Notice and Request for Comment onProposed Amendments toNational Instrument 31-103Registration Requirements, Exemptions and Ongoing Registrant Obligations(“NI 31-103”)and toCompanion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations(“31-103CP”)

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Notice and Request for Comment onProposed Amendments toNational Instrument 31-103Registration Requirements, Exemptions and Ongoing Registrant Obligations(“NI 31-103”)and toCompanion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations(“31-103CP”)

Letter Summary:

We believe that including a deadline for escalating complaints to OBSI would help registrants conduct their affairs with more certainty, including maintaining the appropriate reserves and notations in their financial statements. We believe 180 days is an acceptable period of time within which to escalate a complaint. We note however that it is important that clients be made aware of the internal process within each registrant to resolve complaints prior to contacting OBSI, and of the 180-day deadline for contacting OBSI. Registrants should be specifically required to provide clients with OBSI’s contact information, together with any required forms necessary to start the escalation process, at the time the clients are notified of the outcome of the internal complaint review.

Overview of the Council’s Comments:

As a general matter, the CAC agrees with the choice of the Ombudsman for Banking Services and Investments (“OBSI”)as the dispute resolution service for the discharge of a registrant’s obligation (outside of Quebec) under Section 13.16 of NI 31-103.