Norma vigente
Financial customer protection is crucial for preserving trust in and fostering the stability of the financial system, and a key objective for the Banco de España in the fulfilment of its duties.
The oversight function in respect of institutions’ conduct and transparency of information and, generally, of those aspects which, like the functioning of customer service departments (CSDs), are related to customer protection, has been performed within the Banco de España by the Institutions' Conduct Department since 1 October 2014.
In pursuing this task, the Banco de España has progressively deepened its analysis of the functioning and organisation of supervised institutions' CSDs, identifying in this process the best practices in this domain.
The principles and criteria set out in these guidelines have been defined taking into account the applicable national regulations and draw on the supervisory guidelines adopted by the Banco de España in this area, in particular those of the Joint Committee of the European Supervisory Authorities on complaints-handling for the securities and banking sectors [1] and the European Banking Authority (EBA) Guidelines on internal governance[2].
The guidelines have been drawn up by the Banco de España by virtue of the regulatory authorisations (detailed below) relating to its competence to prepare technical guidelines addressed to supervised institutions and groups, indicating the criteria, practices, methodologies or procedures that it considers appropriate for compliance with supervision regulations:
Law 10/2014 of 26 June 2014 on the regulation, supervision and solvency of credit institutions, in its Article 54.
Law 21/2011 of 26 July 2011 on electronic money, in its Article 20(1).
Royal Decree-Law 19/2018 of 23 November 2018 on payment services and other urgent financial measures (hereinafter Royal Decree-Law 19/2018), in its Article 26(1).
Royal Decree 775/1997 of 30 May 1997 on the legal regime for the official recognition of appraisal services and companies, in its Article 15(1) on supervisory powers over these companies.
Royal Decree 2660/1998 of 14 December 1998 on the changing of foreign currency in establishments open to the public other than credit institutions, in its Article 6 on supervisory powers over these entities.
The content of these guidelines applies expressly to specialised lending institutions, by virtue of the provisions of Article 33(2) of Royal Decree 309/2020 of 11 February 2020 on the legal regime of specialised lending institutions.
These guidelines are addressed to institutions supervised by the Banco de España that are subject to Ministerial Order ECO/734/2004 of 11 March 2004 on the customer service department and ombudsman of financial institutions (hereinafter Ministerial Order ECO/734/2004). Specifically, the guidelines identify the recommended best practices in respect of the organisation and functioning of CSDs at the following institutions:
a) Credit institutions.
b) Specialised lending institutions.
c) Payment institutions and institutions subject to the provisions of Articles 14 and 15 of Royal Decree-Law 19/2018.
d) Electronic money institutions.
e) Branches in Spain of the institutions listed in the foregoing paragraphs with a registered office in another State.
The guidelines are also addressed to appraisal companies and to currency-exchange bureaux authorised to conduct foreign-currency sale transactions, as regards the matters applicable to them in accordance with the second additional provision of Ministerial Order ECO/734/2004.
Any mention in the guidelines to “the institution” or “institutions” shall be understood as referring to all the above types of institutions, expect where another meaning is clearly inferred from the content of the guidelines.
The criteria set out in these guidelines must be used to assess CSDs’ performance in their two main functions. These are, first, the complaints-handling function (which is undoubtedly the most evident and immediate task of CSDs) and, second, the much more strategic and independent function of control, as an early warning engine for the early detection of problems arising from the marketing of products or services and/or from institutions’ customer relations.
Institutions should apply the principles and criteria contained in these guidelines in accordance with proportionality criteria, on the basis of their size and the nature, scope and complexity of their activities. To this end, the following parameters, as a minimum, shall be taken into account:
The authorised activities and services of the institution.
The size of the institution, in terms of the balance-sheet total and/or the size of its operations.
The distribution channels used.
The number of complaints received at any body of the institution.
The type of customer of the institution (consumers, the self-employed, SMEs or other).
3.1. CSD control function
3.1.1. Pursuant to the provisions of Article 4 of Ministerial Order ECO/734/2004, institutions shall have a “specialised customer services department” (commonly known as a CSD) that aims to consider and resolve the complaints made by their customers.
3.1.2. However, as an inherent part of the functions it exercises, in practice the CSD also performs a function of control given its awareness of sources of customer dissatisfaction.
