Internal rules and procedures for registering and considering complaints received from borrowers of “Finance Info Assistance” EAD, UIC 208538540
These rules and procedures of “Finance Info Assistance” EAD have been adopted in compliance with the requirements of Art. 8, para. 11, item 8 of the Law on Credit Servicers and Credit Purchasers (LCLCP) and Art. 41 of the same law and in accordance with the requirements of Regulation No. 49 of the Bulgarian National Bank. According to them, the Company provides a free and transparent mechanism for submitting and considering complaints from borrowers, by publishing information about the procedure on its website www.infoassistance.eu and in a prominent place in its offices. These internal rules and procedures govern definitions, rights and obligations of the parties, specific channels for filing complaints, requirements for their content, procedure and deadlines for confirmation of receipt, consideration and written response, as well as rules for documentation, traceability and accountability.
Definitions
Complaint – a written or oral dissatisfaction, complaint, signal or objection expressed by a borrower (debtor) or his representative, related to the activities of the person servicing the loan. This includes complaints regarding the accuracy or amount of the obligation, the method of communication and treatment by the company, the correctness of the data submitted to the Central Credit Register (CCR), the processing of personal data in accordance with Regulation (EU) 2016/679 (GDPR), the statute of limitations, the non-payment of the obligation and other issues related to the servicing and collection of receivables.
Borrower (obligor) – a natural or legal person who is obliged to repay a loan receivable transferred to the servicing company.
The company – “Finance Info Assistance” EAD, which carries out the activity of servicing receivables on non-performing loans.
Borrower representative – a person authorized by legal grounds (power of attorney, decision, legal representative authority) to file complaints and act on behalf of the borrower.
Channels for submitting complaints
Borrowers can submit complaints to “Finance Info Assistance” EAD through one of the following channels:
- In writing by post or courier: to the official address of the company’s management – Sofia, 8 Vrabcha Str.8
- By e-mail: to the company’s official correspondence e-mail office@infoassistance.eu
- In person at the company’s office: during the announced working hours, the applicant can submit his complaint orally or in writing on site. Oral complaints received in person are immediately documented by an employee of the company (a report is drawn up or a special internal form is filled out).
- By means of communication (informing): By telephone or other similar method, an employee of the company may inform the borrower of the possibility of filing a complaint through the above channels; the request is documented as a complaint if it is explicitly filed.
Requirements for the content of the complaint
For expedited and complete consideration, applicants are encouraged to provide the following information in the complaint:
- Complete details of the complainant: names and personal identification number (PIN/LNF) (or other official identifier).
- Contact details: correspondence address, telephone number and e-mail.
- Contract number or client code: if available, to facilitate case identification.
- Case description: a brief and accurate description of the problem and the complainant’s request (for example: request for correction of an obligation, correction of data in the CCR, complaint about the attitude of an employee, etc.).
- Attached documents: copies of relevant correspondence, contracts, payment orders, court decisions or other documents supporting the justification.
- Representation: if the complaint is filed by a proxy or guardian, the relevant power of attorney or court decision certifying his/her authority must be attached.
When submitting a complaint via electronic form or by email, the text of the complaint is considered equivalent to a written form, as long as it is signed with a qualified electronic signature or contains identifying data allowing for proper identification of the applicant.
Registration and confirmation of receipt
Each received signal or complaint is immediately registered in the Complaints Register and assigned an incoming number. Immediately after the registration of the complaint, a written confirmation (by email and/or by mail) is sent to the complainant. The confirmation contains: date of receipt, registration (incoming) number of the complaint and contact information for the employee responsible for its consideration. If the received complaint is incomplete or lacks clarifying data, the company notifies the applicant and sets a deadline for completion, with the deadline for response starting from the date of receipt of the supplement.
Review of the complaint and response deadlines
The company reviews complaints within a reasonable period of one month (with the possibility of extension in case of complexity), without unnecessary delay. In this regard, “Finance Info Assistance” EAD follows the following indicative deadlines:
- Complaints regarding information in the Central Registration and Registration Center: Decision and written response within 10 working days of receipt (in accordance with Regulation No. 22 of the Bulgarian National Bank).
