Introduction
On September 2, 2013, new regulations and commissioner's
guidance from the Financial Consumer Agency of Canada (the
"FCAC") came into effect. These regulatory frameworks
impose three overarching changes: (i) guidance with respect to the
creation and operation of internal dispute resolution practices and
procedures of federally regulated financial institutions
("FRFIs"); (ii) enhanced oversight requirements for
external complaints bodies that provide services to banks listed in
Schedule I and II of the Bank Act, as well as authorized
foreign banks (which are the subject of an order under subsection
524(1) of the Bank Act) (collectively, "Banks");
and (iii) additional dispute resolution reporting requirements for
Banks. As a result of these amendments, all FRFIs should review
internal dispute resolution practices and procedures to ensure
compliance, and each Bank should additionally ensure that the
external complaints body to which it is a member has been
