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The extension of the scope will provide consumers with the same level of protection, irrespective of which regulated product or service they are purchasing and which regulated institution they are purchasing it from.
The existing JC Guidelines on complaints-handling set out requirements in relation to firms' complaints management policy and function, their registration of complaints, their reporting to national competent authorities, and their assessment of, and responses to, the complaints. The Guidelines are addressed to authorities competent in their jurisdictions for supervising complaints-handling by firms, which in the banking sector include credit institutions, payment institutions and electronic money institutions, as defined in the Capital Requirements Directive (CRD), the PSD2 and the Electronic Money Directive (EMD) respectively.
The consultation paper proposes that the JC Guidelines should also apply to the new payment initiation service providers (PISPs) and account information service providers (AISPs) under the PSD2 and credit intermediaries and non-credit institution creditors under the Mortgage Credit Directive (MCD). In the specific case of AISPs that provide only account information, but no other payment services, the EBA proposes to apply the Guidelines only to security-related, but not to other types of, complaints, in line with related requirements set out in the PSD2 itself.
Responses to this consultation can be sent to the EBA by 27 May 2018.