Managing your internal dispute resolution (IDR)

From February 2024, all Australian Credit License (ACL) holders will have a mandatory and ongoing obligation to report their customer complaint data to ASIC. Information on how to submit a report can be found here.

This is a timely reminder for ACL holders of the importance of having good internal dispute resolution (IDR) practices that meet the requirements of ASIC Regulatory Guide 271: Internal Dispute Resolution. It is also good business to have a good complaints management (IDR) process and practice.

So, what are the key elements of a robust IDR process to manage complaints?

For credit licensees some important considerations in ensuring a good IDR process to manage complaints include:

• providing ongoing training and resources to your credit representatives on how to effectively manage a complaint.
• having an easily accessible complaints policy which tells your customers how to complain and how you will consider and manage your customer’s complaint.
• responding to a customer complaint promptly and no later 30 days from when you receive a complaint.
• making sure you record all complaints that you receive and keep track of the progress in responding to those complaints.

Credit representatives should:

• follow you licensee’s complaints process and procedure.
• know how to proactively identify a complaint and how to respond to a complaint.
• ensure to respond to a complaint in accordance with your licensee’s complaints process and procedure.

The MFAA have developed for the benefit of its members a “Sample Complaints Policy” and a “Sample Internal Dispute Resolution Procedures” available for its members to download by logging in to the MFAA member portal. You’ll find these resources in the Broker toolbox under Legal and Compliance.

Please contact membercommunications@mfaa.com.au if you would like further assistance.