International Complaints Handling: Expansion of New Procedures

Transcription

1 Title Purpse Type Frm Internatinal Cmplaints Handling: Expansin f New Prcedures T advise f wider implementatin f new internatinal cmplaints handling prcedures initially t France, Germany and Spain Event Karen Oliver Senir Manager, Cmplaints Team Date 18 January 2016 Deadline Related links Immediately Territries currently in-scpe 1 April 2016 France, Germany & Spain In Market Bulletin Y4896 Llyd s set ut new arrangements fr the handling f internatinal cmplaints, initially t be pilted in Ireland, Sweden and Nrway. Fllwing the successful cmpletin f the pilt, Llyd s is nw implementing the new arrangements in all territries utside f the UK. The rll-ut is being carried ut in phases, starting with EEA cuntries. In the first phase the new arrangements are being adpted fr France, Germany and Spain, cmmencing with effect frm 1 April This bulletin sets ut the prcedures t be fllwed by managing agents fr all territries ntified t managing agents as in-scpe. The arrangements are substantially unchanged frm the prcedures adpted fr the pilt territries as set ut in Market Bulletin Y4896. Hwever, whereas fr the pilt Llyd s requested managing agents t ntify new cmplaints n a weekly basis, fllwing feedback received, Llyd s is nw nly requiring that ntificatin is given within tw weeks f receipt. The backgrund t the changes being implemented by Llyd s is set ut in Market Bulletin Y4896. Outline and further infrmatin In summary, when handling cmplaints arising utside f the UK, managing agents must, fr all in-scpe territries: Page 1 f 6 Llyd s is authrised under the Financial Services and Markets Act 2000

2 MARKET BULLETIN Take full respnsibility fr handling the cmplaints in cmpliance with all lcal legal and regulatry requirements; Ntify t Llyd s all new cmplaints received; and Prmptly send t Llyd s a cpy f bth the cmplaint and the cmplaint respnse after the respnse has been sent t the cmplainant. Managing agents must ensure they have prcesses in place t cmply with the arrangements fr internatinal cmplaints. The new arrangements are intended t allw fr better versight by Llyd s f the handling f cmplaints utside f the UK cnsistent with the regulatry expectatins f the Financial Cnduct Authrity. They als allw flexibility t managing agents in the way they handle cmplaints, recgnising that different cuntries have different lcal rules and practices. T assist market participants, Llyd s Cmplaints Team has prduced: a summary f the new prcess (see Appendix 1) a practical guidance nte fr managing agents (see Appendix 2) a summary f the imprtant pints f the cmplaint prcess fr each cuntry in scpe frm 1 April 2016 (see Appendix 3) These dcuments can als be fund n Where practical, Llyd s will make available lcal language translatins f its guidance t assist with prviding infrmatin t cverhlders. Llyd s has separate arrangements fr UK cmplaints handling, which can als be fund n Prcess fr internatinal cmplaints handling Fr all in-scpe territries utside f the UK, managing agents must have in place arrangements t ensure that they can cmply with the fllwing: 1. Handling the Cmplaint It is the sle respnsibility f managing agents t handle cmplaints and ensure that they are cmpliant with all relevant lcal rules. Details f the cmplaints handling rules fr each territry where Llyd s has a licence are prvided n Crystal. Managing agents shuld als cnsider in each case whether they require further lcal advice regarding the detailed applicatin f the rules. Llyd s will nt be prviding a stage 2 review f internatinal cmplaints. This means that in respnding t cmplaints, managing agents d nt need t give cmplainants the right t refer their cmplaints t Llyd s. Hwever, Llyd s reserves the right t undertake in depth reviews f any cmplaints where it cnsiders it apprpriate t d s. Page 2 f 6

