Frequently asked questions on the complaint handling process and template

  1. ​With respect to the section of Element 13 on informing merchants of a response delay, the reason and expected response time, how would you minimize the risk that a file could sit waiting an answer at some indeterminate point in the future?
    The internal complaint handling procedures of the payment card network operators (PCNOs) and acquirers should include a section with respect to response delays. It is expected that delays are not a common occurrence, and there should be descriptions as to what would be a reasonable reason for delays (e.g. complexity of the issue, no cooperation from the merchant).
  2. The instructions of the complaint procedure states that “Each PCNO is responsible for ensuring that the template is retainable (i.e. it has a downloadable option, a fillable PDF or a web format option available to merchants).” For added clarity, does this mean that when a complaint is lodged, with either an acquirer or a PCNO, the tool used to send the complaint must provide the merchant with a copy of the complaint that was submitted? That is, if a PDF file is created, or a web screen is generated, it must duplicate all the information provided?
    Merchants should be able to retain the information sent to the aquirer and/or PCNO. If the merchant sends the complaint
    electronically, the merchant should be able to retain a copy of the information sent.
  3. Element 13 requires that PCNOs and acquirers:
    • ​acknowledge receipt of a merchant complaint within five (5) business days, and
    • provide a final decision within ninety (90) days for acquirers and forty-five (45) days for PCNOs as of receiving the merchant complaint.

      Does the 90-day period include the first 5 business days, or does the clock start when the acknowledgement is sent?

      The Code refers to providing a final response within 90 days for acquirers and 45 days for PCNOs of receiving the merchant complaint. This 90- and 45-day requirement includes the 5 business days to acknowledge the complaint.
  4. Once a complaint is submitted by a merchant to an acquirer and/or PCNO, they have 5 business days to acknowledge receipt of the complaint. Is there a specific method of acknowledgement prescribed, or is it at the discretion of the acquirer?
    It is up to the discretion of the acquirer and/or PCNO whether to provide a verbal or written acknowledgement of the complaint. The internal complaint handling policies and procedures of acquirers and PCNOs should provide specifications in this regard.
  5. What format is the final decision to be provided to the merchant: oral or written?
    The final decision should be in writing. Sending a response electronically meets the “in writing” requirement.
  6. What format should the response be if there is a delay in providing a response to a merchant?
    It is up to the discretion of the acquirer and/or PCNO whether to provide a verbal or written response concerning the delay, the reason for the delay and the expected response time. The internal complaint handling of policies and procedures of acquirers and PCNOs should provide specifications in this regard.
  7. In the event that a merchant is not satisfied with the results of the acquirer’s investigation and explanation of its decision, and the merchant wishes to escalate the complaint further, what is the merchant’s escalation path: to the PCNO or to the Financial Consumer Agency of Canada (FCAC)?
    Merchants should follow the established process of the acquirer to further escalate their complaints. This is typically to the PCNO.
    Merchants can be referred to FCAC at any time during the process; however, FCAC does not provide redress or compensation and does not get involved in individual disputes. FCAC’s responsibility is to monitor whether PCNOs are compliant with the Code.
  8. Is there a way for the merchant to indicate the urgency of the complaint or proposed potential way to resolve its complaint?
    The standard complaint handling form includes a summary of the complaint that asks the merchant to provide details of the complaint, which can include suggestions for resolution.
  9. With respect to the example of a complaint handling procedures summary for merchants, although the wording is generic, would it be possible to modify the instruction language as needed in order to best communicate with merchants?
    The complaint handling procedures summary for merchants is an example of what should be included to provide merchants with an overview of the complaint handling procedures of the PCNO or the acquirer. It also should assist merchants in filing a comprehensive complaint.

    This example can be modified to communicate effectively with merchants. We note, however, that the complaint form should closely mirror the template provided on our website. Slight variations are acceptable as long as
    all the fields are included.
  10. Can we move the order of the fields in the common template?
    As long as all the fields are included in the form, the order of the fields can be changed.
  11. Uploading attachments online may be a technological challenge. Can there be an option for merchants to send in supporting documents rather than uploading them?
    Supporting documents can be either uploaded or sent by mail or email.
  12. In the common template, where you request the merchant to identify the Code element that applies to their complaint, can the merchant choose more than one element?
    If there is a fillable version, there should be the opportunity to include either a drop-down menu or check boxes of all elements that the merchant can choose. It is the responsibility of the PCNO and/or acquirer to provide this option if available.

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