The European Association of C-operative Banks (EACB) welcomes the opportunity to respond to the "Joint Committee Consultation Paper on draft guidelines for complaints-handling for the securities (ESMA) and banking (EBA) sectors" and invites the respective supervisory authorities to consider the below comments.
To start with, the EACB would like to point out that co-operative banks take their complaints-handling process very seriously; both as a way to continuously improve their level of services, as well as a manner to best serve their clients, who are often also members and thus take a direct stake in the bank.
Indeed, as a showcase of their commitment on the subject, it should be noted that co-operative banks in many cases developed alternative dispute resolution mechanisms (and processes for complaints-handling that precede the ADR-stage) before it became a topic of regulatory debate. This being the case, the members of the EACB look upon the proposed guidelines from a positive perspective. Having said that, the EACB does want to underline that it is not convinced that there is a strong documented need for supervisory convergence on this point. In addition, there are few elements of the proposed guidelines on which the EACB wishes to put forward its considerations.
For the full document, please download the PDF or consult this document on the related web page.