Falcon Internal Consumer Complaint Handling Process

Introduction

The Falcon Risk Services (Falcon) Consumer Complaints Manual is to be used to assist in the following manner:

  1. Resolution of complaints
  2. Ensuring clear and accurate responses to consumers, their designated representatives, and regulators
  3. Analysis of complaint data in order to identify trends and problems.
  4. Compliance with NAIC mandates and regulations dealing with handling processes and procedures.

This manual contains information to help position Falcon to better serve its customers, regulators, and other interested parties.

Falcon will respond to inquiries fairly, promptly, courteously, and informatively. Falcon will initiate corrective action in our operations, where needed, to improve the quality of service. Individual states and other organizations have their own timelines and will provide the response date. The response must be provided within this period. If this timeframe cannot be met, please follow the extension request instructions detailed further in the report.

As part of the complaints handling procedures, Falcon will administer the process through business units that are responsible for gathering appropriate documentation to respond accordingly. The Falcon compliance department, melissa.rinard@falconriskservices.com  will help all business units with any problems or questions regarding consumer complaints. Please contact the Compliance Officer, melissa.rinard@falconriskservices.com or designee when problems or questions arise.

Complaints Procedure

Once a complaint has been received by any Falcon team member:

  1. Forward complaint to Chief Operating Officer and VP of Operations (CCO/VP)
  2. COO/VP will log the complaint in the Complaint Log on Monday.com completing all fields available based on provided information and attaching any relevant documentation.
  3. COO/VP of Operations will immediately notify Falcon Executive Leadership Team
  4. Notification to the appropriate HDI personnel will also be made as soon as practicable after receiving the complaint to ensure that response timeframes are met.
  1. HDI Global Insurance Company: 
    Legal Department
    complaints@us.hdi.global
  2. HDI Global Specialty SE:
    Complaints
    complaints@hdi-specialty.com
    George Toulkeridis
    georgios.toulkeridis@hdi-specialty.com;
    Arne Seja
    Arne.Seja@hdi-specialty.com

Corporate Policy

It is the corporate policy of Falcon that all complaints be reviewed and responded to within the time specified in the complaint. If a response will not be possible by the due date, the state Department of Insurance contact or other complainer representative must be contacted, and an extension must be requested no later than 48 hours prior to the initial due date of the complaint response. Procedures for requesting an extension are detailed below.

Complaint definitions

COMPLAINT: 

A complaint is any communication from a consumer, a state insurance department, or another party on behalf of an individual, corporation, or interested third party, for the primary purpose of expressing a grievance or dissatisfaction with the products, services, or operations, including the handling of claims, or policies offered by Falcon.

Complaints received from state insurance departments may be sent to the insurance carrier partner or to Falcon directly. The insurance carrier partner will make a determination on who will handle and respond to the complaint. The response is handled as noted in this policy.

Draft responses for complaints which were initially sent to the insurance carrier partner must be sent to the carrier partner for review and approval prior to submission. The insurance carrier partner will notify Falcon who is responsible for the submission of complaint response and any associated documents.

A complaint does not include routine bureau or state insurance department inquiries, nor is an inquiry considered a complaint.

An inquiry is any communication from an individual, corporation, or interested third party for the primary purpose of requesting information.

Complaint Signature Requirements

State insurance departments require that the signature area of complaint responses include the same name of the appropriate underwriting company, along with the corresponding NAIC number.

Preparing the Response

All responses will be drafted by the CCO/VP or their designee and hold the responsibility for submitting the response to the relevant party. Complaints directed to the insurance carrier partner will be referred to the partner for final approval prior to submission.

The response to any complaint is to be used to provide explanations for our actions or to clear any misunderstanding, however the response should not be used as a vehicle to justify prior actions and/or decisions, in particular when we are maintaining our position.

All responses to complaints received from the Department of Insurance (DOI) should be made directly to the DOI and appropriately addressed to the relevant examiner unless instructed otherwise by the DOI examiner. The DOI examiner will communicate directly with the complainant regarding the outcome.

In situations where a response to the complainant is required, such as for complaints filed in California, the Department of Insurance examiner must also be copied.

All complaint responses must be placed on Company letterhead with the applicable insuring company name used in the caption of the response. Include the DOI or other body, such as the Better Business Bureau (BBB), file number on all correspondence. The response letter must always include the name and telephone number of a contact for further questions.

Requesting an Extension of Time for a Complaint Response

While all efforts must be made to respond to a complaint in the time allocated, there will be situations where an extension may be required.

All requests for an extension to respond to a complaint must be in writing to the DOI examiner at least 48 hours prior to the due date of the response. The request for an extension must include the status o f  our response and a detailed reason why an extension is required. We cannot request an extension after the due date has passed.

Please note: not all states will or can allow an extension. For example, California statutes do not allow for an extension of time unless the delay was as a result of a state or a complainant error.

Maintenance of Complaint Files

A complaint file consists of the original notification expressing dissatisfaction or the telephone notes if applicable, the response, and any additional correspondence pertaining to the complaint.

The COO/VP or their designee will maintain all original complaint files. Copies may be maintained in hard or soft copy format. Hardcopies of files will be kept for a period of one year, after which all copies will be scanned for electronic storage and hardcopies will be securely destroyed. Electronic records will be maintained in accordance with the Falcon document retention and information security policies.

Information provided to our customers via Falcon Risk Services Website at www.FalconRiskServices.com:

How to complain - our commitment to you

In line with HDI Global Specialty SE, at Falcon Risk Services, each of our customers is important to us, and we believe you have the right to fair, swift, and courteous service at all times. If you are dissatisfied with the service, you have received and wish to make a complaint, please contact us by email:

compliance@falconriskservices.com

HDI Global Specialty SE and Falcon Risk Services Complaints Procedure

We will acknowledge your complaint in writing within five working days of receipt and promptly work with you to resolve the matter.

Falcon Risk Services
Attn: Compliance Division
225 Liberty St
36th Floor
New York, NY 10281
compliance@falconriskservices.com

HDI Global Insurance Company
Attn: Legal Department
161 North Clark Street
48th Floor
Chicago, IL 60601
complaints@us.hdi.global

HDI Global Specialty SE
HDI-Platz 1
30659 Hannover / Germany
complaints@hdi-specialty.com