Frequently asked questions: Reporting Guide for the Code of Conduct for the Credit and Debit Card Industry in Canada
- There was concern about the potential for confusion in the acquirer and independent sales organization communities with respect to the reporting requirements. We suggest that the descriptions of complaint categories align more closely with the Code of Conduct for the Credit and Debit Card Industry in Canada (the Code).
The guide for reporting Code-related complaints accompanies the aggregate reporting form. This guide refers to the applicable element of the Code and provides a description. In addition, we have included the elements of the Code in the aggregate report form to each classification. This should clarify what classification to use when reporting Code-related complaints.
- Will the aggregate reporting form replace the quarterly Compliance Framework report?
The quarterly reporting requirement section of our Compliance Framework will be amended to reflect the updated Code requirements for semi-annual reporting by payment card network operators.
- Should the report capture voluntary commitments (i.e. zero liability)? Some elements of the form do not apply to acquirers, e.g. Element 7: equal branding and Element 9: premium products. Will an acquirer-specific form be available?
The FCAC reporting form was created to capture the elements of the Code. However, this form will be amended to include public commitments and will be available on FCAC’s website. The form will be provided to PCNOs who in turn may modify it to assist aquirers when reporting complaint data to PCNOs.
- The reporting form is unclear as to what should be included in the outcome/resolved column. How should a complaint that was initially found non-compliant but was then resolved and is now compliant be reported?
If the complaint was initially found non-compliant, it should be reported as such. FCAC may request additional information on the issue. Should a non-compliance complaint be identified as a systemic compliance issue, we expect PCNOs to report this information using the appropriate form within 60 days of identifying the issue, as per FCAC’s Compliance Framework.
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