3 MARKET BULLETIN In handling internatinal cmplaints, managing agents shuld cnsider: Infrmatin requirements: Lcal rules may require that the managing agent prvides certain infrmatin t plicyhlders, including its cmplaints handling plicies/prcedures, fr example in the pre-cntractual infrmatin and/r the plicy dcumentatin. Definitin f cmplaint: Managing agents shuld have regard t the lcal definitin f cmplaint. Time limits fr respnses: Managing agents must ensure that they meet all lcal time limits fr cmplaints handling. Where there are n lcally prescribed time limits, r if the lcal rules allw fr a timescale which is in excess f eight weeks, Llyd s will expect managing agents t prvide the substantive respnse t the cmplaint within eight weeks. External Dispute Reslutin (EDR) facilities: Managing agents must give the cmplainant details f any lcal EDR facility such as an mbudsman r a regulatr where this is prvided fr in the relevant jurisdictin and where the cmplainant is eligible in accrdance with lcal rules. This may require infrming plicyhlders f these rights in the pre-cntractual infrmatin, plicy dcuments r at varius stages in the cmplaint prcess. 2. Ntificatin f new cmplaints t Llyd s Llyd s is asking managing agents t ntify Llyd s f all cmplaints where the custmer is eligible t have their cmplaint cnsidered by the lcal EDR scheme. Furthermre, there may be territries in which the relevant definitin f a cmplainant includes persns whse cases are nt eligible fr cnsideratin by the EDR scheme; thse cases will als need t be ntified t Llyd s. Cuntry specific details are prvided in the summary sheets f lcal rules at Appendix 3. Managing agents are required t ntify t Llyd s cmplaints received frm cmplainants utside the UK within tw weeks f receipt. Cmplaints must be ntified t Llyd s Cmplaints Team, using the internatinal cmplaints template spreadsheet available at This infrmatin shuld be ed t Llyd s at internatinalcmplaints@llyds.cm. Managing agents must use the template prvided by Llyd s and shuld nt create their wn templates. 3. Send cpies f cmplaints and respnses Managing agents must als send t the Cmplaints Team a cpy f bth the cmplaint and respnse in every case. These shuld be prvided t Llyd s as electrnic cpies and sent via t internatinalcmplaints@llyds.cm within tw business days after the respnse is sent t the cmplainant. Llyd s is nt asking managing agents fr translatins Page 3 f 6

4 MARKET BULLETIN f the cmplaint r respnse (althugh these shuld be prvided where available). Translatins, where required, will be arranged by Llyd s. The Cmplaints Team will accept the ntificatin and cmplaints dcumentatin frm managing agents, their cverhlders r third party administratrs (TPAs). Maintaining cmplaints handling standards The rle f the Cmplaints Team will be limited t mnitring cmplaints, including cmpliance with the time limits fr respnding t cmplaints under lcal regulatins. Hwever, where the respnses f managing agents, cverhlders r TPAs persistently fall belw the standards expected f them, then Llyd s will require the managing agent, cverhlder r TPA t send cpies f all prpsed cmplaints respnses in draft frm t Llyd s fr review befre the respnse is sent t the plicyhlder. Further, Llyd s reserves the right t review and take ver crdinating the respnse t individual cmplaints where, in the view f Llyd s, this is apprpriate in all the circumstances, including in rder t ensure cmpliance with the lcal regulatry requirements that apply t Llyd s underwriters. Delegated authrities and TPAs Cverhlders and TPAs will be an imprtant surce f expertise fr managing agents t ensure that lcal cmplaints rules are being cmplied with. Cverhlders/TPAs will need t have prcesses in place t ensure relevant infrmatin is reprted prmptly t managing agents r t Llyd s, where the managing agent has delegated that respnsibility. Managing agents shuld therefre engage with their cverhlders t infrm them f the prcedures and t ensure that the cverhlder/tpa can supprt cmpliance with the arrangements. While managing agents may authrise their cverhlders and TPAs t handle cmplaints, it remains the respnsibility f managing agents t ensure that Llyd s cmplaints requirements, and requirements under lcal regulatins, are cmplied with. It is als the respnsibility f managing agents t ensure that any lcally appinted cverhlder r TPA has the necessary cmplaints handling expertise and is prvided with apprpriate instructins t ensure their cmpliance with Llyd s requirements and lcal regulatins. On binding authrities where there is mre than ne syndicate participating, Llyd s expects the lead syndicate t crdinate the discussins with the cverhlder. Llyd s charges In line with thse charges levied fr UK cmplaints, Llyd s will nt charge any fee in respect f cmplaints first ntified by managing agents t the Cmplaints Team thrugh the frtnightly reprting prcess. Cmplaints first ntified t Llyd s, where Llyd s will be prviding the acknwledgement, will incur Llyd s usual initial Administratin Fee (currently Page 4 f 6

