Complaint handling starts when a client expresses dissatisfaction that needs a response. Record it immediately, assign the licensee’s internal dispute resolution process and investigate before issuing a reasoned outcome. If the client takes the matter to the Australian Financial Complaints Authority (AFCA), keep one person responsible for the brokerage’s response.
For a standard broker complaint, diarise a written response within 30 calendar days of receipt. Obtain your licensee’s complaint procedure and response authority before investigating. This workflow handles a complaint against your brokerage about its service, fees or credit assistance.
Recognise and Record the Complaint
Treat dissatisfaction about your service, staff or complaint handling as a complaint when a response is explicitly or implicitly expected, or legally required. A verbal complaint qualifies. The Australian Securities and Investments Commission (ASIC) sets this test in RG 271 Internal dispute resolution.
For example, a client says your fee differs from what you explained and asks for their money back. Record the complaint during that call. Requiring a special form would add a step before the brokerage deals with the issue.
- Save the client’s words and when you received them, including the original email or a call note.
- Confirm who is complaining, their contact details and any representative’s authority.
- Ask what happened and what remedy the client wants. Separate their account from your initial view.
- Identify the broker, loan reference and responsible licensee. Give the complaint a reference number.
Use the client’s preferred communication method and record any help they need to participate. Tell staff where to send complaints received through ordinary client conversations.
Assign the IDR Response
Assign internal dispute resolution (IDR), the firm’s own complaint process, to the person authorised under the licensee’s procedure. ASIC’s credit dispute resolution guidance makes credit licensees responsible for an IDR system and AFCA membership.
If you are an appointed credit representative, send the complaint to your licensee’s nominated contact promptly. Record who accepts ownership and who approves the response. ASIC’s credit representative guidance also requires AFCA membership for mortgage-broking credit representatives. Identify the actual member involved instead of assuming the aggregator answers every matter.
RG 271 expects acknowledgement within 24 hours or one business day of receipt, or as soon as practicable. Receipt starts the response period. Day one follows receipt, including where receipt occurs on a weekend. An internal handover does not restart it.
Early closure can remove the written-response requirement by the fifth business day after receipt: satisfactory resolution, or an explanation/apology where no further reasonable action remains. A requested written response or hardship complaint still requires one. Apply RG 271.71 to RG 271.75 before relying on this exception.
Route actual hardship or enforcement issues promptly to the lender’s relevant team. Different credit-response rules apply there. Keep any complaint about your brokerage open under its own process.
Investigate the Loan File
Build an issue-by-issue record showing what the client alleges and which loan-file evidence answers it. Preserve the original records. Put later explanations in separately identified notes.
Gather the credit guide, proposal and fee disclosures alongside the application and credit assessment records. Include the advice rationale, options considered, client instructions and records supporting the recommendation. Retrieve messages, call notes and relevant lender or aggregator correspondence.
For each allegation, record the evidence supporting the client and the evidence supporting the brokerage. Identify missing documents and assign someone to retrieve them. Ask the client for clarification where their account differs from the file, then retain their reply with the disputed record.
Keep commission evidence separate from the conduct decision. A statement can establish what upfront or trail the brokerage received. It cannot, by itself, establish that the client understood a fee or that the recommendation met the client’s needs.
In a hypothetical complaint, the client disputes an explanation of the broker’s remuneration. A missing trail entry also appears on the aggregator statement. Investigate the disclosure using the credit guide and conversation records. Investigate the missing payment using the statement and aggregator correspondence. Recovering the payment does not resolve the client’s allegation.
Before drafting the outcome, the complaint owner must be able to explain each finding using a named record or a documented evidence gap.
Write the Response and Remedy
Write a response the client can compare with their original complaint. State the outcome and explain each rejected issue using the findings and supporting evidence. Include the client’s AFCA rights and contact details.
Use this order when drafting the letter.
- Identify the complaint and list the issues you considered.
- Explain the finding on each issue, with the relevant document or conversation.
- State the remedy, who will implement it and when. Explain any part you reject.
- Explain the right to take an unsatisfactory outcome to AFCA and provide AFCA’s contact details.
Use the licensee’s approved AFCA contact block. Make the offer’s conditions clear, including how the client accepts it. Have the authorised person review the letter against the evidence before sending it.
A delay exception requires no reasonable opportunity to respond because of particular complexity or circumstances beyond the firm’s control. Before expiry, send reasons, AFCA rights and contact details. RG 271.64 to RG 271.66 applies. An update alone does not create an extension.
Escalate a threatened deadline internally with the missing evidence and work still needed. Keep investigating and give the client a practical next update. Their right to approach AFCA continues.
Respond When AFCA Receives the Matter
Nominate one AFCA contact and allocate every request to an owner with a due date. Confirm the named financial firm with the licensee and retain the AFCA reference beside the IDR reference. The task is to answer the complaint against the brokerage, even if the underlying loan is with a bank.
AFCA’s guidance on resolving complaints identifies the records financial firms can need to provide. Send an indexed file containing the complaint, IDR outcome and relevant evidence. Map the response to AFCA’s questions so a reviewer can locate each supporting record.
Read the timetable in AFCA’s actual notice. Respond by the specified deadline, or explain promptly why an item cannot be supplied and seek directions. Keep a record of documents sent and any extension AFCA grants. A request for extra time is not an agreed extension.
Give the person attending conciliation authority to settle the matter. AFCA says each party must have that authority. Arrange licensee and insurer involvement under your own notification process before committing to a settlement.
If the matter settles, record the agreed terms and implementation responsibilities. If AFCA issues a determination, send it to the authorised decision-maker immediately. AFCA’s member guidance explains that a determination accepted by the consumer binds the member to the required actions. Track those actions through to completion.
Close the Record and Review Controls
Close the complaint record only after recording the outcome and checking that promised actions are complete. Keep the response and evidence available under your licensee’s retention and access rules.
Use the following fields for a complaints register template in Excel or your existing system. Keep sensitive supporting documents in the controlled complaint file and put references in the register.
| Register Field | What to Record |
|---|---|
| Complaint identity | Unique reference, receipt date and channel, complainant and contact details |
| Responsibility | Broker, responsible licensee, complaint owner and response approver |
| Issues and remedy sought | Client’s account, disputed service or fee and requested outcome |
| Timing | Acknowledgement, response deadline, updates and any delay-notification basis |
| Investigation | Document references, findings, evidence gaps and outstanding requests |
| Outcome | Decision, reasons, response sent and client reaction |
| Remedy completion | Agreed actions, responsible person, due date and proof of completion |
| AFCA | Member and case references, requests, deadlines and settlement or determination |
| Controls and closure | Root cause, recurrence action, reviewer, closure date and follow-up check |
| Separate reporting | Licensee assessment owner, decision and reference to any required report |
ASIC’s IDR data reporting guidance requires credit licensees to submit complaint data. Give your licensee the records needed for that separate reporting process.
Also refer possible reportable situations to the licensee’s compliance lead. A complaint does not automatically establish a reportable breach. Use the broker breach reporting assessment for that separate decision.
Update the complaint controls in your brokerage policies and procedures when the investigation exposes a process failure. Use the next brokerage compliance audit to test whether that change works. For complaint handling training, walk staff through an anonymised file from first receipt to completed remedy, including a verbal complaint and a missed-deadline escalation.
Before marking the matter complete, check that every promised action has evidence of completion and every recurrence action has an owner.
