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 Singapore 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 Singapore 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
Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service, which:
Lloyd’s operates a two stage process in Singapore.
The managing agent or their representative, ie Third Party Claims Administrator/Coverholder has 14 calendar 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 Asia and then to escalate their complaint to the relevant External Dispute Resolution Service (EDR).
If the complainant remains dissatisfied they can request a stage two review. This review will be conducted by Lloyd’s Complaints team on behalf of Lloyd's Asia which has 56 calendar days from receipt to resolve the complaint.
External Dispute Resolution
The policyholder may refer their complaint to one of the following EDRs:
FIDReC handles claims between consumers who are individuals or sole-proprietors and insurers with a value of up to SGD 100,000.
Where claims are small, expensive and prolonged litigation can exhaust time and resources, mediation may be the solution to take control of the outcome of these disputes in a timely and cost-efficient manner.
Any dispute, difference or question which may arise at any time hereafter in relation to true construction of the policy or the insurer respective rights or liabilities under this policy, will be referred to arbitration in Singapore and Singapore laws will apply. The arbitration will be heard by a single arbitrator to be agreed by the insurer and the policyholder within 14 business days of the commencement of the arbitration.