Bank of Lithuania
2021-04-22
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The Bank of Lithuania checked whether payment service providers appropriately investigate consumer complaints. The laws envisage that providers should submit to consumers a comprehensive and reasoned reply based on documents within 15 business days. The survey included 9 banks and 12 electronic money institutions.

Best practice: complaints related to losses incurred by consumers are investigated faster
The survey revealed that the requirements for the investigation of complaints were appropriately followed by the majority (80%) of market participants, however, certain shortcomings were observed in the activity of several enterprises.

In the period under review, there were cases when several payment service providers submitted replies to consumers later than required. When submitting them, they failed to indicate the reasons for being late in replying, as required by laws.

Nevertheless, the majority of payment service providers provide answers to consumers earlier than required by legal acts. Some of them indicated 5 business days on average as the duration for the investigation of complaints, while others indicated 10 business days.

It is important to note that a part of payment service providers accelerate the investigation of those complaints that are related to potential losses of their customers or where these losses are very substantial. The fact that payment service providers consider not only the date of submission of a complaint, but also the requirement indicated in it when investigating complaints, should be considered as best practice, as it ensures a timely response to the situations that cause the largest damage.

Most institutions submit comprehensive and reasoned replies
In terms of their content, replies were comprehensive, detailed and clear. In some cases, shortcomings were ascertained: replies do not always indicate the legislative requirements or contractual provisions that constitute the basis for the resolution of complaints. Therefore, it may be difficult for consumers to understand whether replies submitted by payment service providers are correct and whether it is worthwhile to appeal them.

Recommendations to market participants

  • Efficient investigation of complaints ensuring that consumers know and can evaluate their rights is one of the fundamental elements for the protection of these rights. Therefore, it is necessary to submit to customers as comprehensive and reasoned reply as possible, so that they can assess whether the actions and decisions of payment service providers comply with the requirements of legal acts and/or provisions regulating their relationship.

Recommendations to consumers

  • If you think that a financial market participant infringes your legitimate interests, you should submit a written complaint or claim to the service provider itself at first and only then, if you do not receive a reply within 15 business days or the reply seems unsatisfactory to you, you are invited to apply to the Bank of Lithuania for dispute investigation.