- Complaints under the GDPR: Response within 1 month of receipt, with the possibility of extension (within another 2 weeks), in which case the complainant is promptly notified of the extension.
- Complaints related to enforcement or judicial proceedings: Within 15 working days of receipt; if additional verification is necessary, it may be reasonably extended, and the complainant is informed of the situation.
- Other complaints and inquiries: They are responded to within 30 days of receipt, depending on the complexity of the case and the need to collect additional documents or legal opinions.
If it is necessary to extend the consideration period for objective reasons, the Company shall notify the complainant of the reason and the new expected period. All response periods shall run from the date of the incoming complaint number, unless additional information is requested thereafter – in which case the period shall be suspended until the requested data is received.
Response and feedback
After completing the investigation of the complaint, the Company prepares a written response to the case. The response is sent to the address or e-mail specified by the complainant, or both channels simultaneously – sending via any specified channel is considered proper notification. The response is signed by an authorized person of Finance Info Assistance EAD and contains the specific conclusions and decisions regarding the complainant’s request. If the complaint is upheld, the response includes a description of the corrective actions taken (for example: amendment of an obligation, correction of data, etc.). If the complaint is left unsatisfied, the respondent describes the reasons for refusal and indicates the legal grounds or evidence for the refusal. If additional discussion is necessary, the Company may offer a meeting or other means of communication with the complainant.
Finance Info Assistance EAD does not charge fees or other expenses to complainants for filing and considering a complaint. The procedure is free of charge, as required by the Act on the Protection of Personal Data.
Action as a result of the inspection
Based on the results of the inspection, the Company:
- takes the necessary actions to correct data or eliminate an error if the complaint is justified;
- explains its reasons when the complaint is disregarded;
- may propose an appropriate solution (e.g. additional information, review of certain parameters, scheduling a meeting, etc.).
Documentation, register and reporting
The Company maintains an internal register of all complaints received and the measures taken on them. The entries in the register include the date of receipt, data of the complainant, subject of the complaint, incoming number, competent unit/person for consideration, actions taken and date of issuing a response. All related documents (complaints, correspondence, internal files) are archived. According to Art. 20 of the LCACC, the Company stores all correspondence and other documents related to borrowers, including recordings of telephone conversations (if carried out in accordance with the requirements of the legislation). These documents are kept for a period of at least 5 years from the date of their compilation or from the conclusion of the relevant debt servicing agreement. Upon request, the company provides information on complaints to the Bulgarian National Bank and the Consumer Protection Commission.
The legality of the procedures and compliance with the deadlines are subject to periodic internal control. The Executive Director or an official authorized by them are responsible for ensuring accountability and archival reliability, as well as for training employees on the requirements of this procedure. Copies of all decisions and responses to complaints are stored in the company’s archive for control and tracking.
Additional options and rights of borrowers
Borrowers do not lose the right to seek other mechanisms for protecting their interests. In case of disagreement with the response or the behavior of the company, they may contact the competent authorities: Consumer Protection Commission (CPC) – for violations of consumer rights; Bulgarian National Bank (BNB) – as a supervisory authority under the Anti-Money Laundering and Counterfeiting Act; Personal Data Protection Commission (PDPC) – in case of problems with the processing of personal data. If they wish to resolve the dispute out of court, they may request the formation of a conciliation commission at the PDPC (or other recognized ADR), or apply to the courts under the general procedure. The borrower may also exercise their right to file a complaint or signal electronically to the PDPC through its official form, by e-mail: info@kzp.bg or in writing to the address: 1000 Sofia, Vazrazhdane Square No. 7.
Final provisions
These internal rules and procedures were adopted by Order dated 27.11.2025 of the Executive Director of Finance Info Assistance EAD and shall enter into force immediately.
These internal rules and procedures are subject to an annual review for regulatory compliance and, if necessary, are amended in accordance with changes in the regulatory framework or case law.
Every employee of the company, having contact with borrowers or handling complaints, is familiar with their provisions and is obliged to comply with good practices and ethical standards in their implementation.
CEO:
Dimitar Mihaylov