated to the Bank.
31. FCAC expects a Bank to provide Consumers with the option to escalate their complaint to a Designated Employee before the timeframe for referral has passed.
32. Any Employee may deal with complaints if they are the first point of contact between the Bank and the Consumer, regardless of the channel through which the complaint is communicated to the Bank.
33. If an Employee other than a Designated Employee cannot ensure that a complaint is Resolved or Closed within the timeframe for referral, they should refer the complaint to a Designated Employee without delay.
34. If an Employee other than a Designated Employee requires input or assistance from a Designated Employee, the complaint should be considered to have been referred to a Designated Employee. Therefore, the Bank must report it to FCAC.Footnote 11
35. Once a complaint has been received by or referred to a Designated Employee, it should continue to be dealt with by a Designated Employee. However, this does not preclude the possibility of continued interactions between the Consumer, the Designated Employee and an Employee who is not designated.
V. Accessible complaint-handling Policies and Procedures
36. A Bank’s complaint-handling Policies and Procedures must be easily accessible to all Consumers and describe:
36.1. how the Consumer can complain to the Bank through different channels, including both voice and electronic channels available to both current clients and non-clients. Electronic channels are expected to provide the consumer with a copy of their submitted complaint
36.2. the Bank’s complaint-handling process, including information on when the Bank will automatically refer the complaint to a Designated Employee, the action(s) that will follow, and the associated timelines
36.3. how the Consumer may escalate their complaint to a Designated Employee before the timeframe for referral has passed
36.4. the Consumer’s right to submit a complaint to the external complaints body on the earlier of the two following dates:
36.4.1. when the Bank’s prescribed 56-day period for dealing with the complaint has elapsed; or
36.4.2. when the Consumer has been provided with a Notice of Final Decision by the Bank
36.5. how and under what circumstances the Consumer can contact the external complaints body
36.6. how and for what purpose the Consumer can contact FCAC
37. FCAC expects a Bank’s complaint-handling Policies and Procedures to ensure that all Employees who deal with complaints are able to help Consumers navigate the Bank’s complaint-handling process, including referring their complaint to the external complaints body.
Providing information to Consumers
38. FCAC expects a Bank to be able to demonstrate that it has taken appropriate steps to give Consumers the information and documentation—such as contracts, agreements, and records of correspondence—that they need to meet the requirements set out in the Bank’s complaint-handling Policies and Procedures.
39. FCAC expects a Bank’s complaint-handling Policies and Procedures to ensure that all Employees involved in handling complaints know and understand the Bank’s disclosure obligations to Consumers under the Bank Act.Footnote 12
40. FCAC expects that the following information be made public on a Bank’s website(s) annually (or in writing when responding to a request):Footnote 13
40.1. the total number of complaints that its Senior Designated Employee dealt with that year
40.2. the number of Resolved and Closed complaints dealt with that year
40.3. the average length of time the Bank took to deal with those complaints, from the first interaction with the Consumer to the date on which the complaint was Resolved or Closed
40.4. the products or services to which the complaints relate
40.5. a description of the nature of the complaints, beyond the related product or service information contained in the classification
41. A Bank can respond to a request for information electronically if the request is submitted that way or if the Consumer consents to receive electronic documents.Footnote 14
42. The information a Bank provides to Consumers about its complaint-handling Policies and Procedures must be accurate and use language that is clear, simple and not misleading.
43. FCAC expects a Bank’s online, electronic and printed material to be clear and accurately reflect FCAC’s role using the required text provided in Annex I. The required text is expected to be presented in full and is not to be altered.
Acknowledging complaints
44. FCAC expects a Bank to acknowledge receipt of each complaint to the Consumer without delay regardless of the channel through which it was communicated. The acknowledgement should be in writing, Footnote 15 and take the form of a Notice of Acknowledgement, which includes:
44.1. the date the complaint was received
44.2. an overview of the Bank’s complaint-handling process, including:
44.2.1. any internal escalation process, the action(s) that will follow, and the associated timelines, including the prescribed timeline for dealing with the complaint
44.2.2. how and under what circumstances the Consumer can contact the external complaints body
44.3. a link or reference to the Bank’s complaint-handling Policies and Procedures
45. A Bank can acknowledge a complaint electronically if it was submitted that way or if the Consumer consents to receive electronic documents.
46. FCAC expects that, when responding to a Consumer’s complaint, a Bank’s communication clearly informs the consumer of the next step available to them in its complaint-handling process, including how the Consumer may continue or escalate the complaint.
47. FCAC expects a Bank to document and track each complaint to its final decision and provide Consumers with comprehensive, up-to-date information in a timely manner upon request.
