This policy governs compliance for Caméléon Hypothèques. It must be applied diligently and used as a tool to support the practice of autonomous mortgage brokers and firms in meeting the requirements of the Autorité des marchés financiers (the “AMF”).
For the purposes of this policy, a complaint includes at least one (1) of the following three (3) elements:
An informal request to correct a specific issue is not a complaint when the matter is handled in the ordinary course of the mortgage broker’s activities and the consumer has not filed a complaint.
The compliance officer, Mr. Jean-François Choquette, is responsible for implementing this policy. The compliance officer must provide staff with all information required to comply with this policy.
A summary of this policy must be available on the firm’s website, if applicable. The summary must at minimum (i) describe what communications constitute a complaint that must be recorded in the complaints register, and (ii) state that the firm must open a file for each such complaint.
The compliance officer must ensure that a complaints register is created.
Each complaint file must be entered in the register.
The compliance officer is also responsible for managing the register, including mandatory filings to the SRP (complaints reporting system) as provided in section 7 of this policy.
Whenever a complaint is reported in any form, the compliance officer must open a file and record the date of receipt in the complaints register. The person receiving the complaint must invite the complainant to submit the complaint in writing or must record all verbal details of the complaint.
If someone other than the compliance officer receives the complaint, the employee must notify the compliance officer without delay.
A copy of the written complaint, or the written record if verbal, must be placed in the file.
Any consumer wishing to file a complaint must do so in writing at the following address:
Mr. Jean-François Choquette
1060 Michèle-Bohec Blvd., Suite 101, Blainville, QC J7C 5E2
418-204-7738
info@consortiumhypothecaire.com
Upon receipt of a complaint, the compliance officer must initiate the complaint handling process.
The compliance officer must send an acknowledgement of receipt to the complainant without delay, or no later than five (5) days after receipt of the complaint.
The acknowledgement must include:
If the complaint file is transferred, the transferred file must include all information relating to the complaint.
Compliance with personal information protection rules remains the mortgage broker’s responsibility.
The file must include:
The compliance officer must collect and analyze relevant comments and documentation and obtain any additional information deemed necessary.
Where applicable, the compliance officer or the mortgage broker named in the complaint must notify their professional liability insurer without delay.
When the compliance officer has completed handling the complaint, they must prepare a report and inform the complainant of the investigation results in a written, reasoned response. The report and response must be filed in the complaint file.
Once a year, the compliance officer must submit a report to the AMF through the SEL system on the number and nature of complaints received, whether or not any complaints were received, except where there is only one (1) mortgage broker in the firm.
In that case, a report is filed only when complaints were actually received.
The reporting period is March 1 to May 1 each year for data collected between January 1 and December 31 of the previous year.
This policy must be reviewed annually by the compliance officer, who must document the review work.
The document must address, among other things, whether the policy should be updated, any proposed changes and their rationale.
If an external review occurs during the year, the report’s recommendations must be incorporated into the policy where applicable.
This compliance policy has been in effect since December 17, 2020, and was last updated April 22, 2025.
This page is an English overview. The authoritative, full legal text is maintained in French for Caméléon Hypothèques and may be consulted on the French version of this site or by contacting the compliance officer below.