3.1.3. In the performance of its functions, the CSD assesses the conduct of the business and operational areas in their relations with customers when a complaint has been made. In addition, they are also expected to analyse, on an ongoing basis, complaints-handling data in order to identify and address recurring or systemic problems, and potential legal, operational and conduct risks, among others, duly reporting on the results of such analyses to their management body (for the purposes of these guidelines, “management body” should be understood as the institution’s board of directors or equivalent body or, in the case of branches of foreign institutions or other supervised institutions registered with the Banco de España, general management). The management body may carry out the actions indicated in these guidelines, either directly or through its commissions or delegated committees, except in those situations where action is expressly reserved in the regulations to the most senior management body.
3.1.4. In this regard, thanks to the key source of relevant information that they handle, CSDs provide early warning of problems arising from the marketing of products or services and/or from institutions’ customer relations, which should necessarily be taken into consideration by the institutions for selecting and adopting the appropriate measures in order to correct such problems or even prevent them from arising.
3.2. Organisational and functional independence
3.2.1. Article 6 of Ministerial Order ECO/734/2004 states that “institutions shall adopt the necessary measures to separate the customer service department from the organisation’s other commercial or operational services, so as to ensure the CSD takes decisions in respect of its area of activity autonomously and thus avoids conflicts of interest”.
3.2.2. For these purposes, the CSD manager is also expected to have the institutional authority and weight needed to adopt decisions independently, prevent business units or operational services from interfering in the management and resolution of complaints, exert the capacity to submit proposals to the management body and, in general, enjoy fluid access to this body.
3.2.3. It is for the institution to determine the specific location and reporting lines of the CSD within its structure, so it may be ensured that the CSD manager may act, in the exercise of his or her functions, independently of the organisation’s other commercial or operational services.
3.2.4. In this respect, and with a view to promoting such independence, institutions may opt to have the CSD reporting directly to the institution's management body, or to have it report to cross-departmental committees or bodies removed from the institution’s business management. In any event, institutions should adopt the precise measures to ensure its functional independence from their other operational units.
3.2.5. In short, the aim is for the CSD to be hierarchically and organisationally separate from the services that adopted or influenced the decisions or actions that are the subject matter of the customers’ complaints. In this respect, it is advisable that the hierarchical superiors of the CSD manager report to bodies that solely have functions relating to control or supervisory areas. Consequently, the CSD’s hierarchical line should not participate in – or see its work interfered with by – the performance of functions involving operational or management responsibilities in the institution’s business lines or areas.
3.2.6. As regards determining whether the institution should set up the CSD as an independent and exclusive organisational department or unit, or whether it can be integrated into a department performing other functions, the institution may tailor its decision to its size and the complexity of its activities, provided that, whatever the option adopted, it enables a flexible and effective service to be offered in the resolution of customer complaints, without compromising the control function or the independence of the CSD.
If the CSD is integrated into a department that performs other functions, these functions should not be related to the institution’s commercial or operating activity.
In any event, in general, the attachment of the CSD to the audit department would only be justified on account of an institution’s reduced size or complexity.
4.1. Appointment, removal and renewal of the CSD manager
4.1.1. Under Article 5 of Ministerial Order ECO/734/2004, the CSD manager should have “commercial and professional integrity”, as well as the “appropriate knowledge and experience” for exercising his or her functions.
Further, in order to establish responsibility for the appointment process at the highest level, Ministerial Order ECO/734/2004 lays down the requirement that the institution's management body shall be responsible for designating the CSD manager.
4.1.2. The CSD manager of institutions (as defined in Section 2 of these guidelines) performing activities subject to Law 5/2019 of 15 March 2019, regulating real estate credit agreements (hereinafter Law 5/2019), and its implementing regulations should have the knowledge and minimum skills applicable to real estate lender staff, in accordance with the provisions of that law.
In this respect, these institutions may decide whether the CSD manager should accredit the training referred to in Article 32 ter et seq. of Ministerial Order EHA/2899/2011 of 28 October 2011 on transparency and customer protection in banking services, following the amendments introduced by Ministerial Order ECE/482/2019 of 26 April 2019. In any event, it is advisable that managers of CSDs set up as an independent and exclusive organisational department or unit have the aforementioned accreditation.
