8.1 Complaint Management and Complaint Resolution

8.1.1 Introduction

Licensed Financial Institutions must be transparent with Consumers and operate in a fair, honest and competitive manner. Licensed Financial Institutions must have in place a fair, accessible and transparent process provided without charge for addressing Complaints with Consumers and that are resolved in a timely manner.

8.1.2 Description

1. 8.1.2.1 A Licensed Financial Institution must establish an independent Complaint management function in the organisation that directly reports to the Senior Management. The function must be empowered to effectively resolve Complaints and independent of other business operations.
    
2. 8.1.2.2 Licensed Financial Institutions must have an efficient and effective Complaint management system with supporting policies and procedures. The system must enable Consumers to make Complaints easily and free of cost.
    
3. 8.1.2.3 Licensed Financial Institutions must ensure Consumers are aware of their rights and responsibilities when seeking to resolve their problems or Complaints.
    
4. 8.1.2.4 Licensed Financial Institution is responsible for accepting and addressing all Complaints involving the activities of Authorized Agents as well as any product and/or service sold, marketed or advertised by the agent on behalf of the Licensed Financial Institution.
    
5. 8.1.2.5 Licensed Financial Institutions must ensure compliance with all time frames prescribed by the Central Bank including turnaround time for acknowledgments and provided written responses to Complaints that must provide the Consumer an explanation in writing of any delay or any inability of having a resolution to the Complaint or Error.
    
6. 8.1.2.6 Licensed Financial Institutions must ensure their Authorized Agents provide a credible and unbiased process for Complaint resolution in accordance with this Regulation and Standards and the Licensed Financial Institution’s policy and procedures.
    
7. 8.1.2.7 Licensed Financial Institutions must train their staff and Authorized Agents in identification and handling of Complaints.
    
8. 8.1.2.8 Consumers must be informed of the Licensed Financial Institution’s process for the management of Complaints as well as recourse to a Complaint resolution mechanism to ensure fairness, transparency and neutrality in resolving Complaints.
    
9. 8.1.2.9 The Central Bank will supervise the effectiveness and efficiency of the financial Complaint resolution mechanism.

8.2 Complaint and Inquiries Management Data

8.2.1 Introduction

Data collected on Complaints and inquires is a critical source for analysis that can improve a Licensed Financial Institution’s overall conduct as well as problems with its product offering. Prompt analysis of trends help to identify deficiencies in Licensed Financial Institutions’ sales practice, business conduct, and product design and system defects. Therefore, it is critical for a Licensed Financial Institution to establish standards for Complaint and inquiry Data to be gathered, collected, classified, stored, analysed and reported.

8.2.2 Description

1. 8.2.2.1 Licensed Financial Institutions must utilise the Data collected to conduct analysis and assess key risks and trends arising out of the Data. The results of the analysis must be used by the Licensed Financial Institution for conducting investigations into thematic trends, conducting root cause analysis of repeat issues and for designing new controls to address issues and improving quality and efficiency of various aspects of Consumer service. The Licensed Financial Institution must document any actions taken for review by the Central Bank.
    
2. 8.2.2.2 The Complaints Data must be provided on a quarterly basis to the Senior Management of the Licensed Financial Institution to enable managerial level monitoring of trends and supportive decision-making.
    
3. 8.2.2.3 Licensed Financial Institutions must ensure that the Data collected and reported to the Senior Management and to the regulator as required, is accurate, timely and complies with the Licensed Financial Institution’s data governance policies and procedures.