Regulatory Alerts2013-09-20 | Circular 3/2013 (VA) - Minimum requirements for complaints-handling by insurance undertakingsCircular 3/2013 (VA) – Minimum Requirements for Complaints-Handling by Insurance Undertakings
Issued by the Federal Financial Supervisory Authority (BaFin), this circular implements European EIOPA guidelines by establishing binding minimum standards for how German insurance undertakings handle customer complaints. It mandates the creation of a dedicated, conflict-free complaints management function responsible for maintaining internal policies, registering and analyzing complaint data to identify systemic risks, and reporting findings directly to the regulator. Undertakings must ensure transparent, timely, and legally compliant complaint processing by providing clear procedural information to policyholders, investigating evidence promptly, and offering written final decisions with alternative dispute resolution options.
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