4.1.3. There are no regulatory prescriptions regarding the specific unit or body of the institution that is to select and assess the CSD manager candidates, for the purpose of proposing final appointment (or renewal or removal in the case of incumbents) to the management body. However, it is important that institutions establish appropriate internal units and procedures to carry out the selection and assessment of the heads of control functions (among which CSD managers should be included). If the institution has an appointments committee, the proposal to appoint, renew or remove the CSD manager should ideally be made by such committee.
4.1.4. In this respect, institutions should not only have CSD manager designation procedures that ensure that the person selected has the necessary commercial and professional integrity and appropriate knowledge and experience, but they should also have documented processes for renewal in and removal from the post that safeguard the foregoing guarantees and preserve autonomous decision-making.
4.2. CSD staff and training programmes
4.2.1. As detailed in Article 6(2) of Ministerial Order ECO/734/2004, the institution should ensure that its CSD has the appropriate human, material, technical and organisational resources to fulfil its functions. In this connection, it is considered advisable for the CSD to have:
a) Ready access to the information it may need to perform its functions.
b) Staffing suited to the institution’s complexity and to the number of complaints received so that they are able to resolve complaints within the legally stipulated terms and with the expected quality.
c) A team with appropriate experience in complaints management and/or resolution and in implementing banking transparency regulations that is sufficiently balanced among its members.
d) Periodic training programmes to ensure that staff's knowledge is kept up to date.
e) IT tools with an appropriate capacity so that complaints can be swiftly managed.
f) Automated processes that ensure the efficient receipt, handling and resolution of complaints and mitigate the risk of potential human errors.
4.2.2. As regards training programmes, institutions must establish and apply policies and procedures ensuring that the CSD staff have appropriate awareness of the following: i) the applicable regulations, in general, and transparency and customer protection rules, in particular; ii) good practice criteria adopted by supervisors in resolving complaints; iii) supervisory guidelines on this subject matter, and; iv) the related case law impacting its scope of action.
In this respect, it is desirable that the training of the CSD staff of institutions performing activities subject to Law 5/2019 includes the matters established in that law and in its implementing regulations, relating to the knowledge and minimum skills applicable to real estate lender staff.
4.3. Externalisation of the CSD
4.3.1. Article 4(1)(1) of Ministerial Order ECO/734/2004 establishes the obligation for institutions to have a specialised customer services department. Moreover, it establishes that institutions forming part of the same economic group may, if they consider it advisable, have a single CSD for the entire group. In that case, the CSD would have to be located within the structure of a supervised financial institution.
4.3.2. Further, the Banco de España considers that the CSD and its manager, as the person responsible for this department, should generally be integrated into the organisational structure of the institution (or of the parent institution, in the aforementioned case of a single CSD for groups of companies), thereby avoiding the contingency of transferring this responsibility to a third party, which would limit the Banco de España’s supervisory and control capacity.
As regards the potential externalisation of processes related to the management of complaints and the processing of resolutions, should this occur, it should not void of content the institution’s activity or diminish its internal control capabilities or the Banco de España’s supervisory capacity.
4.4. Conflict of interest policy
4.4.1. It is deemed advisable that institutions’ policies for identifying and preventing conflicts of interest specifically envisage the treatment to be given to those cases in which the conflict of interest affects the CSD manager and staff, and that they establish a protocol for the replacement of persons subject to conflict, setting requirements for those who are to replace them.
4.4.2. One of the sources of such conflicts of interest may arise from dedication by the CSD manager to other tasks or positions not related to CSD functions. In this respect, the degree of dedication of the CSD manager should be appropriate, considering both the number of complaints received by the institution and the other resources assigned to the CSD. Nevertheless, in cases where the post of CSD manager is shared with other functions that are far removed from the business areas, such simultaneous position-holding should contribute to enhancing the implementation of the principles and criteria set out in these guidelines.
4.4.3. Even when in specific cases, justified by the nature, scope and complexity of the institution’s activities, the person designated as CSD manager – or, generally, the staff assigned to the CSD – can perform other functions in the institution, these should not interfere in the CSD’s functions; accordingly, they should not comprise tasks related to operational functions or to the business areas.
4.4.4. In cases in which the CSD manager simultaneously holds other positions or performs other functions which, though far removed from the business areas, could compromise the independence of the CSD's work, such simultaneous position-holding should be avoided. By way of example, this would be the case if the CSD manager were simultaneously to hold the post of audit head, as the CSD is also an auditable function. Conflicts of interest might also emerge in the case of the head of legal counsel, to the extent that the function is predominantly exercised in defence of the institution’s interests.
