management conduct an analysis and made a recommendation to Council.
5.2	What do the user complaints indicate about this company:	IA inquired with management regarding user complaints regarding SLWC services. Management indicated that since the program has been recently launched in Windsor, management is not aware of any complaints regarding the quality of services received by the homeowners. However several complaints have been received from homeowners regarding receiving marketing letters from SLWC for incorrect contact details documented on such letters. IA also conducted its own research for user complaints regarding SLWC services across other municipalities within Canada and US and noted the majority of the complaints were related to incorrect contact details in marketing letters, privacy concerns, and concerns regarding City/municipality promoting/endorsing companies. IA did not find complaints regarding SLWC service concerns.

Conclusion: Complaints noted in our analysis appeared to be related to incorrect contact details in marketing letters, privacy concerns, concerns regarding City promoting other companies.

Allegation #6:

The City of Windsor is getting a commission or kickback from SLWC based on citizen enrollment into the program. The financial arrangement is not disclosed. This is a hidden tax.

Procedures and results:

	Procedure	Results
6.1	Is the City of Windsor getting a commission or kick-back from the company? Is this based on citizen enrollment?	IA inquired with management regarding financial arrangement if any with SLWC in exchange of endorsement. Management indicated that a percentage of revenue from warranty products collected from homeowners by SLWC will be remitted to CoW annually. Management indicated that the program officially started in August 2019 and the amount received by CoW as of Nov 2019 is CAD 13.81. IA reviewed the agreement between CoW and SLWC and noted: SLWC will pay to CoW 5% revenue of the warranty products collected from homeowners. CoW will have the right to conduct an independent audit thereof.
6.2	Is this financial arrangement disclosed to homeowners? Where?	IA inquired with management whether such an arrangement was communicated to the citizens.Management indicated that the financial arrangement between CoW and SLWC was discussed in the report submitted to the Council. This report is public. IA inspected the Council Report S 2/2018 and noted: “As part of the endorsement of the SLWC Service Line Warranty, the City of Windsor would be required to enter into an agreement with SLWC to use the City of Windsor name, logo and property information for marketing purposes and in return, SLWC would remit to the City of Windsor 5 (five) percent of the revenue from the warranty products collected.
6.3	Is this a hidden tax?	IA inquired with management whether such an arrangement is a hidden tax by the City.Management indicated that its does not classify this as an hidden/additional tax to the homeowners and has explicitly mentioned that participation in this program is optional and voluntary for homeowners in Windsor. This is a revenue source for the City and the opposite of a hidden tax. As per the Council Report, it is the intent of the administration to reinvest any such funds into flood protection information education and to leverage the program for the municipality’s own flood protection education program. City Council retains control as to the assignment of any revenues raised through the program.