Complaint Procedures

Real Transfer – Complaints Procedure
Real Transfer Limited is regulated by the ‘Banque Nationale de Belgique’ under the Payment Services Regulations 2017 for the provision of payment services as agent of Jubilee Services SA (provision under the of Article 28 Directive 2015/2366 ) . For simplicity we will refer to ourselves and our offices as “Real Transfers” or “we/our/us”.
Real Transfer is subject to the complaint handling rules. It is Real Transfer’s policy to comply with
these requirements in full including that relating to maintenance of complaint records.

While Real Transfer takes all reasonable steps to ensure that all client experiences
are positive, it accepts that inevitably there will be occasions when they are not. It therefore
intends that, where a client wishes to raise a complaint, his frustration is not compounded by
a dysfunctional complaint handling process.

Therefore, it is the responsibility of the board to ensure that:
It is easy for the client to make a complaint , the directions to relevant guidance are
prominent on the Real Transfer website, https://realtransfer.ie/complaint-procedures/
On receipt the complaint is handled promptly, politely and fairly via email to:
compliance@realtransfer.ie
Every effort is made to understand and resolve the client’s concern without redress to
European Dispute Resolution at

https://ec.europa.eu/consumers/odr/main/index.cfm?event=main.home2.show&lng=EN

Real Transfer’s actions are properly documented to demonstrate that it has acted fairly
through the course of the complaint.

Complaints Handling:
Acknowledgement
A complaint can be delivered in person, by telephone, by email, in writing or verbally. Upon
receipt of a complaint, the compliance Officer shall respond promptly to the client
acknowledging receipt of the complaint.
Initial Response
The Compliance Officer will check the client’s concern against Real Transfer’s systems and
records. If the complaint relates to a delay in a transaction, the Compliance Officer will
immediately check its status and inform the client, identifying any remedial action (and
redress) as appropriate.

Holding Response
If, for whatever reason, Real Transfer is unable to conclude the investigation and
provide a Final Response to the complainant within 15 business days of the complaint first
being received, then the Company will issue a Holding Response. The purpose of this
Holding Response is to inform the complainant.
why Real Transfer cannot provide a Final Response
what Real Transfer is doing to progress the complaint; and
when Real Transfer will provide an indication of what is happening with it.

Final Response
As soon as Real Transfer has completed its investigation, it will write to the
complainant and offer a summary outcome, including any remedial action as necessary.

Where appropriate, it may also include a final offer of redress. Such letters must be marked
clearly as the final response and will include details on how to contact the Compliance
Officer. The Final Response must also state the complainant’s option to refer the complaint to
the European Dispute Resolution if (s)he considers that it has not been resolved satisfactorily or
that the offer of redress is insufficient. For corporate clients an appropriate arbitrator will be
recommended to resolve the issue.

Where a holding response has been sent, and Real Transfer has not been able to
conclude its investigations within 15 business days of the complaint being first received, it
will send its final response within 35 business days of the complaint first being received. In
all other cases Real Transfer will send its final response within 15 business day of
the complaint first being received according to the Regulation 101 of the PSD2 (Payment
Service Directive).

Ultimate Redress
If, after contacting all parties, the complainant remains dissatisfied with the outcome of the
complaint then (s)he may seek redress through the European Dispute Resolution and ultimately the courts if (s)he so wishes.

Version 2.0 18.10.2023