This procedure falls within the scope of the new amendments made to Dealer Member Rules 19, 37 and 2500 regarding the handling of complaints and the settlement of disputes, as approved by competent securities authorities.
The purpose of this procedure is to establish a procedure ensuring the free and equitable handling of all complaints received by Laurentian Bank Securities Inc., hereinafter referred to as “the regulated organization”. It is intended, more specifically, to provide a framework for the receipt of complaints, the delivery of the acknowledgement of receipt and the notice to the complainant, the creation of the complaint file, the transfer of this file to the Autorité des marchés financiers (hereinafter referred to as “the Autorité”) at the complainant’s request when applicable, and the filing of the complaint report with the Autorité.
The Chief Compliance Officer is responsible for the application of this procedure.
As the person in charge of the application of the procedure, the Chief Compliance Officer acts as a representative with regulatory authorities and is responsible for training staff and providing them with relevant information to ensure that this procedure is applied according to requirements.
In addition to the above-mentioned duties, the person in charge is responsible for:
For the purposes of this procedure, a complaint must meet the three following conditions:
Instances of misconduct are: breach of privacy, theft, fraud, misappropriation or illegal use of funds or securities, forgery, inappropriate investments, misrepresentation, or unauthorized transactions pertaining to clients’ accounts, other unauthorized financial transactions with clients and the conduct of securities related activities outside of the broker.
Shall not constitute a complaint any first-level intervention consisting in a consumer’s communication that is part of an informal process aimed at correcting a specific problem, provided that the issue is settled in the regular course of business, without the consumer being required to file a formal complaint.
To be receivable, a filed complaint, other than those relative to customer service, must be made in writing by the complainant.
Shall also be receivable a verbal complaint alleging misconduct when a preliminary investigation indicates that the allegation may be substantiated in some way.
Consumers who wish to file a complaint must do so in writing to the following address:
Laurentian Bank Securities Inc.
C/O Compliance Department
1981 McGill College Avenue
Any employee who receives a complaint shall, upon reception, forward the complaint to the person in charge of the application of this procedure.
The person in charge acknowledges reception of the complaint within 5 business days. The acknowledgement of receipt shall include the following information:
A distinct file must be created for each complaint received. The file shall include the following elements:
Upon reception of a complaint, the regulated organization conducts an investigation. The complaint shall be handled within a reasonable 90-day delay following the reception of all required information. At the end of the investigation, the person in charge forwards to the complainant a written, final and justified answer. A copy of this procedure is enclosed with the detailed answer.
When a complainant is dissatisfied with the examination of his or her complaint by the regulated organization or with the outcome of the examination, he or she may request that the latter forward his or her complaint file to the Autorité. This right may not be exercised by the complainant until the delay provided for the reception of a final answer has expired or, at the latest, later than one year following the reception of that answer. The transferred file contains all of the documents pertaining to the file. The regulated organization remains responsible for complying with the access to information procedure.
A distinct file is created for each complaint established for the purposes of applying this procedure, and is kept for seven years by the person in charge.
The following information is kept with regard to each complaint:
This procedure was updated on February 1, 2010.
For the past few years, Alternative Trading Systems (“ATS”), including Alpha, Chi-X, Pure and Omega to name a few, have been operating in Canada, thus providing increased liquidity and an alternative for securities transaction turnaround. Subject to Canadian securities regulations, Laurentian Bank Securities (“LBS”) must guarantee the best price and the best execution for client orders. For this purpose, LBS uses a computerized system that provides clients with services that meet their requirements.
During regular trading hours, LBS uses a computerized system developed by the Toronto Stock Exchange to execute client orders at the best price, on one or more Canadian markets. Throughout the order routing process, LBS considers all visible markets.
Unless otherwise indicated, LBS decided to elect the Toronto Stock Exchange (TSX) as its main market to facilitate the execution of its clients’ orders.
Trading hours for most stock exchanges and ATS in Canada are 9:30 a. m. to 4:00 p.m., Eastern Standard Time (“EST”), Monday to Friday, except for official Canadian statutory holidays. Client orders made during regular business hours are entered in the order routing system and are processed based on client instructions, according to the trading hours of the market on which they are entered, to guarantee the best possible execution. Orders entered before or after regular trading hours are sent to LBS’s main market.
In a multiple marketplace environment, specific order types require special processing. Unless otherwise indicated, orders will be processed according to the description provided in this document.
Market orders are orders to buy or sell a security at the current prevailing market price, to help ensure a complete and full execution. LBS immediately routes market orders via its computerized system, which checks every available market and books the order on the market that guarantees the best price.
Limit orders are orders for a security at a minimum sale price or a maximum purchase price set by the client. When a limit order cannot be executed immediately, LBS routes it to a market that offers the best chance of execution. The order remains on the said market until it is filled, cancelled or expired. In a multiple market environment, once the order is entered on a marketplace, it is possible for the security to trade in other markets, while the client’s order remains unexecuted.
This type of order, which is valid for one day only, instructs the receiving market to automatically expire the order if it has not been executed in the same trading day.
This type of order remains active until it is cancelled by the client or until it exceeds its set duration. The maximum duration for this type of order is 30 calendar days. Clients are responsible for monitoring the evolution of their orders and to contact their Investment Advisors to extend their orders before they expire. Orders can also have a set expiry date within the 30 day period.
Special Terms Orders
This type of order includes terms that cannot be executed in the regular marketplace. These orders will be routed to LBS’s main market. Using special terms may delay or reduce the chance that orders will be executed, and these orders are valid only during regular business hours.
The “market-on-close” designation means that the whole order is to be executed at the official closing price of the marketplace it is entered upon. Not all markets support this type of order in their systems. For more details, please contact your Investment Advisor.