Lloyd’s complaints: map responsibility while a single-stage process is proposed

A complaint can reach a broker, a coverholder and a delegated claims administrator before the managing agent has a complete account of what went wrong. Each team may be doing its own job, yet the customer can still be left unsure who is dealing with the complaint. Removing a stage from the formal process will only help if the hand-offs behind it are clear.

The FCA’s CP26/32 provides a reason to examine those hand-offs now. Chapter 6 proposes amending DISP 1.11.8G to enable Lloyd’s to move to a single-stage complaints process. The consultation is open as at 1 October 2026, with responses due by 12 October. That is a consultation deadline, not an implementation date.

This article focuses on UK complaints within Lloyd’s procedures, especially where managing agents use coverholders or delegated claims administrators. Check the relevant policy, complainant eligibility and contractual role before applying the exercise. Lloyd’s Europe and overseas arrangements need their own assessment.

What would change, and what would remain?

Under the model described in the consultation, managing agents would handle complaints without a routine second-stage review by Lloyd’s. Lloyd’s would retain powers to intervene, including requiring redress where appropriate. It would also retain responsibility for engagement with the Financial Ombudsman Service and intends to review complaints escalated there. The paper retains an eight-week final-response timeframe.

Those proposals should be read alongside the current position. DISP 1.11 still describes a two-tier procedure, and Lloyd’s March 2024 Code sets out the existing UK stages. Eligible complaints can reach the Ombudsman after the Lloyd’s procedure finishes or after eight weeks from receipt, whichever comes first. Firms should continue to follow the applicable current arrangements while monitoring the consultation outcome and Lloyd’s implementation instructions.

For preparation, the useful question is whether the managing agent can reach and explain a sound decision using information held across the chain. More investigation time would not, by itself, provide access to a missing call recording or resolve uncertainty about who can approve redress.

Start with the authority, then name the owner

Take one material UK arrangement and place its complaints clause, delegated authority, handling instructions and customer communications together. Identify the legal entities involved, rather than relying on trading names. For each participant, record whether it can receive a complaint, investigate it, agree an outcome or issue a response. These are different permissions.

Lloyd’s Code requires the managing agent to ensure suitable arrangements where a coverholder is involved. It also recognises a UK coverholder’s own obligations for complaints about its actions. A future process therefore needs more thought than replacing “Lloyd’s” with the managing agent’s name in a template.

Use a named role and a deputy for each task. “Claims team” is too broad if nobody can say who will obtain evidence, resolve a disputed allocation or authorise a response when the usual handler is absent. Record the document that supports each allocation. If authority is unclear, treat that as an issue to resolve with the relevant firm, not an assumption to build into a procedure.

Make the hand-offs testable

Our suggested ownership map follows six tasks. It is a practical RRCA review tool, not a prescribed regulatory format.

• Receipt and routing: identify every likely entry point, the person who records first receipt and the receiving contact. Check that the acknowledgement of an internal hand-off can be evidenced.

• Scope and allocation: identify who decides which entity and procedure apply, including a complaint that concerns more than one firm. Record how disagreements are escalated while the customer continues to receive updates.

• Investigation: name the person who requests evidence from the broker, coverholder or claims administrator, and the person who chases missing material. Set an internal escalation point early enough to act.

• Decision and response: identify who assesses the outcome, approves any remedy and checks the response. Match the signatory and wording to the authority actually held.

• Referral and oversight: identify who assembles the complete case file and manages requests from Lloyd’s. Keep the proposed continuing Lloyd’s role visible in the future map.

• Remedy and learning: identify who carries out the agreed remedy, checks completion and follows up a recurring cause. Closing the complaint record should not hide an unfinished payment or correction.

Beside each task, write the trigger, internal target, evidence of completion and escalation contact. Keep two columns or versions: the process operating today and a clearly labelled future design. That makes it harder for a preparatory change to slip into live customer communications unnoticed.

Try one complaint all the way through

Consider a hypothetical UK policyholder who complains to a coverholder about a delayed claim. A delegated claims administrator holds the chronology and call recordings. The managing agent must understand both the delay and the customer’s account before the complaint can be assessed properly.

Ask the participants to walk the case through their current process. Can they show when the complaint arrived, where it was recorded, who accepted the investigation and how the relevant records would reach the decision-maker? Then test the future design, expressly assuming that the proposed change has been adopted and the relevant implementation requirements have been met.

Suppose the claims administrator supplies its file on time, but neither the coverholder nor the managing agent has agreed who obtains a disputed telephone recording. The problem is a missing allocation. Record an owner, access route and escalation point, then repeat that part of the exercise. A new policy paragraph alone would not demonstrate that the gap had closed.

Add one complication: the complaint also alleges that the coverholder misdescribed the cover. Check whether this creates a separate complaint about the intermediary’s own conduct, who decides that question and how the customer receives a coherent explanation. Do not assume that every issue can simply be passed to the managing agent.

Turn the map into a controlled change decision

The companion six-page readiness toolkit includes a process overview, role implications, a seven-step readiness exercise, an ownership and hand-off map, and a worked example. It is an RRCA working aid, not a regulatory form or a substitute for checking the arrangements that apply to your firm. Start with one arrangement and use the findings to decide whether other arrangements need review. A successful example shows that the tested route worked; it does not establish that every complaint will follow it.

Separate repairs needed in today’s process from changes that depend on the proposal becoming effective. Missing contacts or uncertain evidence access can be addressed under existing arrangements. A new escalation route, revised customer notice or changed final-response authority needs the relevant legal, Lloyd’s and contractual position to be confirmed before use.

If the exercise reveals an unresolved point in the proposed model, consider explaining it in a consultation response by 12 October. A specific account of the hand-off, the affected customer and the clarification needed is more useful than a general preference for fewer stages.

RR Compliance Associates provides complaints-handling reviews as part of its compliance support. If the map exposes an unclear allocation or a process that works differently from the written instructions, we can discuss a focused review of the arrangement and the changes needed.

Download the free six-page toolkit for a process overview, role implications, readiness actions, an ownership map and a worked example.