Insights

All firms need to ensure that:

• they have a customer communication strategy and plan which will kick in, in the event of serious disruption to its business, products or services. This should be one of the elements covered in the business continuity plan of each licensed firm;
• they will be constantly monitoring, evaluating and mitigating the risks to which they are exposed;
• they engage proactively with the Authority if they fear a significant risk of disruption which could potentially have an adverse effect on consumers. All relevant information should be communicated to the Authority at the earliest opportunity;
• they communicate planned or unplanned service changes, interruptions or withdrawals with the Authority as early as possible and in a transparent manner;
• they have adequate resources available to properly handle complaints even if these are numerous and/or voluminous, and
• provide customers with clear and timely information regarding their rights including details on how to put forward a complaint and the availability of statutory compensation measures. If necessary, ad-hoc training to the respective customer-facing staff should be provided by the firm.

Where there is a significant disruption, the MFSA may require the customer records of those affected. Hence, maintaining accurate and up-to-date customer records is of paramount importance.

The MFSA invited all licence holders to provide information on a voluntary basis to the Authority in relation to any increase in customer complaints which are related to COVID-19. This information should include details of the nature of the issue or the customer detriment involved, whether such complaint has been resolved and the intended actions which the firm intends to take to resolve such complaints.