Liminal secures FSP license from FSRA in ADGM   Read more

Complaints Handling Policy

1.1 First Answer Middle East Limited (“the Company” and/or brand name “Liminal”) must implement systems and controls to comply with the regulatory obligations of the Abu Dhabi Global Markets (ADGM)’s Financial Services Regulatory Authority (FSRA). Such systems include a series of processes and manuals which evidence compliance with such obligations.

1.2 Senior Management within the Company must take reasonable steps to ensure the implementation of such systems which reflect the nature, size, and scale of the proposed activities of the Company.

1.3 As per the ADGM’s General Rule book no. 7 on Complaints handling and dispute resolution, Liminal must have adequate policies and procedures in place to fulfill the provisions on complaints handling.
2.1 As a regulated entity, Liminal is required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints received from its Customers.

2.2 All complaints should be directed to the Compliance Officer. Complaints may be submitted on the website or by email or by post. The Compliance Officer within one week shall provide a confirmation of the receipt of the complaint to the respective customer.

2.3 The Compliance Officer shall then delegate the investigation of the complaints to an employee or to a team depending on the nature of the complaint who shall be responsible for addressing and resolving.

2.4 The submission of the complaint is not tied to any fee or consideration.

2.5 From the initial discussions with the customer and/or information obtained from the assigned employee or team, the Compliance Officer shall be in a position to assess whether the complaint is of a minor nature or whether the complaint is more serious and therefore must be channeled for further investigation in terms of relevant legislation. Decision shall also be taken at this stage if it requires involvement of regulatory and/or legal enforcement authorities.

On receipt of a complaint, the Compliance Officer shall ensure that an acknowledgement is sent out within one week of the complaint being made. This acknowledgement shall contain:

i) Acknowledgement of the complaint and;

ii) On completion of the investigation, the Company will write back to the Customer concerning the outcome.

2.7 Complaints received by the Compliance Officer shall be logged in the Complaints’ Logbook.

2.8 The Company shall strive to resolve all complaints within four (4) weeks of the complaint being made.

2.9 In extraordinary circumstances where adherence to the four-week time frame is not possible, the Company must provide the Customer with an update on the status of the complaint, and explain the extraordinary circumstances delaying its resolution within four weeks of the complaint being made. Nonetheless, the Company shall resolve the complaint by not later than eight (8) weeks from when the complaint was made.

2.10 In communicating its final decision to the client, the Compliance Officer shall:

i) Include a very short description of the complaint, and of the outcome of the Company’s investigation;

ii) Set out the Company’s final view on the issues raised in the complaint; and

iii) Include details of any redress that is being offered, if considered appropriate.

2.11 The Compliance Officer will report to the Board on a quarterly basis in relation to all the complaints received.

The Compliance Officer shall ensure that in handling complaints, there is a clear identification and remedial action taken to avoid the recurrence or systemic problems thereby:

(a) Identifying common root causes of complaints;

(b) Considering whether such root causes can also affect other processes, services or products offered by the Company including those not directly complained of;

(c) Correcting such root causes.