5 MARKET BULLETIN 208). Als an Additinal Administratin Fee may be incurred where the internatinal cmplaints prcess is nt fllwed crrectly. Details f where these charges may be incurred are cntained in the summary f the new prcess (Appendix 2) In-Scpe territries The fllwing territries are already in-scpe r will be in scpe with effect frm the date shwn. - Already in-scpe: Ireland, Nrway, Sweden, Italy - In-scpe frm 1 April 2016: France, Germany, Spain It is als intended that Switzerland will be brught in-scpe with effect frm 1 April Arrangements are currently being finalised fr the handling f Swiss cmplaints and, nce cnfirmed, further details will be ntified t the market. Fr territries that are in scpe, managing agents must cmply with the requirements set ut in this bulletin (which replaces previusly issued bulletins) fr all new cmplaints received frm the date the territry is in scpe The implementatin f the arrangements set ut in this bulletin t further territries will be ntified t the market in due curse. The Cmplaints Team will als cntinue t engage with managing agents t prvide prvisinal details and t cnsult n Llyd s prpsals fr rlling ut the new arrangements t additinal territries. Channel Islands Managing agents shuld nte that different arrangements apply t the Channel Islands. Fr cmplaints arising in the Channel Islands, Llyd s managing agents shuld fllw the prcess that applies t UK cmplaints. Accrdingly, fr all Channel Islands cmplaints, managing agents must ensure that they cmply with the tw stage prcess set ut in the Cde fr Underwriting Agents: UK Persnal Lines Claims & Cmplaints Handling. Cmplainants wh have a right t refer their cmplaint t EDR shuld, hwever, be referred t the lcally administered mbudsman service fr the Channel Islands, the Channel Islands Financial Ombudsman Further details, including details f hw t refer cmplaints t the Channel Islands Financial Ombudsman can be fund in the Channel Island tab in the Internatinal Cmplaints sectin at Further infrmatin Llyd s Cmplaints Team will be hlding briefing sessins n internatinal cmplaints handling fr managing agents during the week cmmencing 29 February Invitiatins will be sent ut shrtly t all managing agents.. Page 5 f 6

6 MARKET BULLETIN Any questins regarding the arrangements fr cmplaints handling at Llyd s can be sent t the Cmplaints Team by at: cmplaints-enquiries@llyds.cm. Alternatively managing agents can cntact the Cmplaint Handling Helpline n Page 6 f 6

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8 Appendix 2 Cmplaints January 2016 Handling Internatinal Cmplaints at Llyd s: Guidance fr managing agents and their representatives This guidance nte prvides a practical prcess fr handling internatinal (nn-uk) cmplaints received frm Llyd s plicyhlders. Where cmplaints arise plicyhlders shuld expect t have their cmplaint dealt with in a prmpt and reasnable way. At the same time, different cuntries have different lcal rules fr the handling f cmplaints. Llyd s arrangements fr internatinal cmplaints are intended t allw fr the versight f cmplaints handling utside f the UK, cnsistent with the regulatry expectatins f the UK Financial Cnduct Authrity (FCA), whilst allwing flexibility fr managing agents in the way they handle cmplaints in accrdance with lcal rules. It is therefre imprtant that managing agents ensure they are able t cmply with the lcal rules in territries utside the UK as well as Llyd s requirements fr handling cmplaints in that territry. Any questins shuld be directed t the Cmplaints team. Nte: This nte is nly intended t prvide summary guidance f Llyd s arrangements fr internatinal cmplaints handling. Managing agents shuld cntinue t refer t Crystal fr the cmplaints regulatins that apply in each territry. In additin, Llyd s has prduced fr each territry a summary sheet setting ut the key lcal requirements. Nte that in a few instances, the lcal requirements will mean that managing agents must fllw a different prcess t that which is set ut in this nte. That is highlighted in the relevant summary sheet. In the event f any differences between the cuntry specific summary sheets and this nte, the cuntry specific summary sheets shuld be fllwed. Fr mre infrmatin abut internatinal cmplaints handling at Llyd s please refer t Prcess t be fllwed fr handling internatinal cmplaints Managing agents must have in place prcedures that allw cmplaints t be made by any reasnable means, including rally. The definitin f a cmplaint t be applied is that which is mandated by the relevant regulatr in each territry. Where n definitin exists, the fllwing definitin shuld be used: "any ral r written expressin f dissatisfactin, whether justified r nt, frm, r n behalf f, a persn abut the prvisin f, r failure t prvide, a financial service, which alleges that the Llyd s cmplaints Page 1 f 5