4.5. Remuneration policy
Institutions are expected to have a specific remuneration policy for the CSD manager and staff. The methods used to determine the variable remuneration, if any, should not jeopardise the objectivity or independence of the CSD manager or staff. In this regard, the parameters considered should not depend on, or be predominantly linked to, the objectives or the performance of the business units they supervise, or other circumstances that could give rise to conflicts of interest. The body or officer that sets the objectives for the CSD and assesses its performance should not be responsible for managing business units.
4.6. Action plans
4.6.1. Institutions are expected to have appropriate action plans (annual or multi-annual) specifying the objectives, time limits and estimates of the technical and human resources needed for the performance of the CSD functions, to ensure its ability to operate on an ongoing and effective basis. The management body shall monitor these plans and regularly check their implementation and fulfilment. This monitoring may be conducted within the framework of the annual report envisaged in Article 17 of Ministerial Order ECO/734/2004 and in accordance with Section 6.2 of these guidelines.
4.6.2. The action plan should include, among others, the following objectives: i) to apply the criteria set by the CSD in its resolutions to the institution’s day-to-day operations in its dealings with customers, with the aim of reducing the number of new complaints; ii) to adapt the resolution period to the type and circumstances of the complaint and, in any event, to comply with the legally established time limits; iii) to increase customer satisfaction during the complaints-handling process; and iv) to reinforce training for CSD staff.
4.7. Operating regulation
4.7.1. In accordance with the provisions of Article 8 of Ministerial Order ECO/734/2004, every institution or group should have an internal regulation on customer protection governing CSD activity, approved by the management body.
Exceptionally, and where appropriate to expedite processing, another body or person designated within the organisation may be delegated the power to amend the regulation and to include, on behalf of the management body, any indications that may be issued by the competent authorities or changes to the legislation in force; the delegate shall have to report on his or her actions to the management body at the next meeting held.
The regulation should include the institution’s general policy for receiving, handling and resolving complaints, in addition to the minimum content provided for in Article 8 of Ministerial Order ECO/734/2004.
4.7.2. As regards the time limits envisaged in the regulation for the admission of complaints, best practice is considered to be that which does not restrict the time limit for lodging complaints to the minimum period of two years from the date the customer becomes aware of the events giving rise to the complaint as established by Article 8(3)(e) of Ministerial Order ECO/734/2004. In this regard, a period of five years from the date such events arose is considered appropriate, provided that the minimum two-year period from when the customer became aware of them is respected.
4.7.3. Additionally, institutions are expected to draw up and approve internal rules including general and operating instructions to be followed by the offices and their own CSD in order to ensure that the complaints submitted by customers and consumers through the different channels set up for this purpose are appropriately registered, transferred, managed and resolved, within the legally established time limits or those assumed by the institution (which may in no case be longer than those established by law).
4.7.4. Under Article 9 of Ministerial Order ECO/734/2004, institutions are required to ensure that the operating regulation of the CSD is available to their customers at all their offices that are open to the public. However, it is also advisable for the general complaints management policy and, specifically, the regulation itself, to be accessible to all the institution’s employees or, at least, to those who render services in business units or who hold a position in the institution where such knowledge might be necessary.
4.7.5. Although the obligation under Article 9 of Ministerial Order ECO/734/2004 to also make the regulation available on institutions’ websites is limited to those cases where they enter into contracts online, such availability is desirable in all cases, even where institutions do not enter into contracts remotely.
4.7.6. In any event, regardless of the format or channel used to make this information available to customers, measures should be adopted to ensure easy and ready access, seeking to feature the regulation prominently when it is included in intranet or internet pages, with a clear access route and a small number of steps or intermediate screens, and regularly verifying that accessibility conditions are maintained.
4.7.7. It should be noted that making the regulation available on their websites does not relieve institutions from their obligation to provide their customers, by any other means made available to them (brochures, pre-contractual information, contractual documents), with accurate information on how to contact the CSD in accordance with the provisions of the regulation, on how to submit complaints, on the time limits and general processing of complaints and on the possibility for the complainant to turn to the competent authority in the event of disagreement with the final decision or if the CSD resolution period elapses without it issuing a decision.
4.7.8. Should the institution engage in other activities not subject [3] to the banking regulation and discipline legislation, it is advisable for this to be stated in the regulation.
