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Customer protection regulations

MONEYGRAM INTERNATIONAL SA CUSTOMER PROTECTION REGULATIONS

TABLE OF CONTENTS

CHAPTER I GENERAL PROVISIONS

Article 1. Purpose

Article 2. Dissemination

Article 3. Approval and modification

CHAPTER II CUSTOMER SERVICE

Article 4. Scope of application

Article 5. Principles of action of the Customer Service Department

Article 6. Head of the Customer Service Department

Article 7. Appointment of the Head of the Customer Service Department

Article 8. Term of appointment, termination of office, grounds for incompatibility and ineligibility

Article 9. Internal organisation

CHAPTER III PROCEDURE FOR THE SUBMISSION, PROCESSING AND RESOLUTION OF COMPLAINTS AND CLAIMS

Article 10. Form, content, deadline and procedure for the submission of complaints and claims

Article 11. Admission for processing

Article 12. Processing

Article 13. Settlement and withdrawal

Article 14. Conclusion of the procedure

Article 15. Resolution and notification.

Article 16. Relationship with the Bank of Spain's Claims Service

CHAPTER IV DUTIES OF COOPERATION AND INFORMATION

Article 17. Duties of information

CHAPTER V ANNUAL REPORT

Article 18. Content.

ANNEX I

Location and Contact Details

CHAPTER I

GENERAL PROVISIONS

Article 1. Purpose

The purpose of these Regulations is to regulate the operation and internal regime of the Customer Service Department, as well as the procedures for handling and resolving complaints and claims submitted by users of the money transfer service provided by MoneyGram International Limited SA (hereinafter ‘MIS’) in relation to their legally recognised rights and interests.

For the purposes of these Regulations, complaints shall be considered to be those submitted by users of the money transfer service offered by MIS due to delays, negligence or any other type of deficient performance observed in the operation of the entity against which the complaint is made.

Likewise, claims shall be considered to be those submitted by users of the money transfer service offered by MIS that highlight, with the intention of obtaining restitution of their interest or right, specific facts relating to actions or omissions by the entity against which the complaint is made that represent a prejudice to the interests or rights of the person making the complaint and that derive from alleged breaches by the entity against which the complaint is made of the regulations on transparency and customer protection or of good financial practices and customs.

Article 2. Dissemination

The MIS Board of Directors shall take the necessary measures to ensure the dissemination of these Regulations among the Entity's departments.

Likewise, the Regulations shall be published on the MIS website for better distribution among its customers, agents and the general public.

Article 3. Approval and amendment

The MIS Board of Directors is responsible for approving these Regulations and any amendments thereto.

These Regulations, as well as any possible amendments thereto, shall be subject to verification by the Bank of Spain.

CHAPTER II

CUSTOMER SERVICE

Article 4. Scope of application

The MIS Customer Service Department is responsible for handling and resolving complaints and claims submitted, either directly or through a representative, to the department, as well as through other existing bodies established for this purpose, by individuals or legal entities, Spanish or foreign, who are users of the money transfer service provided by MIS, provided that such complaints and claims relate to their legally recognised interests and rights, whether arising from contracts, transparency and customer protection regulations or good financial practices and customs, in particular the principle of fairness.

Article 5. Principles of action of the Customer Service Department

1. The Customer Service Department shall be governed by the following principles:

- Fairness - Transparency and customer protection

- Good financial practices and customs

- Application of fair and equitable criteria in the assessment and resolution of complaints and claims submitted by customers.

- Ensuring that communications to customers are accurate and truthful.

2. The resolution of complaints and claims from users of the money transfer service provided by the entity, as well as the application of these principles, will enable the entity to understand the needs of end users, assume appropriate levels of service in terms of customer protection and ensure customer satisfaction.

Article 6. Head of Customer Service

1. The head of MIS Customer Service must be a person of commercial and professional integrity with adequate knowledge and experience to perform their duties.

2. Commercial and professional integrity is found in those who have a personal track record of compliance with commercial and other laws governing economic activity and business life, as well as good commercial and financial practices.

Those who have performed duties related to MIS's own activity have adequate knowledge and experience.

Article 7. Appointment of the Head of Customer Service

1. The Head of Customer Service shall be appointed by the MIS Board of Directors.

2. The appointment of the Head of Customer Service shall be communicated to the Bank of Spain, as the supervisory authority of MIS for the activity it carries out.

Article 8. Term of appointment, removal from office, grounds for incompatibility and ineligibility

1. The Head of Customer Service shall hold office for a term of two years and may be re-elected one or more times for periods of equal duration.

