In conducting its off-site supervision and on-site inspections, the WAMU Banking Commission ensures that regulated institutions comply with regulatory provisions pertaining to depositor protection, in accordance with the provisions of the Annex to the Agreement Governing the WAMU Banking Commission.
This supervision covers, inter alia, banking terms and conditions (the all-inclusive effective interest rate [TEG], usury rates, banking services provided free of charge, etc.), customer data privacy, complaint resolution mechanisms, and the right to a basic bank account.
With respect to complaints filed by customers of banking institutions, the Supervisory Authority issued Circular No. 002-2020/CB/C dated September 18, 2020, concerning complaint handling for customers of banking institutions under its supervision.
The core provisions of this Circular address the following :
- the formal definition of a "complaint" ;
- the requirement for regulated institutions to establish an internal framework for handling customer complaints, including procedures for processing and monitoring such grievances, subject to the approval of the governing body ;
- the obligation for regulated institutions to inform customers of the existence of this internal complaint handling system, notably by displaying such information on their premises, on their websites, and within contractual documents whenever a financial product or service is provided;
- the mandatory one-month deadline for regulated institutions to respond to customer complaints;
- the requirement for regulated institutions to submit a periodic report to the Banking Commission ; and
- the admissibility criteria for complaints. In this regard, the grievance submitted by the customer must not be currently under review by any judicial, extra-judicial, or administrative body, specifically including the mediation mechanisms established under the Financial Services Quality Observatories (OQSF).
