This policy is part of the provisions of the Act respecting the distribution of financial products and services with respect to the handling of complaints and the settlement of disputes.

1. Purpose of the policy

The purpose of this policy is to provide a fair and free process for all complaints received by LMBF inc., hereinafter referred to as "the firm". It aims in particular to supervise the reception of a complaint, the transmission of an acknowledgment of receipt, the constitution of a file of complaint, the transmission to the Authority of the financial markets ("the Authority").

2. Responsible person

a. The person responsible for the application of this policy in our office is Milad Boutros.

b. As person in charge of the application of the policy, this person acts as a sponsor with the AMF and sees to the training of the personnel and to transmit to him the relevant information with a view to a correct application of this policy.

c. The manager also has the following functions:

  • To ensure the transmission of acknowledgment of receipt of complaints.
  • To transmit the file to the Authority, at the request of the complainant.
  • Maintain a register of complaints.

3. Complaints

a. For the purpose of this policy, this complaint must state one of the following three elements:

  • Complaint against the firm, one of its brokers or an employee.
  • Identification of potential or actual harm to a consumer.
  • The request for a corrective measure.

b. A complaint does not constitute the first manifestation of dissatisfaction or the informal approach of a consumer to correct a particular problem that can be resolved by one of the firm's areas of operation.

4. Reception of the complaint

a. Consumers wishing to file a complaint must do so by email at the following address: info@lmbf.ca or by mail at the following address: 1955 CH. De La Côte-de-Liesse suite 201 Saint-Laurent, QC H4N 3A8

Any broker or employee of the firm who is seized of a complaint must refer it, as soon as it is received, to his immediate superior, if not to the person responsible for the application of this policy.

The responsible person acknowledges receipt of the complaint within 5 working days. The acknowledgment of receipt must contain the following information:

  • A copy of this policy.
  • A description of the complaint received.
  • The name and contact information of the person responsible for handling the complaint.
  • In the case of an incomplete complaint, a notice stating the need to provide the person responsible with additional information within 5 working days, failing which the complaint is deemed to have been abandoned.
  • A notice to the complainant of his right to request, upon the expiry of 15 working days from receipt of all necessary information and no later than one year after the response to his complaint, the transfer of his file with the AMF, if it is dissatisfied with the response or the handling of its complaint and the AMF may offer mediation if the parties consent.
  • A reference to the complainant indicating that mediation is a process of amicable resolution of a dispute by which a person intervenes with the parties to help them reach a satisfactory agreement.

5. Constitution of the complaint file

a. Any complaint received must be the subject of a separate file opening.

b. The file must include the following elements

  • Complainant's complaint, including one of the three elements of a complaint (the complaint against the firm, the broker or the employee, the actual or potential harm and the corrective action requested).
  • The outcome of the complaint process (the analysis and supporting documents).
  • A copy of the firm's final reasoned response that was sent in writing to the complainant.

6. Treatment of a complaint

a. Upon receipt of a complaint, the person identified in paragraph 4.2, his / her immediate supervisor and the complaint manager shall conduct an investigation.

b. The complaint must be processed within 15 working days after receipt of all necessary information.

c. At the end of the investigation, the manager shall forward to the complainant the final written and reasoned response of the firm.

7. Transmission of the file to the Authority

a. When the complainant is not satisfied with the examination of his complaint by the firm or the result of this examination, he can ask the firm to transfer his complaint file to the AMF.

b. This right can be exercised by the complainant only after the expiry of the 15 working days deadline for obtaining a final answer or at the latest 1 year after this answer.

c. The file transferred to the AMF consists of all the documents relating to the complaint file.

8. Creating and maintaining a register

a. The firm establishes a complaints register for the purpose of applying this policy. Its update is the responsibility of the responsible person.

b. Must be registered in this register, any complaint formulated and corresponding to the definition of article 3.