2. The head of the Customer Service Department shall cease to hold office for any of the following reasons: a) Expiry of the term for which he or she was appointed, unless his or her re-election is agreed. b) Resignation. c) Death or supervening incapacity. d) Termination of the employment relationship with MIS. e) For serious cause or justified reason, the Board of Directors of MIS may, in any case, agree to his or her dismissal.

3. The replacement or appointment of the new head of the Customer Service Department shall be the responsibility of the Board of Directors of MIS within a period not exceeding one month and shall also be communicated to the Bank of Spain, as the supervisory authority of MIS.

4. No person who is legally incompatible may hold the position of Head of Customer Service.

Article 9. Internal Organisation

1. The Customer Service Department performs its functions independently of the other commercial or operational departments of the Entity. This autonomy is justified in order to adequately protect the interests and rights expressly recognised by law and to avoid conflicts of interest.

2. MIS shall take the appropriate measures to ensure that the procedures established for the transmission of information required by the Customer Service Department to the rest of the organisation's departments comply with the principles of speed, security, efficiency and coordination.

3. The Customer Service Department shall be provided with the appropriate human, material, technical and organisational resources to carry out its functions. It shall also take the necessary steps to ensure that the Head of Customer Service has adequate knowledge of the regulations on transparency and protection of financial services customers.

CHAPTER III

PROCEDURE FOR THE SUBMISSION, PROCESSING AND RESOLUTION OF COMPLAINTS AND CLAIMS

Article 10. Form, content, deadline and submission of complaints and claims

1. Complaints and claims may be submitted in person or through a representative, on paper or by computer, electronic or telematic means, provided that these allow the documents to be read, printed and stored, through the channels specified in Annex I:

The use of computer, electronic or telematic means must comply with the legal requirements for electronic signatures.

2. The procedure shall be initiated by submitting a document stating:

- Name, surname(s) and address of the interested party and, where applicable, of the duly accredited person representing them; and NIF, NIE, passport or document from the country of residence and details referring to the public register for legal entities.

- The location, department or service where the events that are the subject of the complaint or claim took place.

- A description of the events that gave rise to the complaint or claim and a clear specification of the issues on which a ruling is sought.

- Express indication that the claimant is not aware that the matter that is the subject of the complaint or claim is being dealt with through administrative, arbitration or judicial proceedings.

- Place, date and signature of the user.

The claimant must provide, together with the above document, any documentary evidence in their possession that supports their complaint and claim.

3. The maximum period for submitting complaints and claims to Customer Service shall be two years from the date on which the user of the money transfer service became aware of the facts giving rise to the claim or complaint. Claims and complaints submitted after this period shall not be accepted.

Article 11. Admission for processing

1. Once the complaint or claim has been received by Customer Service, if it has not been resolved in favour of the claimant by the department that is the subject of the complaint or claim, the latter shall open a file, which shall be given the corresponding serial number.

The provisions of the preceding paragraph shall be understood without prejudice to the fact that the maximum period for completion shall begin to run from the date of submission of the complaint or claim to Customer Service, at its registered office or at its offices, if any, or via the email address provided for this purpose. Likewise, the time taken by any department of the entity to try to resolve the complaint or claim, once it has been made, shall be counted within the two-month period available to Customer Service to issue its decision.

In any case, written acknowledgement of receipt must be provided and the date of submission must be recorded for the purposes of calculating this period. The complaint or claim may only be submitted once by the interested party, and may not be repeated before different bodies of the entity.

2. If the identity of the claimant is not sufficiently proven, or if the facts that are the subject of the complaint or claim cannot be clearly established, the signatory will be required to complete the necessary documentation within ten calendar days, with the warning that if they fail to do so, the complaint or claim will be filed without further action. Once the claim has been filed due to the interested party's failure to complete the required documentation, the interested party may do so in the future, giving rise to the opening of a new file.

The period taken by the claimant to correct the errors referred to in the previous paragraph shall not be included in the calculation of the two-month period provided for in Article 14(1).

3. Complaints and claims may only be rejected and filed away in the following cases:

a) When essential information for processing is omitted and cannot be corrected, including cases where the reason for the complaint or claim is not specified.

b) When attempts are made to process as a complaint or claim, appeals or actions that fall within the jurisdiction of administrative, arbitration or judicial bodies, or when the matter is pending resolution or litigation or has already been resolved in those instances.

c) When the facts, reasons and request on which the issues that are the subject of the complaint or claim are based do not refer to specific transactions or do not comply with the requirements set out in Article 4 of these Regulations.

d) When complaints or claims are made that repeat previous ones that have already been resolved, submitted by the same user of the money transfer service offered by MIS in relation to the same facts.

e) When the deadline for submitting complaints and claims established in these Regulations has passed.

When it becomes known that a complaint or claim is being processed simultaneously with an administrative, arbitration or judicial proceeding on the same matter, the former shall not be processed.

