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 Spanish complaints the process to be followed is modified in a number of respects as set out in Market Bulletin Y4961. 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
A complaint shall mean a statement of dissatisfaction submitted by a user of a financial service due to delays, neglect or any other failing in the functioning of the financial institution against which the complaint is filed. It also includes complaints with a view to obtaining compensation for the harm to the user’s interest or right, for specific facts about acts or omissions, which are detrimental for the user and that, arise from breaches of the regulations on transparency and customer protection, or of good practices in financial business.
A complaint must be submitted to the insurer in writing in order for it to be considered a complaint.
The insurer must issue its final response, in writing, within 10 days after it has made a decision on the complaint which at the latest should be made within two months of receiving the complaint.
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.