Response to consultation on Guidelines on complaints handling by credit servicers under CSD
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Consultation question: Is there a reason why the requirements on complaints handling for credit servicers under Directive (EU) 2021/2167 should differ from the ones in the existing JC Guidelines on complaints handling that are applicable to other financial institutions across the banking, Investment and insurance sectors?
No, Federation Bancaire Française considers that there is no reason why the requirements on complaints handling for credit service providers under in Directive (EU) 2021/2167 should differ from those existing in the Joint Committee Guidelines that are applicable to other financial institutions across the banking, Investment and insurance sectors.
As indicated in recital 52 of the Directive, one of the objectives of this text is to ensure a high level of protection for consumers. We therefore consider that our members' borrowing clients or any other borrowers whose loans could be transferred to credit managers should be able to benefit from the protective framework for processing complaints set out by the Joint Committee Guidelines.