Customer Complaints Policy and Procedure
Credit Licensees are required, as part of the general conduct obligations of an Australian Credit Licence, to have in place a Complaints Policy. The complaint policy needs to describe how the business (licence holder) manages complaints and the framework within the business that supports this.
In addition to promoting a culture of fair customer treatment, complaints policies also assist your business to comply with:
a. ASIC Regulatory Guide RG165 (on dispute resolution);
b. External disputes resolution scheme rules (e.g. CIO or FOS);
c. International Standards Organisation standard ISO10002 (on complaints handling); and
d. The National Consumer Credit Protection Act 2009 and associated Regulations.
A good complaints policy applies to all employees, agents and representatives of the business ("staff") and to all your products. We understand that brokers are more likely to receive a complaint about a Lender's process, rather than their own, however he definition of a complaint (the way ASIC views it) is important for your policy. This often is missed.
QED will prepare the document that will clearly detail the procedures your Staff must follow on becoming aware of a complaint, just the way that ASIC requires ,
Part of Credit Licensees' obligations is to test their business against their policy regularly, to document the results and take action to comply. If audited by ASIC, a Licensee will be required to provide access to this documentation.
QED CompliFast is an online compliance monitoring system that Australian credit licensees use to meet their NCCP compliance obligations. With different areas tested quarterly, QED CompliFast ensures adequate testing, documentation and recommended action plans for the management of complaints.