9 LLOYD'S INTERNATIONAL COMPLAINTS cmplainant has suffered (r may suffer) financial lss, material distress r material incnvenience." It is the respnsibility f managing agents t handle all internatinal cmplaints apprpriately and ensure they are cmpliant with all relevant lcal rules. This includes any requirement t acknwledge cmplaints, prvide infrmatin t the cmplainant and meet applicable time limits. Every tw weeks (r mre frequently if required t cmply with the 14 day ntificatin requirement) managing agents r their representative (which culd be a cverhlder r third party administratr) must cmplete the Llyd s Internatinal Cmplaint Ntificatin template, prviding details f all new cmplaints received where the cmplainant is eligible t have their cmplaint cnsidered by the lcal External Dispute Reslutin (EDR) scheme. Furthermre, there may be territries in which the relevant definitin f a cmplainant includes persns whse cases are nt eligible fr cnsideratin by the EDR scheme; thse cases will als need t be ntified t Llyd s. There is n need t include cmplaints which were brught t the attentin f the managing agent by Llyd s. There is n requirement fr a nil return where n new cmplaints have been received. On plicies r binding authrities where there is mre than ne syndicate participating, Llyd s expects the lead syndicate t ntify the cmplaint. The Internatinal Cmplaint Ntificatin Template shuld be dwnladed frm and sent nce cmpleted via t: internatinalcmplaints@llyds.cm. Managing agents must use the template prvided by Llyd s and shuld nt create their wn templates. Cmplaints must be ntified t Llyd s within 14 days f receipt and thse nt ntified t Llyd s with 21 days f receipt will incur an Additinal Administratin Fee charge The fllwing table explains hw t cmplete the Internatinal Cmplaint Ntificatin template. Cmpletin f all fields is mandatry, with the exceptin f the Address field. Managing agents shuld ensure that they prvide the infrmatin in a way that is cmpliant with the applicable data prtectin laws. Field Submitting cmpany Cverhlder Third Party Administratr (TPA) Plicyhlder Surname / Cmpany Name Cmments This is the name f the managing agent r its representative wh is cmpleting and submitting the template. If the plicy was bund by a cverhlder, select the cverhlder name frm the drp dwn list. If a TPA is invlved, select the TPA name frm the drp dwn list. This is the name f the insured individual/entity. Llyd s cmplaints Page 2 f 5

10 LLOYD'S INTERNATIONAL COMPLAINTS Address (Optinal) Pst Cde Plicy Number Risk Lcatin Date Received Cmplaint Cde Class f Business Placement Type Syndicate Number Insert a crrespndence address fr the cmplainant. The pstcde, mailing cde, zip cde, etc. fr the plicyhlder. Please ensure that the Plicy Number detailed n the spreadsheet is referenced n the cmplaint respnse. The territry in which the insured is lcated. Select frm drp dwn list. Insert the date the cmplaint was first received by the managing agent r its representative. Fr example where the cmplaint was initially received by a cverhlder wh subsequently ntifies the managing agent f the matter the date the cmplaint was first received by the cverhlder will be the perative date. Select frm drp dwn list. Select frm drp dwn list. Select frm drp dwn list. Lead syndicate n the cverage. Cmplaints will be entered nt the cmplaints mnitring database by Llyd s t enable effective mnitring and regulatry reprting. Managing agents must als keep their wn recrd f each cmplaint received and the measures taken fr their reslutin. Llyd s reserves the right t review and take ver crdinating the respnse t individual cmplaints where, in the view f Llyd s, this is apprpriate in all the circumstances, including t meet lcal regulatry expectatins f Llyd s. Respnse t cmplainant In all cases a written respnse must be sent t the cmplainant by the regulatry deadline. Where there is n lcal regulatry deadline, a respnse shuld be sent within eight weeks f the date f the cmplaint being received. Respnses must ntify the cmplainant f any right (where applicable) t refer their cmplaint t the relevant EDR service e.g. an Ombudsman r Regulatr, OR the UK Financial Ombudsman Service, if n lcal EDR is available. The letter shuld set ut details f any redress r remedial actin being ffered. Redress includes: Payments t put the cmplainant back int the psitin the cmplainant shuld have been in had the act r missin cmplained abut nt ccurred, including any claim payments Amunts paid fr distress and incnvenience Gdwill payments and gdwill gestures Llyd s cmplaints Page 3 f 5

