Our Market Code of Conduct

IC Savings aspires to make fair treatment a core principle of our business practices. Fair treatment is ingrained in our corporate culture and is demonstrated in the dedication of our Board of Directors, our executive management and our employees.

Decisions at the strategic and operating levels of IC Savings are made in the best interests of our members; this provides for a trustworthy credit union. Our employees are expected to treat everyone who interacts with IC Savings, as well as their fellow colleagues, in a respectful and honest manner. We respect that each individual must be treated with fairness.

The integrity of our business practices and the commitment to treat all persons with fairness are established by our Board of Directors. Management is responsible for setting the operating policies for fair treatment and the procedures to set the policy into motion. Senior management is required to certify to the Board of Directors that the fair treatment policies and procedures and the principles of this Code have been followed.

Like any other business, we are allowed to interact with governments and comment on policy, legislation, or regulations. Our business practice requires that we ensure any lobbyist, whether a staff member or a consultant, who acts on behalf of IC Savings must disclose any conflicts of interest, register with the appropriate registries and follow all laws and regulations that apply.

Fair Treatment

IC Savings treats all individuals who use our products and services fairly, and we demonstrate fair sales practices in all our business relationships.

Fairness means we will not discriminate against any of our members or anyone considering using our services, and we abide diligently by the Ontario Human Rights Code. We must make exceptions when justified by law.

Fairness means that IC Savings does not take advantage of anyone by misrepresenting facts, concealing information or engaging in manipulation, unfair dealings or unethical activities. We take care to be clear and comprehensive with those who are unable to protect their own interests or who are only just familiarizing themselves with how we operate.

IC Savings does not use misleading, threatening, intimidating, or abusive language. Nor do we apply excessive or unreasonable pressure to repay against any borrower. We take all reasonable steps to identify, avoid, or manage conflicts of interest. When there is a potential or perceived conflict of interest, we will bring this to our members’ attention, and they will be given the opportunity to cancel, postpone or continue the transaction.

Protection of Personal Information

Fair treatment also applies to how IC Savings manages the personal information of our members. We commit to handling members’ financial affairs with discretion and all personal information collected and used for the purpose of providing financial services and products is handled confidentially.

At IC Savings, we do not leave member information unattended and we do not discuss or disclose any member information to anyone outside of IC Savings unless we are required to do so by law, or are authorized to do so by the member involved. We will not access member information except in the normal course of our duties, for legitimate purposes, and with proper authorization or consent. In addition, employees are not allowed to access member information processed by another employee unless there is a legitimate need to know the information and the appropriate access clearance has been provided.

When dealing with member information, IC Savings must comply with all laws as well as the privacy requirements set out in government legislation.

Financial Well-Being and Literacy

IC Savings wishes to support each member’s financial well-being and financial literacy and will do this through policies and procedures on providing material and education on how to improve one’s financial well-being through appropriate financial planning.

Fair Sales

Everyone who uses IC Savings has access to accurate information to help them choose the most affordable and appropriate product or service to meet their needs. Our advertising, marketing materials, and communications are straightforward, accurate, and easy to understand. We provide information that helps individuals make informed and suitable choices when considering our products and services. We exercise reasonable and prudent judgment in all our business dealings.

IC Savings is committed to the professional development of our employees, who are educated to provide financial information that individuals can trust. Our employees’ knowledge is gained through, and improved upon by, appropriate development programs or work experience. Employees are required to keep abreast of changes in products and services, industry standards and regulations relevant to their role.

Integrity in Sales

IC Savings does not permit practices that could be seen to be “tied selling.” IC Savings does not engage in undue pressure or coercion to convince people to select any particular product or service. We do not impose any form of pressure to induce members to buy a particular product or service they do not want as a condition of obtaining those they do want.

IC Savings does not practise negative-option billing, which means automatically billing for a product or service a member has not specifically asked to purchase. We always obtain members’ consent to provide them with new and optional products and services, and we seek their consent for changes made to agreements that affect their rights and obligations.

IC Savings does not permit “mis-selling,” a sales practice in which a product or service is deliberately misrepresented, or members are misled about its suitability in their situation. IC Savings’ employees provide full information to members to enable them to make effective decisions on financial products and services, and the material on our products and services that we make available in printed form and on the internet is accurate and complete.

Preferential Relationship Pricing

In certain instances, IC Savings may offer a better price or rate on all or part of a product or service. This practice is not “tied selling,” and it is permissible under existing legislation. For example, we may offer a preferential price if a member, account holder or consumer has bought or is considering buying several other IC Savings products or services. We are completely transparent about these opportunities.

Risk Management

To manage risks and costs, and to comply with laws that apply to our operations, we may make reasonable requests of our members as a condition of acquiring a product or service.

Digital Products and Services

Many legislative and regulatory requirements apply to digital financial products and services. IC Savings follows regulatory guidance and best practices when providing internet-based products and services in a digital environment.

IC Savings aims to provide members with access to fundamental banking services. We open deposit accounts for anyone whose identity can be verified in accordance with applicable legislation, and if we refuse to do so, it is only for sound risk management reasons.

