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Complaint Policy 

 

Policy Statement 

Zenus Bank International (“Zenus”) is committed to consistent, fair, and confidential complaint handling and to resolving complaints as quickly as possible. It is the policy of Zenus to treat all customers and non-customers making a complaint with courtesy and respect. It is the policy of Zenus to respond to customer and non-customer complaints promptly as Zenus understands the seriousness of complaints. This Complaint Policy and Zenus’ procedures are intended to encourage customers and non-customers to openly communicate any issues or concerns with the Institution. 

 

For purposes of this Policy, a complaint is defined as an issue raised at customer service or department level or issues raised directly with Zenus management or with a third party (e.g., regulatory agencies) for resolution. 

 

Customer and non-customer complaints may come in many forms, including verbal or in writing, directly from the customer or non-customer, his/her attorney, or a regulatory agency. It is the policy of Zenus to monitor complaints to and/or about third parties that are providing services on behalf of Zenus. The appropriate procedure to follow for addressing a complaint depends on the form in which it was received. 

 

Zenus has implemented procedures for the submission, tracking, and resolution of all submitted complaints. Procedures shall ensure complaints are addressed promptly. Individuals or departments responsible for addressing complaints shall be designated and communicated to all Zenus personnel to expedite responses. 

 

Consumer Complaint Response 

The responsibility for monitoring and responding to complaints is delegated to the Complaint Resolution Officer of Zenus. Complaints may be indicative of a compliance weakness in a function or department. Therefore, the Chief Compliance Officer must be made aware of any complaints received. Management shall ensure a timely resolution. Management shall determine the cause of the complaint and take action to improve the Institution’s business practices, as appropriate. 

 

All complaints shall be logged in the Zenus Complaint Log with, at a minimum, the following information: 

  • Date Complaint Received; 

  • Description of the Complaint; 

  • Received From (name, address, telephone number); 

  • Relationship to the Institution; 

  • Received By; 

  • Copied To; 

  • Assigned to for Resolution; 

  • Date Initial Response; 

  • Date Final Response; and 

  • Description of Resolution. 

 

It is the policy of Zenus in the event a complaint is received by an employee or one is sent to Zenus’ state or federal banking regulatory agency, that Zenus shall use the following general guidelines in responding to a complaint: 

  • When practical, provide a copy of the Zenus’ Customer Complaint Policy and Procedures Notice to the complaining party. A copy of the Notice is found in the Appendix to this Policy. 

  • All verbal or written inquiries or complaints are to be forwarded to the department related to the complaint with a copy to the Compliance Department. If the complaint involves an alleged violation of a regulation, such as Regulation E, or has been directed to Zenus through its regulatory agencies, the complaint shall be logged and assigned to the Compliance Officer and CEO for resolution. 

  • NOTE: Any customer complaint that comes to Zenus in the form of legal action must be forwarded to the Compliance Officer with a copy within one business day to be addressed by Zenus legal counsel. The Compliance Officer and CEO shall coordinate such efforts with legal counsel. 

  • It is the responsibility of the management (or designee) to log, thoroughly review, and investigate the complaint promptly. All complaints should be reviewed within 1-2 business days. If further action is warranted, Zenus’ will promptly assign the issue to the senior manager of the impacted business area, who will be responsible for timely resolving the matter. It is the policy of Zenus to strive to resolve complaints within 10 business days of receiving the complaint. If the investigation will take longer than 10 business days, the assigned senior manager shall contact the complaining party to inform him/her that the complaint has been received and is under investigation and provide anticipated resolution date. 

  • An initial written response to the complaint is to be prepared by the senior manager and forwarded to the Compliance Officer for review as may be appropriate. If applicable, the Compliance Officer shall prepare a response within 5 business days to the Zenus state and/or federal regulator acknowledging receipt of the complaint and noting a formal response will be forthcoming. 

  • The senior manager is responsible for ensuring the reviewed response is communicated and mailed to the complaining party and notifying senior manager of the disposition of the complaint. The Compliance Officer shall be responsible for ensuring the final resolution is communicated in writing to such regulator. 

  • A copy of the response must be forwarded to the Senior Manager for record retention and resolution logging. 

All documentation concerning the complaint, including the results of Zenus’ investigation, is to be maintained by the Senior Manager and placed in the Zenus’ Complaint Response date base. 

 

 

 

Specific Complaints 

 

Electronic Fund Transfers Act 

If the nature of the complaint is an error as defined in Regulation E (12 CFR Part 1005), it is the policy of Zenus to follow the required error resolution process as set forth in Regulation E. 

 

Unfair, Deceptive and Abusive Acts and Practices (UDA(A)P) 

If the nature of the compliant is unfairness with respect to unfair, deceptive, or abusive acts or practices (“UDAAPs”) including Section 5 of the Federal Trade Commission Act (“FTC Act”) and Sections 1031 and 1036 of the Dodd-Frank Act. Zenus will analyze repeated complaints as well as individual complaints which may raise UDAAP concerns. Complaints that allege, for example, misleading or false statements, or missing disclosure information, may indicate possible UDAAPs in need of review. 

 

Customer Service  

If the nature of the compliant is related to customer service, Zenus will analyze the compliant using the Zenus employee manual.  