11 LLOYD'S INTERNATIONAL COMPLAINTS Interest n delayed settlements Waiver f any excess A cpy f the respnse tgether with a cpy f the riginal cmplaint must be ed t internatinalcmplaints@llyds.cm within tw business days after the respnse is sent t the cmplainant. There is n requirement fr these dcuments t be translated t English; this will be arranged by Llyd s. The cvering shuld cnfirm the rt cause f the cmplaint, selecting the main reasn frm : Claim cverage / terms and cnditins Claim delay Claim quantum Claim standard / duratin / delay f repair Cancellatin / refund Custmer Service Prduct suitability Other (we wuld expect this ptin t be rarely used) Llyd s Cmplaints team will mnitr each cmplaint against Key Perfrmance Metrics t ensure: the respnse t the cmplaint addresses all issues raised regulatry deadlines are cmplied with apprpriate EDR rights are prvided t the cmplainant Failure t (1) prvide a cpy f the riginal cmplaint, (2) issue a respnse within the required timeframe, (3) prvide a cpy f the respnse t the Cmplaints Team, (4) prvide crrect and cmplete EDR rights, r (5) cnfirm the rt cause f the cmplaint will incur an Additinal Administratin Fee charge. Where respnses persistently fall belw the standards expected f them, Llyd s will require cpies f all prpsed cmplaints respnses in draft frm fr review befre the respnse is sent t the plicyhlder and these cmplaints will incur an Additinal Administratin Fee charge. Referral t Regulatr r Ombudsman Service Subject t applicable eligibility criteria, cmplainants may refer their cmplaint t their lcal EDR service (mbudsman r regulatr), OR the UK Financial Ombudsman Service if n lcal EDR is available. Managing agents r their representatives must infrm the Llyd s Cmplaints team as sn as they are aware that a cmplaint has been referred t any EDR scheme. When the EDR prcess has been cncluded a cpy f the EDR utcme must be prvided t Llyd s Cmplaints team. Where the EDR scheme perates n a nn-binding basis Llyd s will als require cnfirmatin as t whether the EDR decisin is being accepted r rejected. Llyd s cmplaints Page 4 f 5

12 LLOYD'S INTERNATIONAL COMPLAINTS FCA cmplaints return Every six mnths, Llyd s is required t submit a return t the FCA, detailing the number f cmplaints received, hw quickly they were reslved, hw many were upheld in the perid and the amunt f redress paid. A separate reprt will be submitted fr UK and Internatinal cmplaints. Managing agents will be required t cnfirm n a quarterly basis that they (and anybdy acting n their behalf) have ntified Llyd s f all cmplaints received by them. Llyd s cmplaints Page 5 f 5

13 Appendix 3 Internatinal Cmplaints Handling at Llyd s: France Definitin f a Cmplaint A statement f dissatisfactin frm a custmer t a prfessinal rganisatin. A request fr a service, infrmatin, clarificatin r an pinin is nt a cmplaint. Definitin f a cmplainant Nt defined. Hwever, Llyd s understands that a cmplainant can be an individual persn r a cmmercial entity. Applicatin f Llyd s prcedure and lcal cmplaint regulatins All insurance plicies written n a freedm f services r establishment basis. Timescale An acknwledgement f the cmplaint within 10 business days. A final respnse t be prvided within tw mnths f receipt f the cmplaint. EDR Scheme and Eligibility Insurance Ombudsman at the French Federatin f Insurers (FFSA) / Le Mediateur de la FFSA BP Paris Cedex 90 France Fax: Tel: le.mediateur@mediatin-assurance.rg The Insurance Ombudsman will deal with cmplaints frm plicyhlders and insureds that are individual persns. It will nt deal with cmplaints frm individual third party claimants r beneficiaries r any legal entity. Lcal Regulatry Reprting Requirements Nne Llyd s Cmplaint Ntice The cmplaints ntice fr France, LSW1853, will be amended in due curse. The amended ntice will be published n the Llyd s Wrdings Repsitry in English r French and referenced in the Pre-cntractual ntificatin and Insurance dcuments sectins f Crystal.

