Trusted Contact Person

With the objective of protecting the assets of our clients and to meet the new requirements of the  Canadian regulatory authorities, including the  AMF, we developed a policy to address the evolving needs of aging and vulnerable clients and issues that may arise in their interactions with FIS or a representative. 

Vulnerable clients and financial abuse

Vulnerability can affect clients of all ages, takes many forms and may be temporary, sporadic or permanent. This objective of acting in  your interest will guide the actions taken by FIS and its representative in the application of the terms and conditions described herein. 

When opening an  account or updating your information, you  will be asked to identify a trusted contact person whom FIS may contact if needed, but only under the  conditions described below. Your representative will ask you  for the name, mailing address, telephone number and e-mail address of the person, as well as the relationship of trust that unites you. The trusted contact person will be a  resource to  help FIS and  its representative protect your interests and financial assets in the event of possible financial abuse or concerns about your potential vulnerability. You may refuse to give us contact information for a trusted contact person. 

You may also withdraw a consent previously communicated. If you wish to make changes to the contact information of your trusted contact person or to replace this person by another, please contact our Advisory Service or your representative.

Circumstances in which we will communicate with your trusted contact person

We may find it necessary to communicate with your trusted contact person after witnessing indicators of vulnerability as a result of, for example, a face-to-face meeting or a telephone discussion, and after a reasonable effort to discuss our concerns with you. 

The following indications of vulnerability, whether taken individually or not, are given as examples only; other circumstances may prompt us to contact your trusted contact person:

  • Sudden or unexplained withdrawals; 
  • Unexplained change in investor profile; 
  • Unusual transaction instructions from a mandatary; 
  • Refusal or sudden difficulty concerning the scheduling of a meeting after the appointment of a mandatary; 
  • Evidence of physical neglect or abuse.

Examples of indicators of concern that a vulnerable person can no longer make financial decisions:

  • PMemory loss, such as forgetting personal information allowing identification at the start of a call;
  • New confusion or misunderstanding of previously understood financial concepts;
  • Increased passivity, anxiety or aggressivity or other sudden mood or personality changes.

We may also communicate with your trusted contact person when it comes to temporarily blocking one or more of your accounts.

What we will communicate to your trusted contact person

We will communicate with your trusted contact person to share indications of vulnerability that we have observed. We will not share your personal information. We will not take any transaction instructions from that person. We may also contact your trusted contact person to confirm your contact information or if we have difficult contacting you. 

When we communicate with your trusted contact person, we will comply with our obligations under the Privacy Protection Notice and the Mutual Investment Fund Account Agreement.

Temporary blocking

FIS may assess that it is in your interest to temporary block one or all of your accounts, if we reasonably think that you have been, are, or may be a victim of financial exploitation, or that your vulnerability does not reasonably allow you to make decisions concerning your financial matters. You will be quickly notified of this temporary blocking and the reasons that led us to act in order to preserve your assets held at FIS. We have a regular reassessment mechanism for accounts blocked temporarily for the reasons stated above, with the aim of maintaining the freeze only if the circumstances justifying it are still present.

Achieve financial independence faster

Think about the future. Start investing today.