 

Whistle-blower  

It is the responsibility of all directors, officers, and employees to comply with the Code of Ethics and to report violations or suspected violations of any and all potentially, ethically, and/or legally questionable behavior or practices immediately. If any employee or representative reasonably believes that a policy, practice, or action of the institution or any of its representatives is in violation of any law, rule, or regulation or the Code of Ethics, they should promptly report the violation. 

 

Complaint Reporting 

It is the responsibility of management in coordination with the Compliance Officer to provide a written report to the Board of Directors regarding complaints that includes an overview of: 

  • The number of complaints the institution has received for the reporting period and a year-to-date total; 

  • The types of complaints; 

  • The source of complaints (e.g., in person, regulator);  

  • Any trends of a particular product, service, branch or personnel, as applicable; 

  • Any actual or potential regulatory violations; and  

  • A risk rating for each type of complaint. 

Reports shall be provided to the Board of Directors at least quarterly. If a complaint involves an alleged violation of unfair, deceptive, or abusive acts or practices (UDAAP); or legal action, or the complaint was received through the Zenus’s regulatory agencies, such complaint shall be reported at the next regularly scheduled board meeting or as may be otherwise appropriate. 

Details of a complaint shall include, at a minimum, the following: 

  • A description of the complaint; 

  • Results of the investigation; and 

  • Resolution and subsequent actions taken by Senior Management, the CRO, and/or the Compliance Officer. 

Senior Management shall maintain complaint information and provide such details to the Board, Senior Management and/or staff as appropriate. 

 

Enforcement and Oversight 

The Board of Directors has the authority to approve and enforce this Policy. Changes to this Policy require approval by the Institution’s Board of Directors. However, Senior Management is responsible for ensuring that the policy is implemented and administered in compliance with this Policy. 

 

Changes to any corresponding operating procedures may be approved by the appropriate senior manager, in conjunction with the Chief Compliance Officer as may be appropriate, over the impacted area. 

 

It is the responsibility of each employee and director to comply with this Policy and any applicable laws, rules, regulations, and, if appropriate, regulatory issued guidance. 

 

Audit and Monitoring 

Periodically, Zenus’ Compliance Officer shall audit the compliance of this Policy and report the results of such audit to the Board of Directors. 

 

Training 

Zenus Chief Compliance Officer and Senior Management will ensure appropriate training is given to new and existing employees. 

 

Record Retention 

The institution shall retain evidence of compliance with this Policy for a period of five years or until the completion of the next regulatory examination. Additionally, the institution shall retain evidence of compliance within accordance with the applicable regulations that may be impacted by such complaint. 

 

 

 

 

 

 

 

APPENDIX TO COMPLAINT POLICY 

The following Customer Complaint Policy and Procedures Notice will be Published on Zenus.com and referenced in Client Agreements. 

 

Inquires and complaints  

Our aim is to provide clients with products and services of the highest standards. We welcome feedback and ideas that can help us improve. Equally, we recognize that from time-to-time things may go wrong or there may be misunderstandings. We’re committed to dealing with inquires, requests and complaints positively and sympathetically. If we are at fault, we aim to put things right quickly.  

 

Questions, inquiries or requests 

 

If you have a question about our products and services, please take a look at our Support section in the first instance. It features a wealth of information about our services and step-by-step guides to resolving most issues and requests.  

 

Should you have a specific question about your application, account or transactions please contact our Client Services team. They will look into the matter as soon as they can and aim to resolve inquiries within one business day. Where further information is required, we will contact you within ten (10) business days advising you on what is needed   

 

Official Complaints  

 

If our Client Service team have not resolved your inquiry to your satisfaction, or if you wish to make a complaint, please email our Complaints Team at complaints@zenus.com. 

 

Once we have received your complaint, we will acknowledge its receipt by email. Your complaint will be handled by someone who is not directly involved in your original inquiry. We aim to resolve complaints within ten (10) business days. If our investigation is expected to take longer than this, we will notify you with status updates until we have resolved the case.  

 

To aid our investigations please provide as much information as possible in your submission. 

 

Office of the Commissioner of Financial Institutions 

Following the investigation of your complaint, if we have not provided a final response, or you are dissatisfied with our investigation and the outcome, you can refer it to the Office of the Commissioner of Financial Institutions (OCIF). The OCIF will act as an impartial adjudicator and review the complaint. You can find out more about their process on the OCIF website and contact them: 

 

 

In person: 
Office of the Commissioner of Financial Institutions  
Centro Europa Building-Suite 600  
1492 Ave. Ponce de León (opposite the Centro de Bellas Artes)  
San Juan Puerto Rico 00907  
 
By mail: 
Commissioner of Financial Institutions 
Attention: COMPLAINTS DIVISION  
Office of the Commissioner of Financial Institutions  
PO Box 11855  
San Juan PR 00910-3855  
 
By email:querellas@ocif.gobierno.pr  or querellas@ocif.pr.gov 

 

Or Phone: 

 
Phone: Metro Area (787) 723-8445  
Free of Charge (800) 981-7711  
Fax: (787) 723-4225

If not, please contact Client Services