Every business will get complaints but some believe that a complaint is a just a massive time waster. Complaints can challenge the way things are done and highlight a process failure that needs attention.

The question is: How do you use effective complaint management to improve your business model? Read on to find some information that will simultaneously help you to comply while enhancing your business.

Maybe there really is a silver lining to that complaint cloud!


Businesses, including those involved in the credit and finance sector, are impacted by new regulatory dispute requirements on dealing with complaints. The Australian Securities & Investments Commission (ASIC) recently issued an updated Regulatory Guide: RG 271 Internal dispute resolution and an enforceable “Instrument”.[1] This new guidance is an update of RG165 which was issued in 2009 when the NCCP Act initially came into effect.

In ASIC’s view, a financial firm’s approach to complaints handling is “a meaningful measure of how it treats its customers and listens to their voice… and plays a critical role for firms to restore consumer trust when things have gone wrong.” 

While new obligations for brokers aren’t triggered until October 2021, it will be useful to tweak your systems and procedures to ensure that you comply with the requirements and at the same time, adjust your processes to build trust, referral rates and the satisfaction levels of your clients.

What are the changes?

Brokers will have 30 days to respond to a complaint but if they resolve it to the customer’s satisfaction within 5 days, there’s nothing more to do expect to keep a record of it and your resolution (unless they want a written response). If 5 days is too short, the new guidance specifies inclusions in the written IDR response that a firm must provide to the customer to allow the consumer to decide whether to escalate their complaint or not.

An eye on future success

Some will consider this to be yet another bit of red tape that needs to be navigated. However, business owners with an eye to future success and enhanced profitability need to be clear about what the expectations are on them in the way they manage complaints. These owners also understand that prompt and effective resolution is the best way to manage this issue and at the same time they will be able to modify systems and procedures to minimise the risk that more such complaints may arise leading to a more reliable and robust service.

What do broker statistics show?

Mortgage and finance brokers have demonstrated that they have extremely low numbers of complaints with the Australian Financial Complaints Authority (AFCA) when compared to other credit sector participants and to other industry sectors such financial advice and insurance.

This means that, despite unjustified criticism from some quarters, brokers are either:

  • brilliant at ensuring that complaints don’t occur in the first place; or
  • exceptional at resolving complaints quickly and efficiently.

Whatever the case, it seems therefore that brokers may already be managing their complaints well which is a great relief to regulators, the community and the whole intermediated lending sector.

How to manage complaints effectively

While ASIC requires certain actions to be completed, it is fairly obvious that a procedure to manage customer expectations and outcomes needs to be established in advance. You need to be able to respond quickly and appropriately to a complaint. If a complaint is via social media, you need to be able to respond effectively to avoid any ‘wildfires’ through a matter going viral.

Where’s the value in managing a complaint well?

Managing complaints positively pays dividends. Current wisdom is that the benefits include:

  • customer retention – if a customer complains s/he wants you to convince him/her to stay;
  • “Brand” maintenance – loyal customers do not denigrate you;
  • increased efficiency - through consistency of systems/procedures;
  • continuous improvement – someone gives you a free kick to “get it right” before they leave you; and
  • staff retention - because staff know what to do and how to do it, when someone complains. No-one likes to be in the firing line every time!

Do’s and Don’ts

Here are some Do’s and Don’ts to help you in dealing with a complaint:


  • Accept complaints
  • Put a complaint management procedure in place
  • Give your name
  • Get their details and the facts and write them down
  • Let the complainant decide whether to pursue their 'complaint' or not
  • Consider the complaint as a personal criticism
  • Ask them to complain in writing or in person or come back later
  • Take the person and their complaint seriously
  • Be honest
  • Let them have their say
  • Tell them what will happen next
  • Be sympathetic
  • Have a clear mechanism to lodge a complaint via a website (or similar)
  • Have a written template for your response already established
  • Analyse data on complaints if you receive them regularly
  • Be flexible to adjust your complaints system if it is lacking



  • Ignore the complaint
  • Argue with the complainant
  • Assume a superior (knowledge) position
  • Deny fault if it is yours
  • Delay your response any longer than necessary
  • Get angry even if they do
  • Get into a blame conversation
  • Undermine your business/employer
  • Pass the complainant on to another person in the organisation - even if it’s not about your particular area
  • Accept abuse from a complainant e.g. swearing
  • Forget to train staff to handle complaints well
  • Deter people from making a complaint
  • Ignore a systemic problem – fix it
  • Use jargon when writing to the complainant or speaking on the telephone






[1] See ASIC RG 271.8: The standards and requirements set out in an enforceable Instrument: ASIC Corporations, Credit and Superannuation (Internal Dispute Resolution) Instrument 2020/98.