Gestion Phocus
Richard Benoit Financial Services Inc. AND Steeve Mc Lean Financial Services Inc.
Date: 06/15/2024 to 06/15/2025
Application of this Policy
Gestion Phocus, a financial services firm, is responsible for handling complaints regarding life insurance representatives formally affiliated with it under the law.
As a result, this policy applies to all life insurance representatives associated with Gestion Phocus.
Purpose of the Policy
The purpose of a complaint handling and dispute resolution policy is to establish a fair and free process for managing complaints received by a life insurance representative (subject). Specifically, it aims to regulate the receipt of complaints, the issuance of acknowledgments and notices to the complainant, the creation of complaint files, the transfer of those files to the Autorité des marchés financiers (hereinafter the “Authority”), and the compilation of complaints for the development and submission of a biannual report to the Authority.
The Person Responsible
The compliance department of Gestion Phocus Financial Services Inc. is responsible for implementing the policy and acts as the contact person with the Authority. This person ensures that staff and representatives are trained and informed of this policy. Their responsibilities include:
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Sending an acknowledgment of receipt to the complainant
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Sending the required notices to the complainant
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Transferring the file to the Authority, at the complainant’s request
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Maintaining a complaint register
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Submitting a biannual report to the Authority
Complaint
For the purposes of this policy, a complaint involves at least one of the following elements:
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A reproach against a subject (mutual fund dealing representative)
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Identification of a real or potential harm suffered or that could be suffered by a consumer
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A request for corrective action
An informal step aimed at resolving a specific problem is not considered a complaint, as long as the issue is addressed within the representative’s normal activities and the consumer has not formally filed a complaint. A complaint must be submitted in writing by the complainant to be admissible.
Receipt of Complaint
Consumers wishing to file a complaint must do so in writing to the following address:
Gestion Phocus Financial Services Inc.
545 Saint-Georges Street, La Prairie QC J5R 2N2
Tel: 450-985-2940
Fax: 450-922-4701
assurance@gestionphocus.com
Any person who receives a complaint must forward it immediately to the person responsible for this policy. If a representative receives a written complaint at their office, they must immediately forward it to the compliance department at Gestion Phocus Financial Services Inc. The compliance officer must acknowledge receipt of the complaint within five (5) business days, stating that the complaint will be reviewed within 90 days. The acknowledgment must include at least the following:
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A description of the complaint, specifying the harm suffered or potential harm, the reproach made against the representative, and the requested corrective action
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The name and contact information of the person responsible for handling the complaint
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In the case of an incomplete complaint, a notice requesting additional information to be provided within 15 days, failing which the complaint will be deemed abandoned
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A copy of the complaint handling and dispute resolution policy
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A notice informing the complainant of their right to request that the file be transferred to the Authority if they are not satisfied with the outcome or the handling of the complaint after the 90-day period has expired
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A notice stating that the Authority may offer mediation if deemed appropriate and both parties consent
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A notice explaining that mediation is an amicable settlement process in which a third party (mediator) helps the parties reach a satisfactory agreement
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A notice informing the complainant that filing a complaint with the Authority does not interrupt the limitation period for legal proceedings in civil courts
Creation of the Complaint File
Each complaint must have a separate file, which must include:
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The complainant’s written complaint, including the three required elements (reproach against the representative, actual or potential harm, and requested corrective action)
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The result of the complaint handling process (analysis and supporting documents)
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A copy of the representative’s final written and reasoned response sent to the complainant
The complaint file is kept at the office of Gestion Phocus Financial Services Inc.
Complaint Handling
Upon receiving a complaint, Gestion Phocus must conduct an investigation to determine the facts related to the allegations. Gestion Phocus must handle each complaint fairly and impartially and provide an appropriate response based on the circumstances. The complaint must be processed within a reasonable time once all necessary information is received. Upon conclusion, the compliance officer must send the complainant a final, written, and reasoned response.
Transferring the File to the AMF
If the complainant is dissatisfied with the outcome or handling of the complaint, they may request that Gestion Phocus forward the file to the Autorité des marchés financiers (AMF). This right may only be exercised after the deadline for receiving a final response has passed. The transferred file must contain all documents related to the complaint. It remains the responsibility of the firm to ensure the protection of personal information.
Creation and Maintenance of the Register
A complaints register must be created to apply this policy. The compliance officer at Gestion Phocus (Richard Benoit) is responsible for updating it. Any complaint that meets the definition must be entered in the register, specifically:
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Any written complaint, regardless of the level of involvement in handling it
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Any lawsuit that meets the definition of a complaint
Biannual Report
The compliance officer must send the Authority a report indicating the number and nature of complaints received, categorized according to the register, by the following deadlines:
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No later than July 30 each year for data collected between January 1 and June 30
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No later than January 30 each year for data collected between July 1 and December 31