The following examples discuss some of our compliance experiences with PSPs to date.
Implementing resolutions, Recommendations and Decisions
PSPs are required to implement CCTS resolutions, Recommendations and Decisions. When PSPs do not implement these, the CCTS follows up to ensure implementation.
Sometimes our efforts are successful. In other cases, the PSPs refuse to cooperate or do not respond to our communications. When they do not respond, we sometimes learn that the service provider has gone out of business. If a provider is still in business, we have the authority to terminate its participation in the CCTS for refusal to implement a Recommendation or Decision.Usually, this is enough to get the PSP to comply. However, if the PSP has gone out of business, there is not much that we can do.
Promoting awareness of the CCTS
PSPs are required to promote awareness of the CCTS to Canadians, to ensure that Canadians know about their right to escalate their complaint with the CCTS. Promoting awareness includes a requirement for PSPs to provide, on their website, a notice about the CCTS along with a link to the CCTS website.
We have identified 21 PSPs with no information about the CCTS on their websites.
After being contacted by the CCTS and as of August 2019, 11 PSPs have remedied the situation, 8 are in the process, and 2 have not responded.
Cooperating in good faith
PSPs are required to cooperate in good faith with the CCTS throughout the complaint investigation process.
After customers of one PSP submitted complaints to the CCTS, the PSP contacted the customers and asked them to withdraw the complaints. This is not cooperating in good faith. It is in the interests of PSPs to resolve complaints, not to dissuade customers from submitting them. We worked with the PSP to explain this and ensure it understood the good faith requirement.
Following all of the participation requirements
One PSP breached all of the compliance requirements by refusing to:
- pay its CCTS fees
- promote awareness of the CCTS
- adhere to the Procedural Code:
- did not submit required revenue information to the CCTS
- did not cooperate in good faith with investigations and threatened to take customers to court
We are working with the PSP to bring it into compliance with the CCTS requirements.
The CCTS will continue to monitor and report on compliance and to work with PSPs to help them come into compliance with the CCTS requirements.