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New Internal Dispute Resolution Obligations
The new Internal Dispute Resolution (IDR) regulation now applies to any complaints received by financial firms.
Designed to provide fair, timely and effective dispute resolution to consumers and small businesses, the IDR regulation has been amended to improve the complaints handling process for financial firms and to deliver better outcomes for consumers (including small businesses) and drive consistency across financial firms.
The introduced changes require financial firms to:
- adopt the new, broader definition of “complaint”
- have a publicly available, easily accessible complaints management policy with specific content
- have an internal complaints management procedure that supports the complaints management policy – comprehensive, step by step that complies with ASIC’s requirements and clearly defines roles and responsibilities
- adhere to reduced maximum timeframes for responding to complaints
- ensure consumers are fully informed of decisions made in written responses
- escalate systemic issues identified through consumer complaints
With the changes heavily focused on documented evidence and stricter timeframes, it’s more important now than ever to have effective controls and record-keeping processes in place to ensure compliance and for all involved to understand the part they play in both meeting customer expectations and driving compliance.
Important considerations for compliance
Roles and responsibilities
Meeting any obligation requires clearly assigned accountability for those responsible. Making sure all staff involved in the complaints handling process know what their responsibilities are is critical and an ongoing training and development program is necessary to support and enable them to perform their roles.
Encouraging best practice
Writing a comprehensive internal complaints procedure is just one step, compliance with the procedure is another. A positive and proactive complaints management culture must be fostered, where staff are engaged in the process and properly encouraged to deliver best practice including prompt escalation of possible issues identified for investigation and action.
Proficient use of effective systems that adequately capture and store the data required will allow those responsible for governance and oversight to regularly analyse, take corrective action where necessary and report outcomes in the required timeframes.
Monitoring and reviewing the performance of your IDR process and demonstrating continual improvement is essential and not only required for compliance purposes but is imperative to your sustained success.
Are you confident your new IDR process and complaints management culture will deliver compliance and allow for continuous improvement?