Firm Bulletin: Early Resolution initiative pilot to be implemented on an ongoing basis
We are pleased to announce that OBSI is implementing its Early Resolution initiative on an ongoing basis.
This initiative is designed to encourage firms to resolve complaints directly with consumers as early as possible in the OBSI process. As noted when the pilot was launched on November 1, 2025, early settlement of complaints can enhance consumer satisfaction and reduce resource demands, benefiting all users of our service.
Results of the pilot initiative
Our evaluation of the pilot initiative indicates that it has broadly achieved its intended objectives.
Key findings include:
- cases resolved before investigation increased 40% compared to the prior two-year period, from 7.4% of all cases closed to 10.4%
- significantly higher consumer satisfaction levels in cases that were resolved early
- positive feedback from participating firms, with no significant concerns raised
- no material negative impacts on OBSI workflows
While early settlement volumes remain a relatively small proportion of overall cases, we observed that the participation among firms varied significantly, demonstrating that there is potential for a greater number of firms to take the opportunity to engage early with their clients to resolve cases at an early stage of the OBSI process.
The continuation of this initiative reflects OBSI’s commitment to improving outcomes for consumers and enhancing efficiency in resolving complaints.
We encourage firms to continue identifying opportunities for early settlement and engaging with consumers early during the intake stage of our process.
How the Early Resolution initiative works
Under the continuing initiative, any case that is settled directly between a firm and a consumer before an OBSI investigator is assigned will continue to be excluded from OBSI’s fee calculations.
For fee setting and billing purposes, cases resolved through Early Resolution:
- will not be included in sectoral case volumes for the sectoral allocation
- will not be included in firm-level volumes used for fee calculations
For background on OBSI’s fee allocation methodology, please see our discussion here.
There will be no change to how these cases are reported. Early resolved cases will continue to be counted in OBSI’s open and closed case volumes and reported as “settlement prior to investigation.” Banking cases that are early resolved will be included in the count of cases “resolved to the satisfaction of the consumer”. Investment and provincial credit union cases that are early resolved will be included in the count of cases closed “with compensation”.
We believe that excluding cases resolved early in our process from our fee allocations is fair to the resolving firm and is consistent with our goal of ensuring that our firm fees are fair to all participating firms because cases resolved early before an investigator is assigned require significantly fewer OBSI resources than those resolved during or after investigation.
How to take advantage of this initiative
To make the most of Early Resolution, firms should follow these steps:
1. Identify eligible cases early
Firms should consider the characteristics of a case that will make it a good candidate for early settlement. For example, the type of issues raised in the case, the complexity of the case and the value at issue. When a case is opened with OBSI, firms will be notified and asked to submit relevant file materials. During this intake phase – before an investigator is assigned – firms should assess as early as possible whether the complaint has the potential for early settlement.
2. Engage in direct settlement discussions
When opening a case, OBSI provides consumers with information about what to expect from our process. This information will ensure consumers are aware that their firm may reach out to them to resolve their case early. Consumers will be informed that their participation in settlement discussions is entirely voluntary, but that early settlement may benefit them by providing a faster and easier conclusion to their complaint than a full investigation.
3. Pay attention to timelines
Firms should reach out as early as possible to explore settlement options with their customers, while reviewing and preparing their investigation documents for disclosure to OBSI if settlement discussions are unsuccessful. Firms generally have 21 days to provide us with their internal investigation materials. No additional time is granted for early offers to settle cases.
4. Notify OBSI of settlement
If a settlement is reached, firms must promptly notify OBSI. OBSI will record the case as closed, with the outcome noted as “settlement prior to investigation.”
FAQs
What kind of cases are eligible for Early Resolution?
All cases are eligible for Early Resolution, and it is entirely at the firm’s discretion whether to engage in early settlement in any given case. Each firm should establish criteria for early settlement that reflect its unique business model and complaint experience.
How long does a firm have to engage with their customer to see if settlement is possible?
We do not add any time to our existing case opening and assignment timelines. When firms are informed of a new case opening, we ask that the firm’s documentation be provided within 21 days. Once we receive the firm file, the case is made ready for assignment to an investigator, and an investigator is usually assigned within two weeks. Currently due to exceptional case volumes, some cases may take longer for assignment. We expect that firms will explore the potential for early settlement during this case intake and assignment period.
Will reporting be enhanced and how can firms track early settled cases?
Firms can see cases and outcomes in the firm portal in real time and in quarterly and annual reporting.
If a case is opened in one year and early resolved in another year, how will this impact fees?
Cases settled through Early Resolution will be excluded from sectoral and individual firm fee calculations for the subsequent year as follows:
- Cases that were opened in 2025 and settled early will be excluded for the purpose of calculating 2027 fees, which are determined in 2026 for the following year.
- Case that are opened in 2026 and early settled in 2026 will impact 2028 fees, which are determined in 2027 for the following year.
How will Early Resolution benefit me as a bank that pays the minimum fee?
For banks that pay the minimum fee, participating in Early Resolution can offer meaningful benefits. By settling cases early – before an OBSI investigator is assigned – you reduce the number of cases counted toward your future fee calculations. Over time, this could help maintain your minimum fee status or prevent increases if your case volumes rise. Additionally, early settlement improves consumer satisfaction and reduces the time and effort your staff must spend on complaint handling and OBSI investigations.
Can firms opt out of Early Resolution of cases?
There is no obligation on any firm to engage in early settlement of cases if they do not wish to.
Early settlement of cases has always been possible in OBSI’s process. Early settlement does not change our process, except in respect of the accounting for Early Resolution cases in our fee-setting process, which we hope will incentivize higher levels of early settlement and achieve the positive outcomes outlined above.
Do consumers have a choice to participate in an Early Resolution process?
Yes. Consumers are not required to participate in an early settlement process. Early Resolution is a voluntary option that may be available when both the consumer and the firm agree that it could help resolve the matter more quickly. In addition, firms are under no obligation to engage in Early Resolution if they choose not to do so. If Early Resolution is not pursued, the case would proceed through OBSI’s regular investigation process.