The Financial Consumer Agency of Canada (FCAC) published a supervisory highlight summarizing a thematic review of the banking sector’s compliance with legislative complaint-handling procedure obligations under the Financial Consumer Protection Framework. Based on detailed work across six small and medium-sized banks, FCAC found recurring weaknesses in complaint record-keeping, meeting the 56-day resolution requirement, and the quality and governance of quarterly complaints reporting, while the 14-day internal escalation requirement was generally understood and embedded in policies. Key issues included employees not fully applying the expanded Bank Act definition of “complaint,” with some banks differentiating between expressions of dissatisfaction and “formal” complaints, leading to incomplete records and limited review of complaint data. On timeliness, FCAC identified failures to resolve complaints within 56 calendar days, including inefficient multi-level internal processes, weak internal referral structures, lack of designated-employee access to complaint records, attempts to “freeze the clock” while awaiting consumer responses, and practices that excluded senior-most designated employees from the 56-day period. Reporting gaps centred on the absence of end-to-end internal procedures and data validation for quarterly complaints reports, with submissions missing required information such as complaint descriptions and investigative steps. FCAC also flagged inconsistent issuance of substantive written responses for complaints closed within 14 days by non-designated staff, weak monitoring and controls over complaint record access and modification, late-stage internal alerts that left insufficient time to meet the 56-day limit, and insufficient safeguards to ensure third parties comply with applicable consumer provisions where banks offer products through third-party arrangements. Each of the six participating banks received institution-specific feedback and is required to implement corrective actions, with FCAC actively monitoring progress. FCAC also expects all Canadian banks to review the findings, assess their own compliance with complaint-handling requirements, and address any deficiencies in a timely manner.
Financial Consumer Agency of Canada 2025-07-31
Financial Consumer Agency of Canada identifies complaint-handling shortcomings at small and medium-sized banks and sets remediation expectations
The Financial Consumer Agency of Canada (FCAC) released a supervisory highlight from a review of six small and medium-sized banks, identifying weaknesses in complaint record-keeping, resolution timeliness, and reporting quality under the Financial Consumer Protection Framework. Issues included incomplete complaint records, failure to meet the 56-day resolution requirement, and reporting gaps. FCAC requires corrective actions from the reviewed banks and urges all Canadian banks to address compliance deficiencies.