We may refuse to open a deposit account if an applicant has previous write-offs or losses or a poor credit bureau score. We assess whether we can minimize the risk by instead imposing restrictions on the account. Our decision is influenced by several factors. We consider the amount of past losses or write-offs, the length of time since the loss, and any extenuating circumstances.

When we refuse to open an account, we inform the applicant of our decision. We never refuse to open a deposit account for unjust discriminatory reasons, or if the applicant is unemployed, or has been bankrupt. We do not refuse to open an account when the applicant is not making an immediate deposit. If we close a deposit account, we do so only in strict accordance with the agreement that governs our relationship with that member or account holder.

Restrictions on Deposit Accounts

IC Savings may impose reasonable restrictions on certain deposit accounts. Restrictions include placing temporary holds on cheques to allow time for them to clear or limiting the amount of cash provided on a deposited cheque. If warranted, we may impose limits on overdrafts, on debit card privileges, or on ATM and online access. We will inform affected members of any restrictions to deposited funds, withdrawal limits, or increases to cheque-hold periods. We are not required to grant access to funds if we suspect any deposit is tied to illegal activity.

Low-Fee and No-Fee Deposit Accounts

IC Savings has a variety of accounts, including low fee and no-fee options that allow access to fundamental banking services for people who might not otherwise afford to open and operate an account.

IC Savings provides suitable product and service information that is easy to understand and that considers the financial needs of our members. Current information is made available to individuals before a product or service is acquired, and afterwards if there are changes to product and service information. Our documents are clear and contain all the financial implications of a transaction. All products and services are operated within the requirements of any applicable legislation.

Informed Decisions

When members open an account, we aid them in making an informed decision by letting them know the key features of the account and any associated risks, exclusions or limitations. We strive to explain the financial implications of a transaction and to ensure that members understand all the related costs and know about the terms and conditions and their rights and obligations. We draw special attention to the key areas of an agreement, including fees and charges, restrictions, overdraft protection, deposit insurance coverage, and other relevant terms and conditions.

When members acquire a product or service, we provide them with relevant information on the nature of the product or service. We provide members with access to regular statements, and we advise them of any changes to the operating nature of the product or service. If a statement has already been provided, we may charge a reasonable fee to provide a duplicate copy. IC Savings gives advance notice of changes to agreements, service fees or account structures, and interest rates in accordance with applicable legislation. In cases where notice is not legally required, IC Savings may post a notice on its website and/or in branch, or send a notice by Canada Post mail or electronic mail.

IC Savings provides members with information on the options available with respect to loans and mortgages. The information outlines how the credit products operate, as well as the terms and conditions, which also include the borrowers’ responsibilities.

Branch and ATM Closures

We understand the inconvenience that the closing of a branch or ATM may have on our members, and therefore we make every effort to alert our members to the closing of a branch or ATM as soon as possible, once a decision to do so has been made. IC Savings will notify members of any closures, either permanent or temporary, in accordance with applicable legislation. In cases where no legislation applies, notice may be communicated by IC Savings on its website, in branch, by Canada Post mail or electronic mail.

Use of “Banking” Terminology

Because we often use the terms “bank,” “banking” or “banker” in our marketing materials, we make sure account applicants new to IC Savings understand that the account is being opened in a provincial credit union and not a federal bank.

Identifying Deposit Insurance System

When identifying our deposit insurance system, we follow the restrictions, guidance, requirements, and display and advertising rules established by the Ontario Deposit Insurance Corporation and provided through the Financial Services Regulatory Authority of Ontario (FSRA). Information on the role of the FSRA can be found at www.fsrao.ca.

IC Savings understands that members may encounter issues when using our products and services, or in connection with the conduct of our staff and/or actions of the credit union itself. We respect complaints expressed by members and examine each one to gain a proper understanding of the issue. Where appropriate, we determine a fair settlement of the issue through a process that is accessible to everyone, at no cost. In order to identify trends and the types of complaints, IC Savings maintains records of complaints received, and the actions taken to address them. We review trends identified in the records on a regular basis to facilitate process improvements and improve member satisfaction.

Issues and misunderstandings may occur, and IC Savings encourages people to report issues directly through the process outlined below. It is important that we deal with any member concern in an expedient and respectful manner. Where concerns are reported in good faith, there will be no reprisal or unwarranted negative consequences.

For complaints, members are encouraged to contact the relevant staff member and/or their supervisor.

If members are not satisfied with how the relevant department handled their complaint, the complaint officer of IC Savings can be reached at complaints@icsavings.ca. The complaint officer works closely with members and the relevant department of IC Savings to investigate the complaints thoroughly, and is committed to arrive at an unbiased, fair and transparent solution for all members.

If members are not satisfied with the decision of the complaint officer, they can contact the Financial Services Regulatory Authority of Ontario (FSRA) for further review.

Financial Services Regulatory Authority of Ontario
Licensing & Market Conduct Division
Credit Union and Caisse Populaire Complaints
25 Sheppard Avenue West, Suite 100
Toronto, ON, M2N 6S6 or
Or by email at contactcentre@fsrao.ca