Complaint against an investment firm before the CNMV (Spanish securities market regulator)

Complaint against an investment firm before the CNMV (Spanish securities market regulator) is filed with Comisión Nacional del Mercado de Valores (CNMV). With Managora you do it 100% online: you answer a few questions, sign a digital mandato (power of representation) and we draft, sign and file your recurso (appeal) for you. What we charge you: €298.

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We file a complaint against your broker, bank or fund manager before the CNMV's Servicio de Reclamaciones del Inversor (investor complaints service) for deficient risk information, improper fees, unauthorised transactions, mis-sold complex products (preferentes or preference shares, subordinadas or subordinated debt, investment funds), execution errors and any MiFID II malpractice. If you have not yet complained to the firm's SAC (customer service department) or Defensor del Inversor (investor ombudsman), we first draft that written submission at no extra cost.

Practical guide: Claiming to the CNMV and the Insurance Compensation Consortium. Requirements, deadlines and the steps, explained.

What we charge you: €298
Managora's fee: €298.00 (21% VAT incl.)
Tasa (official government fee): No tasa payable
Processing time: Resolution by the CNMV complaints service: approximately 4 months. The resolution is NOT binding on the firm, but its evidential value in court proceedings is very high, especially for a nullity action for defective consent (4 years from becoming aware of the error).
Where it is filed: Comisión Nacional del Mercado de Valores (CNMV) ↗
What you receive: Recurso (administrative appeal)

Cost breakdown: Our fee €298.00 (21% VAT incl.). The complaint to the CNMV complaints service is free of charge, with no tasa (official fee)..

Complaint against an investment firm before the CNMV (Spanish securities market regulator): how is it filed?

1Answer the questions in the chat (~5 minutes).
2We will show you whether your case can be taken straight to the CNMV or whether it is best to complain first to the SAC.
3Payment of €298.00 (21% VAT incl.). If a prior SAC step is required, we include the written submission to the SAC at no extra cost and, once the legal deadline of one month has passed, we escalate to the CNMV.
4Signature of the mandato (authority to act on your behalf) from your mobile.
5Complaint submitted at sede.cnmv.gob.es by our case handler.
6You receive the submitted written document, annexes, signed mandato, submission acknowledgement and invoice.

Which documents do you need?

•Investment services contract and idoneidad (suitability) test, both signed (if you have kept them).
•Statements of your securities account, the product's KIID/PRIIPS documents and relevant transactions.
•Communications with the SAC (customer service department) or Defensor del Inversor (investor ombudsman): emails, reference number, reply. You do not need to upload it here.

Legal basis and things to bear in mind

The CNMV is free of charge: you pay no tasa (official fee) to the body. Our fee covers the technical drafting and the submission.
What the Complaints Service issues is a reasoned REPORT, not a resolution, and it is not binding on the firm nor does it oblige it to pay you back anything. Its value is evidential in a later civil claim.
The action for nullity on grounds of defective consent runs for four years and it is a CADUCIDAD period, not a limitation period: complaining does not interrupt it. And the article is 1301 of the Civil Code, not 1266, which is the one defining when error vitiates consent. Art. 1301 itself says that in cases of error the period runs from CONSUMMATION OF THE CONTRACT, not from when the investor realises; case law has adjusted this for complex products, but counting from the moment you find out is the quickest way to be too late.
For preferentes (preference shares) and subordinadas (subordinated debt), the case law of the Tribunal Supremo (Supreme Court) has been favourable to retail investors: the absence of the test does not by itself establish the error, but it allows it to be presumed. It is a rebuttable presumption, not an automatic outcome.
If your case involves more than 5.000 € or the product is complex, it is usually worthwhile to also start court proceedings in parallel. We will guide you.

Complaint against an investment firm before the CNMV (Spanish securities market regulator): frequently asked questions

Complaint against an investment firm before the CNMV (Spanish securities market regulator): how much does it cost?

We charge you €298: our fee plus, where applicable, the fixed official tasa we advance. Our fee €298.00 (21% VAT incl.). The complaint to the CNMV complaints service is free of charge, with no tasa (official fee).. Managora's fee is €298.00, 21% VAT included (€246.28 net + €51.72 VAT). This procedure carries no official tasa.

Complaint against an investment firm before the CNMV (Spanish securities market regulator): how long does it take?

Resolution by the CNMV complaints service: approximately 4 months. The resolution is NOT binding on the firm, but its evidential value in court proceedings is very high, especially for a nullity action for defective consent (4 years from becoming aware of the error).

Complaint against an investment firm before the CNMV (Spanish securities market regulator): which documents do I need?

You need to have to hand: Investment services contract and idoneidad (suitability) test, both signed (if you have kept them)., Statements of your securities account, the product's KIID/PRIIPS documents and relevant transactions., Communications with the SAC (customer service department) or Defensor del Inversor (investor ombudsman): emails, reference number, reply. You do not need to upload it here.. You do not upload them here: we collect the details through the guided chat.

Who files the procedure?

Managora files it in your name with Comisión Nacional del Mercado de Valores (CNMV). You only provide the details through the chat and sign a mandato (power of representation); we prepare, sign and register it.

Can it be done online?

Yes. The whole process is online: you answer a few questions in the guided chat, sign a simple mandato on screen and receive the receipt and the official documents by email, with full legal validity.

Related procedures

Based on the legislation in force and on the official site of the competent authority: Comisión Nacional del Mercado de Valores (CNMV) ↗.

Managora Gestion SL (company number B88823893) is a private company. We are not Comisión Nacional del Mercado de Valores (CNMV), we are not affiliated with, authorised or endorsed by any public authority, and this website is not an official government portal. What you pay on this page is our fee for preparing, signing and filing the procedure on your behalf: it is separate from the official tasa, which where applicable belongs to the authority and is shown to you separately. You can carry out this procedure yourself, directly with Comisión Nacional del Mercado de Valores (CNMV).

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