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.
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
An expression of dissatisfaction by a person to an insurer or, to the knowledge of the insurer, to the insurer’s service provider relating to a policy or service provided or offered by that insurer which indicates, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a policyholder query, that :
- the insurer or its service provider has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the insurer or to which it subscribes;
- the insurer or its service provider’s maladministration or wilful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or
- the insurer or its service provider has treated the person unfairly
The insurer must issue its final response, in writing, within 8 weeks of receipt of the complaints.
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 appropriate EDR service, for review. They should be provided with the full EDR contact details, which can be found in the Complaints Handling Summary.