ComplaintsProcess

Purpose

To ensure complaints are identified, acknowledged, escalated, investigated, resolved and retained in a fair, timely, consistent and auditable manner. This process supports Fair Treatment of Customers, insurer expectations, HUB Financial oversight standards, and provincial insurance council expectations.

Area of Impact

All complaints received by Solomon Financial, Advisors, Staff, contractors, representatives, websites, social media pages, insurer channels, HUB Financial channels or regulators.

Source Alignment

HUB Financial compliance requirements.
FINTRAC guidance for life insurance companies, brokers and agents and compliance program requirements.
CCIR/CISRO Conduct of Insurance Business and Fair Treatment of Customers guidance and CISRO Principles of Conduct for Insurance Intermediaries.
CLHIA Guideline G2 and CCIR/CISRO Segregated Funds Guidance expectations for IVIC/segregated fund disclosure, distribution, sale and servicing.
PIPEDA, provincial privacy rules where applicable, and OPC breach-record guidance.

Definition of Complaint

A complaint is any verbal, written or electronic expression of dissatisfaction about Solomon Financial, an Advisor, Staff member, service, recommendation, disclosure, product, compensation matter, privacy matter, marketing material, administrative handling or conduct matter where the concern cannot be resolved as a simple service request at first contact.

Complaint Type	Examples	Initial Risk
Service / Administration	Delay, missing paperwork, incorrect routing, follow-up concern	Low to Medium
Disclosure / transparency	Compensation, conflict of interest, product limitation, insurer responsibility	Medium
Suitability / conduct	Unsuitable sale, pressure tactics, replacement concern, misrepresentation	High
Privacy / cybersecurity	Unauthorized disclosure, lost device, misdirected email, compromised account	High to Critical
AML/ATF / fraud	Suspicious activity, attempted suspicious transaction, false identity, suspected elder abuse or undue influence	High to Critical
Regulatory / insurer / HUB inquiry	Complaint from regulator, insurer or HUB Financial Compliance	Critical

Complaint Intake Channels

Email: compliance@solomonfinancial.ca or other management-approved complaint inbox.
Telephone: Solomon Head Office 403.346.0095.
Website: Solomon Financial complaint page or complaint form.
Advisor websites and social profiles: mandatory link to Solomon complaint process and statement that complaints cannot be handled solely by the Advisor named in the complaint.
Mail or in-person delivery to Head Office.
Insurer, HUB Financial, regulatory, social media or third-party referral channels.

Immediate Handling Rules

The subject of a complaint must not independently control, suppress, delete, alter or resolve the complaint without notifying the Compliance Officer or designated leadership contact.
Forward complaints to the Compliance Officer or designated complaint owner as soon as practicable.
Preserve all records and evidence immediately, including emails, notes, applications, KYC/KYP records, disclosure forms, Reasons Why letters, marketing materials, screenshots and messages.
Do not admit liability, offer compensation, destroy drafts, alter documentation or make promises about outcomes without management direction.
Escalate immediately if the complaint includes privacy breach, cybersecurity, vulnerable client harm, fraud, AML/ATF concern, fund transfer issue, licensing/E&O concern, unsuitable sale or regulatory inquiry.

Complaint Workflow

Receive the complaint and determine whether it is a service request or complaint.
Open a complaint file and assign a complaint owner who is independent from the subject of the complaint.
Acknowledge receipt in writing and provide the complainant with the contact person, expected process and escalation options.
Classify the complaint by issue type and risk rating. Identify any privacy, AML/ATF, client vulnerability, misconduct, insurer or regulatory escalation triggers.
Collect, preserve and review all relevant documents and communication records.
Interview the Advisor, Staff member or other relevant parties. The subject of the complaint may provide information but must not be the sole investigator or decision maker.
Determine whether HUB Financial Compliance, the insurer, privacy officer, legal counsel, E&O carrier or a provincial regulator must be notified.
Document findings, corrective action, client communication, training, supervision, compensation remedy if approved, and final outcome.
Issue written response where appropriate. If unresolved or carrier-related, provide external escalation options, including the applicable insurer complaint process and OmbudService for Life & Health Insurance for life and health insurance matters.
Close the complaint file only after resolution, documented escalation, withdrawal, referral or final decision.

Complaint Register Required Fields

Field	Requirement
Complaint ID	Unique identifier.
Date/time received	Date, time and channel.
Client / complainant	Name and contact information.
Advisor / Staff involved	Name, role and code if applicable.
Issue category	Service, suitability, product, disclosure, privacy, marketing, AML/ATF, vulnerable client, conduct, other.
Risk rating	Low, Medium, High, Critical.
Complaint owner	Compliance Officer or designated management reviewer.
Documents preserved	List of records retained.
Escalations	HUB, insurer, regulator, privacy, AML, legal or E&O escalation.
Outcome	Resolved, ongoing, escalated, rejected, withdrawn.
Closure date	Date closed and final response sent.
Retention location	Complaint register and related file path.

Recommended Tools & Resources

Complaint Intake Form and Complaint Register.
Solomon Disclosure document updated to include complaint process.
Solomon website complaint page and Advisor-branded website complaint link.
Client file, KYC/KYP documentation, Needs Analysis, Reasons Why letter and disclosure templates.
HUB Financial Compliance resources and insurer complaint guidance.
OmbudService for Life & Health Insurance (OLHI) and provincial insurance regulator complaint resources.

Training and Monitoring Requirements

Complaint recognition and escalation training at onboarding.
Refresher training for Advisors, Staff, and support personnel.
Quarterly review of open and closed complaint register entries by Compliance Officer or designate.
Annual trend analysis to identify recurring issues, training needs and process gaps.

Ramifications

Failure to identify, document, escalate or handle complaints fairly may result in client harm, regulatory scrutiny, insurer or HUB Financial escalation, mandatory retraining, enhanced supervision, suspension of privileges, termination of affiliation, regulatory reporting, civil liability or reputational harm.

Click Here to File a Complaint