How to file a complaint

The possible ways to file a complaint are:

sending an e-mail to reclami@illimity.com, or a certified e-mail certified e-mail to: illimity@pec.illimity.com

sending a letter either by ordinary mail or a registered letter with advice of delivery at: at Via Soperga, 9 − 20124 Milano (MI) – Complaints Office.

Generally, a complaint must contain:

Customer identification data (i.e. if the customer is a natural person: name, surname, date and place of birth, tax code, address; if the customer is a legal entity: company name, VAT number/tax code, registered office);

Telephone number, email address or certified email address in order to allow the Bank to contact the Customer;

A clear description of the reasons of the complaint alongside with a reference to the product/service to which the complaint refers;

Any documentation deemed useful to support the claim.

The contents described above are essential for the Bank’s Complaints Office to guarantee that every claim is handled correctly:

In the event the matter in question can be traced back to the ordinary management of relations between the Bank and the Customer, which can be resolved through an effective and prompt intervention of the credit institution, the request will not be qualified as a complaint.

By way of example, the following demands will not be considered a complaint:

Requests/reminders for sending documentation relating to banking relations;

Requests/reminders for the management of banking relations;

Requests/reminders to obtain information or clarifications on the banking relations being signed and/or already signed between the parties (e.g. information/clarifications on banking contracts, information/clarifications on the conditions of banking contracts, information/clarifications on the accounting movements of banking contracts, information/clarifications on the methods of extinction of banking contracts, information/clarifications on the operational use and/or conditions of banking relationships and of any related accessory instrument/product, such as: debit cards, credit cards, home banking and similar requests to those shown here);

Requests/reminders for the review of conditions relating to banking relationships;

Requests/reminders to support the use of subscribed banking products/services.

In the cases listed above and in similar instances, the Customer Care channels of the Bank are at complete disposal of the Customer. More information can be found on www.illimitybank.com.

Response time

The Bank must respond:

within 60 days to complaints related to banking and financial operations and services.

within 45 days to complaints related to the distribution of insurance products. In the event that the complaint concerns the behavior of the insurance company, the Complaints Office transmits the communication to the insurance company and simultaneously informs the costumer.

within 15 working days to complaints related to payment services as referred to in Directive 2015/2366/EU (PSD2), such as, for example, wire transfers, charges on debit cards and credit cards. Should the Bank, in exceptional circumstances, not being able to respond within the expected 15 working days, a response to the customer will be sent indicating the reasons for the delay in the response times and specifying the term within which the customer will obtain a definitive answer. In any case, the deadline for receiving the final answer shall not exceed 35 working days.

In the event the complaint is found to be well-founded, the Bank notifies the customer in writing, specifying the technical times that will be needed to resolve the reported problem. On the other hand, if the Bank deems the complaint unfounded, the reasons for the non-acceptance will be explained to the customer in writing, alongside with indication of the other possibilities for resolving the dispute.

Modalities for alternative dispute resolution relating to: Disputes on banking, financial and payment services

Under the current legislation, in the event a customer who has filed a complaint on banking, financial or payment services is not satisfied with the response given by the Bank or if they did not get a feedback within the statutory period provided for the different kind of complaints (i.e. 60 days for complaints on banking and financial services and 15 working days for complaints related to payment services), they are entitled to address:

The Banking and Financial Ombudsman (ABF). For further information on how to contact the Banking and Financial Ombudsman and on the scope of its activity, customers may visit the website www.arbitrobancariofinanziario.it or ask for information to the branches of the Bank of Italy;

The Banking and Financial Conciliator – non-profit association specialized in dealing with banking, financial and corporate disputes – ADR, registered with the Ministry of Justice under no. 3. The rules of the Banking and Financial Conciliator are available on the website https://conciliatorebancario.it and they can be requested to the Bank;

Other mediation bodies registered with the Ministry of Justice (the list is available on the website https://www.giustizia.it/giustizia).

Modalities for alternative dispute resolution relating to: Disputes on investment services and activities

In the event a customer who has filed a complaint on investment services and activities is not satisfied with the response given by the Bank or if they did not get a feedback within the statutory period provided for the this kind of complaint (i.e. 60 days), they are entitled to address:

The Arbitrator for Financial Disputes, with regard to disputes on the Bank’s observance of the obligation of information, fairness and transparency in contractual relations with the investors. The right to appeal to the ACF cannot be waived, even as a result of clauses, contained in the contracts, of devolution of disputes to other out-of-court resolution bodies. More information on the Arbitrator for Financial Disputes (ACF) is available on the website https://www.acf.consob.it;

Other mediation bodies registered with the Ministry of Justice (the list is available on the website https://www.giustizia.it/giustizia).

Modalities for alternative dispute resolution relating to: Disputes on distribution of insurance products

In the event a customer who has filed a complaint related to insurance distribution activities is not satisfied with the response given by the Bank or if they did not get a feedback within the statutory period provided for the this kind of complaint (i.e. 45 days), they are entitled to address:

IVASS – Insurance Supervisory Authority. More information on how to file a complaint before IVASS and on the required paperwork is available on the website https://www.ivass.it;

Other mediation bodies registered with the Ministry of Justice (the list is available on the website https://www.giustizia.it/giustizia).

If the complaint is related either to behaviors of the insurance company or to specific features of the products offered by the insurance company itself, the Bank will promptly forward the complaint to the company so that the latter can process the request within the statutory period. If this is the case, the Bank will give prompt notice to the customer.

On the Transparency section of illimity’s website the following guidelines are available:

ABF: ABF in the simplest terms and Guidelines on how to use the ABF’s portal;

Banking and Financial Conciliator: Regulation of the Banking and Financial Conciliator – Arbitration/Mediation;

ACF: ACF’s regulation and operative instructions on how to initiate proceedings before the ACF;

IVASS: IVASS’ guidelines on complaints

Defaults

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Decision