Response to consultation on draft RTS on the requirements, templates and procedures for handling complaints under MiCAR
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In particular, it is not clear to me whether the "complaints management function" shall be a separate function within the IART, with the sole responsibility of handling complaints or whether it can also be part of the "compliance function", especially for small size IART.
I would suggest to specify that, depending on the size of the IART, the compliance department may be held responsible for handling complaints and therefore incorporate the "complaints management function".
Question 1: Do you consider that the approach proposed in the RTS strikes an appropriate balance between the various competing demands described? If not, please suggest an alternative approach and the underlying reasoning and evidence.
YesQuestion 2: Do you have any comments on the requirements proposed in Articles 1, 2, 3 or 4 of the draft RTS?
I have a comment on article 2 (b) of the draft RTS.In particular, it is not clear to me whether the "complaints management function" shall be a separate function within the IART, with the sole responsibility of handling complaints or whether it can also be part of the "compliance function", especially for small size IART.
I would suggest to specify that, depending on the size of the IART, the compliance department may be held responsible for handling complaints and therefore incorporate the "complaints management function".