Client Complaint Process
CLIENT COMPLAINT PROCESS
The Commission de Surveillance du Secteur Financier (“CSSF”) has adopted Regulation N° 16-07, followed by specifications by the CSSF Circular 17/671 related to the out-of-court resolution of complaints (this regulation is available on the CSSF website: https://www.cssf.lu/en/customer-complaints
As part of the obligations laid out in Regulation N° 16-07, COMO DL S.A., as a payment institution authorized by the CSSF, seeks to provide a high-quality service to its clients. In particular, it informs them that all potential concerns and complaints will be treated in a careful, effective, and prompt manner in compliance with the procedure below.
In addition, COMO DL aims to take all the necessary measures to ensure that the processing of personal data for clients' complaints analysis and solving complies with the applicable rules on protecting personal data.
1. A complaint can be submitted by certified mail against return receipt, by electronic mail, or via telephone to the following addresses:
COMO DL S.A.
7, Am Scheerleck
Phone: (+352) 26 20 2877
Complaints can be made in the Luxembourgish, German, English, or French.
2. The complainant (“Complainant”) shall include in his complaint his first and last name (and/or that of his legal representative), address, and other contact details (telephone number, mobile number, electronic mail).
3. The Complainant shall include a detailed description of the circumstances underlying his complaint. All complaints submitted by Complainants must contain all relevant information as well as copies of all relevant documents in the Complainant’s possession.
4. A written acknowledgment of receipt will be provided to the complainant within ten (10) business days of receipt of the complaint unless the answer itself is provided to the complainant within this period.
5. Once the complaint has been received by COMO DL, COMO DL shall deal with it within the terms indicated within COMO DL Complaints Procedure. COMO DL designates and coordinates the responsible persons in charge of the treatment of the complaint, who have management-level ranking (“Person Responsible for Complaints Handling”). The Person Responsible for Complaints Handling will gather all relevant evidence and ensure that a thorough and impartial investigation is carried out within the mandatory timeframe after receipt of a complaint.
6. Following an assessment, COMO DL provides the Complainant with its position by registered letter, courier, or certified email within a maximum of one month from the date of receipt of the complaint. If, for any reason, COMO DL considers that it shall exceed this period, it commits to advising the Complainant about the reason for the delay and indicate the date by which its examination will be finished.
7. Where the complaint handling does not result in a satisfactory answer within a reasonable timeframe, the Complainant may notify the CSSF within one year of filing the initial complaint and use the out-of-court procedure.
Any complaint submitted to the CSSF, should be drafted in the English, Luxembourgish, German, or French language and can be submitted to the CSSF by mail or email:
Commission de Surveillance du Secteur Financier Départment Juridique CC
283, Route d’Arlon
8. Within three weeks of receipt of the request and in case of an unfounded complaint, the CSSF will send in writing to the Complainant and COMO DL a detailed explanation of why they do or do not agree to deal with the dispute.
9. In the event the CSSF considers the request of the Complainant found and complete, it will also send a written confirmation to COMO DL asking for its position within a reasonable period, which should not exceed one month.
10. The CSSF then provides a motivated decision within 90 days addressed to the Complainant and COMO DL, inviting them, in case the request is well-founded, to resolve their differences, in consequence of which the parties shall attempt to reach an amicable agreement and inform the CSSF.
CSSF CUSTOMER COMPLAINTS:
CSSF CIRCULAR 16-07 RELATING TO OUT-OF-COURT COMPLAINT RESOLUTION:
https://www.cssf.lu/wp-content/uploads/RCSSF_No16-07eng.pdf (English version)
https://www.cssf.lu/wp-content/uploads/RCSSF_No16-07.pdf (French version)