5.1. Channels for receiving complaints
5.1.1. Article 11 of Ministerial Order ECO/734/2004 stipulates that complaints may be submitted on paper or by computer, electronic or telematic means, provided the documents may be read, printed and stored. In this connection, it should be possible to submit complaints at any of the establishments open to the public, even if it is not the customer’s branch, regardless of whether the complaints refer to a transaction carried out in another branch. In any event, institutions must provide a CSD e-mail address for customers to lodge their complaints.
5.1.2. It is also advisable for institutions to make available to their customers, on paper and in electronic format, forms for submitting their complaints to the CSD that contain the minimum information requirements of Article 11(2) of Ministerial Order ECO/734/2004. This is without prejudice to the fact that institutions must accept complaints that meet the regulatory requirements and are submitted in any other format.
5.1.3. Additionally, institutions are required to clearly inform customers of the specific official channels that have been set up for submitting complaints, subject to Ministerial Order ECO/734/2004. The channels for contacting the CSD are expected to be featured prominently on institutions’ websites, grouped together in a single section with a clear access route. In this regard, institutions should have sufficient information about the volume and characteristics of the complaints filed through each of these channels.
5.1.4. In any event, regardless of the channels set up, the institution must ensure that a written acknowledgement of receipt of the complaint is issued to the user, either on paper or in any other durable medium. The latter is understood to be any instrument enabling the customer to store the information personally addressed to him/her in such a way that it can be readily recovered over an appropriate period of time for the purposes for which the information was issued and that allows the information stored to be reproduced without changes, thus documenting the date on which the complaint was submitted and, if appropriate, transferred to the CSD.
5.1.5. Under no circumstances is it admissible to establish alternative channels for the receipt of complaints which do not fulfil the obligation to transfer to the CSD any complaints not resolved in favour of the customer.
5.2. Controls and register
5.2.1. The plurality of sources and formats for submitting complaints requires that institutions set up controls to ensure that complaints are not only properly registered but that they are sent, when appropriate and within the time limits set by the institution for this purpose, to the unit responsible for resolving them within the legally established time limit.
5.2.2. Thus, institutions should have a centralised register of complaints received that enables all of them to be comprehensively managed and handled in a uniform manner, irrespective of the channel through which they were received, and allows the CSD to be aware of them, including those resolved directly at the offices and those, if any, processed by the branch.
5.2.3. In this connection, institutions’ general policy for receiving, handling and resolving complaints should envisage the various forms or media available for their customers to be able to submit complaints, as well as the bodies specified for receiving them, the procedure established for registering them and acknowledging receipt, the time limits set internally for transferring them to the competent body for resolution and the control mechanisms to ensure that the procedures function properly, thus avoiding incidents such as loss, errors, omissions or delays in the aforementioned time limits.
5.3. Resolution bodies
5.3.1. Where an institution has set up separate complaint resolution bodies, the competences of each one are expected to be clearly defined, along with the resolution criteria, in order to apply them in a uniform and predetermined manner throughout the organisation.
5.3.2. However, under no circumstances should such decentralisation lead to failure to comply with the obligation to send to the CSD those complaints resolved against the customer, nor can it entail the CSD losing its comprehensive view of the functioning of global complaint management at the institution.
5.3.3. Specifically, since the commercial offices are one of the most direct and easily accessible channels for customers to submit complaints, when the institution considers the office itself to be one of the complaint resolution bodies, it should establish a procedure determining its powers in the direct resolution of complaints which includes transferring to the CSD the information relating to the complaints handled, including those resolved by the branch itself.
5.4. Resolution criteria and time limits
5.4.1. Institutions are expected to have an appropriate written procedure for the resolution of complaints. The document should include uniform and predetermined criteria applicable to the resolution of complaints received at the institution, the way in which these criteria are made known and the frequency with which they are revised and updated, and allow possible regulatory changes or their progress to be monitored in an orderly fashion.
5.4.2. Similarly, institutions should gather and analyse all the relevant data and information about complaints and use straightforward easily understandable language in their communications with customers. Institutions are reminded of the need to provide a thorough explanation of their position on the complaint as well as information about the possibility of referring the matter to the higher competent dispute resolution body.
In addition, in the event that the institution also engages in other activities not subject to the banking regulation and discipline legislation, this should be mentioned in the CSD’s resolution.