Dealing with complaints when the Consumer has not provided their name
48. When a Bank receives a complaint from a Consumer who has not provided their name (for example, a complaint submitted through social media using a nondescript handle), FCAC expects the Bank to respond and provide the Consumer with the opportunity to access the Bank’s complaint-handling Policies and Procedures.
48.1. If that Consumer then decides to provide their identity, FCAC expects the Bank to deal with the complaint in accordance with its complaint-handling Policies and Procedures.
48.2. If that Consumer does not reveal their identity, the Bank is not expected to handle the complaint. However, FCAC expects a Bank to create a record of the complaint with the information it has available.
Notice of Final Decision
49. FCAC expects a Bank to inform a Consumer of the Bank's decision in respect of a complaint without delay and provide a Consumer with a written response titled “Notice of Final Decision.”
50. FCAC expects a Bank's Notice of Final Decision to represent a Bank's final decision, if applicable, in respect of a Consumer's complaint and to only be issued when a complaint is:
50.1. Closed by an Employee other than a Designated Employee
50.2. Resolved or Closed by a Designated Employee
51. FCAC expects the Notice of Final Decision to clearly indicate that it marks the conclusion of a Bank’s internal complaint-handling process.
52. The Notice of Final Decision is to include all the information a Consumer needs to make an informed decision about whether they are satisfied with the outcome, including:
52.1. the date on which the complaint was first communicated to the Bank
52.2. the timeframe the Bank took to deal with the complaint
52.3. a statement of facts relating to the complaint, including relevant timelines
52.4. the Bank’s final decision in response to the complaint, as well as all relevant information on how the final decision was reached (for example, financial or non-financial harm done to the Consumer)
52.5. the method used to determine redress and remediation, if applicable
52.6. information on the Consumer’s right to submit the complaint to the external complaints body, including how and when to contact that body
VI. Administrative processes and controls
53. A Bank must report to FCAC all complaints received by a Designated Employee directly or that were referred to them. This includes cases where a Designated Employee represents the first interaction between the Bank and a Consumer, whether or not the Consumer has provided their name.
54. A Bank must maintain a record of all complaints it receives, including any in which the Consumer is not named, and any received by or in relation to a Third Party.Footnote 16
55. A Bank must, without delay, provide the external complaints body with all relevant information about a complaint— including contracts, agreements, records of correspondence (both internal and with the consumer), transaction records, and any internal documents related to the Bank’s complaint investigation—once the external complaints body notifies the Bank that it has received the complaint.Footnote 17
56. FCAC expects that any information provided to the external complaints body during an investigation be submitted in a timely manner.
57. A Bank must report complaints to FCAC in accordance with FCAC’s Regulatory reporting guide for banks and authorized foreign banks.
VII. Miscellaneous
58. Questions relating to this Guideline can be sent by email to compliance@fcac-acfc.gc.ca or by mail to:
Financial Consumer Agency of Canada
Attention: Deputy Commissioner, Supervision and Enforcement Branch
427 Laurier Ave West, 5th Floor
Ottawa, ON K1R 7Y2
Annex I: Required text for FRFIs to include in online and print complaint-handling information for customers
Financial Consumer Agency of Canada (FCAC)
The Financial Consumer Agency of Canada supervises all federally regulated financial institutions, which includes banks, (financial institutions), for compliance with federal consumer protection laws.
Financial institutions are legally required to have a complaint-handling process in place.
If you have a problem with a financial product or service, you may file a complaint with the responsible financial institution directly.
If you are not satisfied with how your complaint has been handled or 56 days has passed since you made your complaint, you can escalate the complaint to the following External Complaints Body: [insert the name of the external complaint body, and link or refer to information on the external complaints body, as set out in online and print complaint-handling information for customers].
If you want to know your rights or need information about the complaint-handling process of a financial institution, you may contact FCAC by online form, mail, or telephone. FCAC uses information from consumer enquiries to support its mandate.
Web site: www.canada.ca/fcac
Online form: https://www.canada.ca/en/financial-consumer-agency/corporate/contact-us.html
Phone:
For service in English: 1-866-461-FCAC (3222)
For service in French: 1-866-461-ACFC (2232)
For calls from outside Canada: 613-960-4666
Teletypewriter (TTY): 1-866-914-6097 / 613-947-7771
Video Relay Service: FCAC welcomes Video Relay Service (VRS) calls. You do not need to authorize the relay service operator to communicate with FCAC. Visit https://srvcanadavrs.ca/en/ to learn more.
Mailing address:
Financial Consumer Agency of Canada
427 Laurier Avenue West, 5th Floor
Ottawa, ON K1R 7Y2