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Market Conduct (Supervision)

Market Conduct Resources

Market Conduct Supervision Framework

Circular Letters and Publications

Complaint Form

Surveys and Questionnaires

Guidelines

Legislation

Market Conduct (Supervision)

Market Conduct refers to the manner in which a financial institution designs its products and services and manages its relationship with clients and the public, including via the use of intermediaries (sales representatives or agents). In recent years, financial institutions have been encouraged to re-examine and strengthen their market conduct policies in order to protect the interest of consumers.

As part of its mandate to preserve financial stability, the Central Bank must assess the significant risks to institutions fulfilling their market conduct outcomes, prioritize actions that prevent risk from escalating, and consider early corrective measures to improve the customer experience. The objective of the Central Bank is thus to balance the interests and rights of the financial consumer with the need for financial institutions to innovate and develop.

Institutional Roles & Jurisdiction

Type and Scope of Complaints Addressed by the Office of the Financial Services Ombudsman and the Market Conduct Supervision Unit

At the Central Bank of Trinidad and Tobago, the Office of the Financial Services Ombudsman (“OFSO”) and the Market Conduct Supervision Unit serve different but connected roles.

Role and Function of the OFSO

Independent Dispute Resolution & Redress

The OFSO is an independent body established to provide a fair, impartial, and accessible mechanism for resolving disputes between consumers and financial service providers. Its core role is to investigate complaints brought by individuals or small businesses [1] against banks, insurance companies, and non-bank financial institutions. The OFSO functions primarily as a dispute resolution body, addressing complaints that have not been satisfactorily resolved by the institution’s internal complaint resolution process.

The OFSO focuses on individual complaints and seeks to facilitate fair outcomes for consumers through mediation and negotiation, encouraging both parties to reach mutually acceptable solutions. Where necessary, the OFSO may issue a recommendation based on principles of fairness and industry standards to help ensure accountability within the financial services sector. In addition, the OFSO has the authority to direct financial compensation to consumers where appropriate, a power not vested in the Market Conduct Supervision Unit.

[1] A small business is defined as one which possesses assets, excluding the value of land and buildings, up to a value TT$1,500,000.00 at the time of the matter that gave rise to the complaint.

Scope of Services – OFSO

The OFSO can consider complaints about a wide range of products and services offered by insurance companies, commercial banks, and nonbank financial institutions. Rather than itemizing these services here, readers are directed to the Office of the Financial Services Ombudsman’s official website, which provides the most up-to-date and comprehensive list of products, services, and exclusions.

Role and Function of the Market Conduct Supervision Unit

Regulatory Oversight & Market Integrity

The Market Conduct Supervision Unit is located within the Financial Institutions Supervision Department (FISD) of the Central Bank of Trinidad and Tobago. FISD is spearheaded by the Inspector of Financial Institutions.

In addition to mediating consumer complaints against financial institutions, the Market Conduct Supervision Unit (MCSU) is responsible for the supervision and regulation of financial institutions in order to inter alia, promote the existence of efficient and fair banking and insurance markets. The Unit plays a critical role in ensuring that regulated financial institutions treat customers fairly and operate with transparency and integrity. MCSU is responsible for processing conduct-related complaints against regulated institutions and entities across the regulated financial sectors.

Regulatory Mandate – MCSU

Functions at a broader systemic and institutional supervisory level to enforce statutory market conduct frameworks, eradicate unfair practices, oversee group plan complaints, and promote industry-wide consumer confidence.

Complaint Types: OFSO vs. Market Conduct Supervision Unit

The following table provides examples of the different types of complaints processed by the OFSO and the MCSU and their areas of focus using some specific examples: –

Type of Complaints

What the OFSO Does?

What the MCSU Does?

Individual Life and Annuity insurance product

What the OFSO Does?

Claim denials or delays in settlement
Inadequate settlement offer
Surrender value and policy benefits
Payment and calculation disputes

What the MCSU Does?

Non-disclosure/ Misrepresentation issues
Lack of post-sale communication
Product suitability
Premium increases or change in terms and conditions
Misleading advertising and promotional material

Policy/Contract issues – Individual policyholder

What the OFSO Does?

Dispute over policy interpretation
Claim denial due to policy exclusion and limitation
Inadequate settlement offer

What the MCSU Does?

Eligibility for insurance coverage
Cancellation of policy contract
Policy terms and conditions
Incorrect premiums
Unreasonable or unexpected fees and charges on policy
Inadequate disclosure and transparency – terms of contract unclear

Delayed settlement or denial of personal injury claim

What the OFSO Does?

N/A

What the MCSU Does?

Non-settlement or inadequate settlement of personal injury claim

Unsettled claims under Group Health Plans / Group Pension Plans

What the OFSO Does?

N/A

What the MCSU Does?

Cancellation/ Suspension of Health Plan
Non-settlement of medical claims under Group Health Plan
Inadequate or delayed settlement of claims under Group Health Plan

Foreign exchange issues / interest rate on investment policy

What the OFSO Does?

N/A

What the MCSU Does?

Complaints over lack of availability of foreign exchange
Lowered interest rate on insurance policy
Non-payment of accumulated interest on policy

Unsettled motor damage claims arising from accident

What the OFSO Does?

Third party property damage claims of $100,000.00 or less under a motor policy

What the MCSU Does?

Third party property damage claims under a motor policy in excess of $100,000.00

Fraud-related matters

What the OFSO Does?

Fraud matters involving individual life and annuity products
Unauthorized transactions
Phishing and social engineering scams

What the MCSU Does?

Unauthorized transactions
Phishing and social engineering scams
Cybersecurity issues
Dispute over liability and compensation
Electronic and online security failures

Source: Office of the Financial Services Ombudsman Insurance Services brochure, March 2026; Office of the Financial Services Ombudsman Banking Services brochure, March 2026; Market Conduct Supervision Framework.

Summary of Distinctive Jurisdictions

In summary, the key difference between the OFSO and MCSU lies in their approach and scope. The OFSO addresses individual complaints and provides remedies for redress, whereas the MCSU processes conduct-related issues as well as complaints arising from Group Life and Health Plans and policies. The MCSU functions at a broader regulatory level to prevent misconduct and promote proper industry practices. Through these efforts, each area contributes to strengthening consumer protection and enhancing confidence in the financial system.