4. When the complaint or claim is deemed inadmissible for any of the reasons indicated, this shall be communicated to the interested party by means of a reasoned decision, giving them a period of 10 calendar days to submit their arguments. When the interested party has responded and the grounds for inadmissibility remain, they shall be notified of the final decision taken.

Article 12. Processing

1. During the processing of the complaint, the Customer Service Department may request from both the complainant and the various departments concerned any information, clarifications, reports or evidence it considers relevant to its decision.

2. The departments have a duty to provide the Customer Service Department as quickly as possible with any information it requests in relation to the performance of its duties.

Article 13. Settlement and withdrawal

1. If, in view of the complaint or claim, the entity rectifies its situation with the complainant to the latter's satisfaction, it must notify the Customer Service Department and provide documentary evidence of this, unless the interested party expressly withdraws the complaint or claim. In such cases, the complaint or claim shall be filed without further action.

2. Interested parties may withdraw their complaints and claims at any time, resulting in the immediate termination of the procedure.

Article 14. Conclusion of the procedure

1. The case shall be concluded within a maximum period of two months from the date on which the complaint or claim was submitted to Customer Service or at its registered office or offices, if any, or via the email address provided for this purpose.

2. The complaint procedure before Customer Service shall be deemed to have been concluded by means of a reasoned decision, withdrawal by the interested parties, settlement or dismissal of the complaint for the reasons indicated in Article 11.

Article 15. Decision and notification.

1. The decision shall always be reasoned and shall contain clear conclusions on the request made in each complaint or claim, based on the contractual clauses, the rules of transparency and customer protection, as well as good financial practices and customs.

In the event that the decision deviates from the criteria expressed in similar previous cases, the reasons justifying this must be provided.

2. The decision shall be notified to the interested parties within 10 calendar days of its date, in writing or by computer, electronic or telematic means, provided that these allow the documents to be read, printed and stored, and comply with the requirements of Law 59/2003 of 19 December on electronic signatures, as expressly designated by the claimant and, in the absence of such indication, through the same means by which the complaint or claim was submitted. Similarly, the interested party shall be informed when the complaint or claim is deemed inadmissible for any of the reasons mentioned in Article 11.

3. The decision shall expressly inform the claimant of their right to refer the matter to the Bank of Spain's Complaints Service if they disagree with the decision taken by the Customer Service Department or if no decision has been taken by the latter within two months, it being essential to first exhaust the Customer Service Department's channels.

Article 16. Relationship with the Bank of Spain Complaints Service The Customer Service Department shall comply with any requests made by the Bank of Spain Complaints Service in the exercise of its functions, within the time limits determined by the latter in accordance with its Regulations.

CHAPTER IV

DUTIES OF COOPERATION AND INFORMATION

Article 17. Duties of information

MIS shall make the following information available to users of the money transfer service offered by MIS on its website and at its registered office or offices, if any:

a. The existence of a Customer Service Department, indicating its postal and email addresses.

b. The obligation on the part of the entity to deal with and resolve complaints and claims submitted by its customers within two months of their submission to the Customer Service Department, at its registered office or offices, if any, or via the email address provided for this purpose.

c. Reference to the Bank of Spain's Claims Service, specifying its postal and email addresses, and the need to exhaust the customer service department or service before submitting complaints and claims to it.

d. The regulations for customer protection.

e. References to the regulations on transparency and protection of financial services customers.

CHAPTER V

ANNUAL REPORT

Article 18. Content.

Within the first quarter of each year, the Customer Service Department shall submit to the Director General of Spain an explanatory report on the performance of its duties during the previous financial year, which shall contain at least the following:

a. a statistical summary of the complaints and claims handled, with information on their number, admission for processing and reasons for non-admission, grounds and issues raised in the complaints and claims, and amounts involved,

b. a summary of the decisions issued, indicating whether they were favourable or unfavourable to the claimant,

c. general criteria contained in the decisions,

d. recommendations or suggestions derived from their experience, with a view to better achieving the aims that inform their actions.

At least a summary of the report shall be included in the entity's annual report.

Annex I

LOCATION AND CONTACT

In accordance with Article 10 of the Regulations, complaints and claims may be submitted in person or through a representative, on paper or by electronic or telematic means, provided that these allow the documents to be read, printed and filed, through the following channels:

1. Freephone number - 900 900 383.

2. Email - customerservice@moneygram.com

3. Letter addressed to the Customer Service Department of MONEYGRAM INTERNATIONAL SA, Plaza Carlos Trías Bertrán, nº 4, 28020 – Madrid, Office 3-4 c/o Ibercenter, Spain

4. Online form - fill in the online form at www.moneygram.com.

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