Submissions to Government

PMAC Submission – AMF Consultation on Regulation respecting complaint processing and dispute resolution in the financial sector

PMAC’s mission statement is “advancing standards”; we are consistently supportive
of measures that elevate standards in the industry and improve investor protection.
PMs generally manage client assets on a discretionary basis; they are subject to the
highest proficiency standards in the industry and are fiduciaries to their clients, with
a duty to act in clients’ best interests.

PMAC supports the AMF’s goal of ensuring the fair processing of consumer
complaints in the financial sector and of imposing standards for investor complaints
across different types of firms. However, we have serious concerns that, as drafted,
the Draft Regulation will impose undue regulatory burden and costs to PM firms,
without a corresponding investor protection benefit. We have detailed our key
recommendations and concerns below.

This submission is available in English and French.