90-Day Complaint Handling: Definition + Case Study

90-Day Complaint Handling

The CIRO rule requiring dealers to deliver a substantive response to a client complaint within 90 days.

Definition

Under the CIRO IDPC Rules' complaint-handling provisions, a dealer must acknowledge receipt of a complaint in writing within 5 business days and provide a substantive written response within 90 days of receiving the complaint. The substantive response must address the merits of the complaint and inform the client of their right to escalate to OBSI if they are not satisfied. The 90-day clock starts from the date the complaint is received, not from when the firm starts investigating. Failure to meet this deadline gives the client the right to take the complaint to OBSI immediately.

Source

CIRO IDPC Rule 3700 series, complaint-handling provisions; OBSI terms of reference

Where this shows up on the CIRE

Outcome 9.2

Test yourself

Two real CIRE-bank questions on this exact outcome. Click to reveal the answer and the rule citation.

1
Under CIRO's recordkeeping requirements, for how long must a dealer member generally retain records related to client accounts and transactions?
Outcome 9.2 · click for answer
A.Records must be retained for a minimum of one year from the date of the transaction.
B.Records must be retained for a minimum of seven years, with certain records accessible for the first two years.Correct
C.Records need only be retained until the client relationship ends.
D.Records must be retained for 25 years to align with the provincial statutes of limitations for civil claims.
CIRO's recordkeeping rules generally require dealer members to retain books and records related to client accounts and transactions for a minimum of seven years, with records from the most recent period remaining readily accessible. This retention period supports both regulatory examinations and client dispute resolution. Retention ending at the close of the client relationship or after only one year would be inconsistent with the multi-year investigative and litigation windows that regulators and courts apply.
2
Under IDPC Rule 1201, a 'material conflict of interest' is defined as a conflict that could be expected to affect what?
Outcome 9.2 · click for answer
A.The dealer's regulatory capital ratios by more than 5%.
B.The registrant's compensation in any calendar quarter.
C.The decisions made by a reasonable client, or that a reasonable client would expect to be told about.Correct
D.The suitability assessment of at least 10% of the dealer's retail accounts.
IDPC Rule 1201 defines a material conflict of interest as one that a reasonable client would expect to know about, or that could reasonably be expected to affect the decisions of a reasonable client. The test is objective; it focuses on the perspective of the reasonable client, not on monetary thresholds relative to the dealer's capital or the number of accounts affected. Conflicts that are purely internal administrative matters and would not affect client decisions are not material under this definition.

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