Response to consultation on Guidelines on complaints handling by credit servicers under CSD
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?
As regards the question whether, there is a reason why the requirements on complaints handling for credit servicers under Directive (EU) 2021/2167 that are being proposed in this CP 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, the BKS answers in the negative.
Therefore, BKS considers the option 1b optimal, proposing to apply the JC Guidelines (the ‘draft Guidelines’) to credit servicers. As the existing guidelines are already known, accepted, and used for the best practice approach in the secondary market, it would be only consistent from the BKS's perspective to transfer the requirements relating to complaints management from the JC Guidelines to the credit services under Directive (EU) 2021/2167.