Supervisory Circular 2023 - Complaints Handling Survey Review (2024-02-23)

Summary

This is a CIMA supervisory circular sharing the results of a 2023 Complaints Handling Survey conducted by the Authority's Banking Supervision Division. The survey covered seven deposit-taking institutions ("Participating Institutions") and assessed their complaints handling policies, procedures, and overall framework effectiveness. It is an informational document reporting survey findings rather than introducing new binding rules.

The circular summarizes key themes identified across participating institutions and highlights both good practices and areas of concern observed during the survey. These themes include:

• Varying levels of Board engagement in complaints oversight
• Inconsistent Board approval of complaints policies
• Differing methods of communicating complaints procedures to customers
• Staff training practices
• Client engagement during complaint resolution
• Monitoring/tracking mechanisms
• Post-resolution quality control reviews

While the circular itself does not impose new rules, it reminds all regulated entities (not just the surveyed institutions) to consider the highlighted themes and incorporate recommended enhancements into their complaints management frameworks. It also points regulated entities to the previously issued Revised Rule and Statement of Guidance on Internal Controls and the Revised Rule on Corporate Governance for Regulated Entities, both effective 14 October 2023, noting that compliance with these Revised Rules and SOG (particularly the complaints-related sections) will be assessed in future CIMA inspections.

Key obligations

• Regulated entities should review the general themes and recommended enhancements highlighted in the circular and incorporate them, where necessary, into their complaints management framework.
• Regulated entities are encouraged to review the Revised Rule and Statement of Guidance on Internal Controls for Regulated Entities and the Revised Rule on Corporate Governance for Regulated Entities to ensure compliance with updated complaints-handling requirements (Section 5.7.5 of the Revised Corporate Governance Rule and Sections 12.11 & 12.12 of the Revised Internal Controls Rule and SOG).
• Institutions should ensure their complaints handling framework incorporates the additional requirements prescribed by the Revised Rules and SOG, as compliance will be assessed in future CIMA inspections.

Applies to

deposit-taking institutions, banks, regulated entities

Deadlines

• 14 October 2023: Effective date of the Revised Rule and Statement of Guidance on Internal Controls for Regulated Entities and the Revised Rule on Corporate Governance for Regulated Entities, which regulated entities are expected to comply with regarding complaints handling.