Lloyd’s has set out the process to be followed for international (non-UK) complaints in Market Bulletin Y4961 – International Complaints Handling: Expansion of New Procedures. For New Zealand complaints the process to be followed is modified in a number of respects as set out in Market Bulletin Y5154, the most notable differences are that New Zealand complaints are handled in accordance with a two stage process. These changes reflect local regulatory and legal requirements and market practice.
Lloyd’s arrangements for international complaints are intended to allow for the oversight of complaints handling, consistent with the regulatory expectations of the UK Financial Conduct Authority (FCA), whilst allowing flexibility for managing agents in the way they handle complaints in accordance with local rules.
Definition of a complaint
Expression of dissatisfaction about a Participant, where a response or resolution is explicitly or implicitly expected from the Participant.
Lloyd’s operates a two stage process in New Zealand.
The managing agent or their representative, ie Third Party Claims Administrator/Coverholder has 10 business days to attempt to resolve the complaint. The stage one response must outline the right of the complainant to request a stage two by Lloyd's New Zealand and then to escalate their complaint to the Insurance and Financial Services Ombudsman (IFSO).
If the complainant remains dissatisfied they can request a stage two review. This review will be conducted by Lloyd’s Australia on behalf of Lloyd's New Zealand which has 10 business days to resolve the complaint. If the matter cannot be resolved at stage two and/or it has been more than two months since the complaint was made, the complainant will be advised of the reasons for this via a 'deadllock' letter and advised of their right to elevate the matter to IFSO.
External Dispute Resolution
When responding to a complaint, the complainant must be informed that if they remain dissatisfied they may be able to refer their complaint to the Insurance and Financial Services Ombudsman in New Zealand, for review.