5.4.3. Also, in order to ensure compliance with the legally established time limits for the resolution of complaints, institutions are expected to clearly define the time limits for their internal procedures and, in particular, for transferring to the CSD the information required by the latter from other units, and to set out the arrangements for the follow-up of effective compliance with these internal time limits and for the monitoring of the age of the complaints.
5.4.4. Institutions are also expected to adequately follow-up on the complaints submitted by their customers to the competent authority and to set up an assessment procedure for resolutions so as to include, where appropriate, the criteria for interpreting the regulations and the good practices contained therein.
6.1. Communication channels
6.1.1. Institutions should ensure that there are clear, direct lines of communication between the CSD manager and the management body, and with the institution’s other control units, allowing for regular reporting (e.g. periodic reports) and occasional reporting, as circumstances require, in order to convey alerts, concerns, etc.
6.1.2. It is also advisable for the CSD manager to participate in a direct and fully independent manner in the committees responsible for approving new products or significant changes in existing ones, or for the standpoint and experience of the CSD to be incorporated into the approval process, which would contribute to improving the design of products, mitigation of their risks, the ability to understand them, the definition of their target group and how they should be marketed.
6.2. Reports prepared by the CSD
6.2.1. As provided by Article 17 of Ministerial Order ECO/734/2004, in the first quarter of the year the CSD should submit to its institution’s management body a report on the performance of its functions during the preceding year. The report should be made available to the management body sufficiently in advance of the date envisaged for its approval, so that it can be duly analysed.
6.2.2. Ministerial Order ECO/734/2004 regulates the minimum content of this report, which should include, among other details, a statistical summary of the complaints submitted and of the decisions issued, the general criteria included in these decisions and the recommendations or suggestions arising from its action.
In particular, it is expected that the statistical summary of complaints referred to in the aforementioned regulation will make it possible to obtain a systematic breakdown of complaints, by nature and number of the complaints received and under criteria of proportionality, that offers detailed and up-to-date information on the most relevant types of complaints.
By way of example, this systematic breakdown could take into account parameters such as: i) the total number of complaints received, broken down by the different channels set up by the institution or the bodies for their submission, indicating the number of complaints admitted for consideration and rejected; ii) the complaints received by type of complainant for each product group or sub-group; or iii) the breakdown, for each product group and sub-group, of the number of complaints resolved and those that were favourable to the customer, and of the total amount paid out by the institution, classified according to the main specific reasons for complaint. This should all be consistent with any information reported to the supervisor.
6.2.3. Should several institutions of the same group have a shared CSD, it is expected that the annual report will contain, at least, the minimum information referring to each individual institution and that this information will be submitted for approval to their respective management bodies.
6.2.4. It should be noted that, aside from the minimum obligations required by Ministerial Order ECO/734/2004 with regard to the annual report, the latter is a core element of the accountability of the complaints management function vis-à-vis the management body and, consequently, should offices or other bodies in the institution participate in the resolution of complaints, within or outside the framework of Ministerial Order ECO/734/2004, the information on the volume and manner in which they are resolved should also form part of said annual report.
6.2.5. Additionally, the annual report must include the follow-up of the degree to which the recommendations made by the CSD in previous annual reports are implemented in order to assess the effectiveness of the measures suggested in these reports.
6.2.6. In addition to the above-mentioned annual report, it is desirable that institutions, at least larger and more complex ones, set in train procedures for the CSD to report to the management body including, for example, information on the number of particularly relevant complaints submitted to and resolved by the competent authority.
6.3. Independent review by internal audit
The CSD is expected to be subject to independent internal review by the institution’s internal audit function. Internal audit should assess the proper functioning and organisation of the CSD. In particular, it will review the proper registration, transfer and handling of complaints, and the overall communication and control mechanisms, independence, organisation and procedures of the CSD.
6.4. Complaint follow-up and control
6.4.1. The scope of the complaints assessment process should cover all the complaints processed within the institution, irrespective of the body which has resolved them.
6.4.2. It is also advisable that, as a result of the analysis, not only the institution's procedures which are directly affected be corrected so that the same problems do not happen again, but that the causes be investigated as to whether they could affect in turn other processes or products, including those for which no direct complaints have been received.
6.4.3. In cases where several institutions in a group have a shared CSD, these follow-up and control mechanisms should be defined for each of the institutions attached to the CSD.
These guidelines shall enter into force on the day following their publication on the Banco de España website.