14 Internatinal Cmplaints Handling at Llyd s: Germany Definitin f a cmplaint A statement f dissatisfactin expressed by any persn in relatin t an insurance undertaking with regard t the insurance cntract r any service ffered t such a persn. Cmplaints addressed t an insurer cntaining a reference t an insurance intermediary are als included in the definitin. The handling f cmplaints is distinguished frm claims handling, as well as frm a simple request t fulfil the cntract r t prvide infrmatin r clarificatin. A cmplaint, in rder t be cnsidered as such, des nt necessarily have t be titled with the wrd cmplaint. Definitin f a cmplainant A persn wh is presumed t be eligible t have a cmplaint investigated by an insurance undertaking and has already ldged a cmplaint, e.g. a plicyhlder, an insured, a beneficiary, an injured party. Llyd s understands that this definitin refers t cmplaints made by an individual persn r a crprate entity. Applicatin f Llyd s prcedure and lcal cmplaint regulatins All insurance plicies written n a freedm f services r establishment basis. Timescale A prmpt acknwledgement f the cmplaint A final respnse must be prvided within eight weeks f receipt f the cmplaint. EDR scheme and eligibility The Insurance Ombudsman Insurance Ombudsman / Versicherungsmbudsmann e. V. Pstfach Berlin Germany Tel: Fax: (German nly) The cmplainant is eligible t refer a cmplaint t the Insurance Ombudsman if it meets all f the fllwing criteria: the cmplainant is a cnsumer r in a cnsumer-like psitin, the plicy was written n an establishment basis,

15 the value f the cmplaint is EUR 100,000 r less, the plicy is subject t German jurisdictin, the plicy has been issued in the German language, the cmplaint des nt relate t private health insurance, credit insurance r re-insurance The Federal Institute fr Financial Services Federal Institute fr Financial Services / Bundesanstalt für Finanzdienstleistung (BaFin) Graurheindrfer Straße Bnn Germany Tel: +49 (0) mplaintstbafin/cmplaintstbafin_nde.html An individual persn can refer a cmplaint t BaFin at any time and withut first submitting the cmplaint t the relevant insurer r the Insurance Ombudsman. Lcal Regulatry Reprting Requirements Annual reprting t BaFin. This is dne centrally by Llyd s General Representative n behalf f the Llyd s market, Llyd s Cmplaint Ntice A new cmplaints ntice fr Germany will be prduced in due curse. The pre-cntractual ntices LSW1650E and LSW1651D will als be amended accrdingly. The new and amended ntices will be published n the Llyd s Wrdings Repsitry in English r German and referenced in the Pre-cntractual ntificatin and Insurance dcuments sectins f Crystal.

16 Internatinal Cmplaints Handling at Llyd s: Spain Definitin f a Cmplaint A cmplaint shall mean any cmplaint submitted by a user f a financial service due t delays, neglect r any ther failing in the functining f the financial institutin against which the cmplaint is filed. It als includes cmplaints, with a view t btaining cmpensatin fr the harm t the user's interest r right, fr specific facts abut acts r missins, which are detrimental fr the user and that arise frm breaches f the regulatins n transparency and custmer prtectin, r f gd practices in financial business. A cmplaint must be submitted t the insurer in writing in rder fr it t be cnsidered a cmplaint. Definitin f a cmplainant There is n definitin f a "cmplainant" but any individual persn r crprate entity that has a right r interest in a plicy (e.g., plicyhlder, insured, beneficiary, third party claimant) is entitled t submit a cmplaint t an insurer. Applicatin f Llyd s prcedure and lcal cmplaint regulatins All insurance plicies written n a freedm f services r establishment basis. Timescale A prmpt acknwledgement f the cmplaint The insurer must issue its final respnse, in writing, within 10 days after it has made a decisin n the cmplaint and at the latest within tw mnths f receiving the cmplaint. EDR scheme and eligibility Dirección General de Segurs y Fnds de Pensines / Directrate General f Insurance and Pensin Funds Pase de la Castellana, Madrid Spain Tel: Cmplaints frm individuals and crprate entities may be referred t the insurance regulatr, the Directrate General f Insurance and Pensin Funds (DGS). The DGS deals with cmplaints in respect f mass risks written by lcal and EEA insurers.

17 Lcal Regulatry Reprting Requirements Llyd s Cmplaints Ntice Nne A new cmplaints ntice fr Spain will be prduced in due curse. The Pre-cntractual ntices and the Imprtant Infrmatin ntices fr plicy dcuments will be amended accrdingly. The new and amended ntices will be published n the Llyd s Wrdings Repsitry in English r Spanish and referenced in the Pre-cntractual ntificatin and Insurance dcuments sectins f Crystal.