Ensure compliance to complaints standards.
Complaints Compliance Audits
The Customer Service Institute of Australia with its recognised Complaint Handling Framework assessments to AS/NZS 10002 [Guideline for complaint management in organisations] is ideally and possible uniquely situated to provide RG 271 Compliance Audits to the 10,500 financial organisations that are subject to the Regulatory Guidance as at October 2021.
RG 271.189/190 States that ‘Firms should conduct regular compliance audits to identify and address issues of non-conformity with this regulatory guide and internal requirements. Unless the number of complaints is very small, we would expect compliance audits to be undertaken at least annually. Where non-compliance with this regulatory guide is identified, appropriate action should be taken—such as performance feedback, re-training and enhanced supervision for complaints management staff and, where appropriate, rectification for the complainants adversely affected by the non-compliance.
This is in addition to the required review of Internal Dispute Resolution processes as noted in RG 271.193/194/195 - Senior management should conduct or arrange regular reviews of the IDR process to:
(a) consider the suitability, effectiveness and efficiency of the IDR system;
(b) assess whether systemic issues are being promptly identified and remedial action taken to address the issues;
(c) assess whether the remedial action is prioritised and effective;
(d) identify improvements that need to be made; and
(e) assess customer satisfaction (e.g. through surveys).
For a smaller firm with few complaints, senior management could undertake the IDR process review in conjunction with the compliance audit. For a larger firm, the internal audit function or an appropriately qualified independent consultantcould undertake the IDR process review.
Further to this RG 271.197 states that ‘Firms should also consider other improvement activities, including: (a) conducting benchmarking exercises; amongst other activities.
The Complaints Management Compliance Review
Audit your Internal Dispute Resolution (IDR) processes as part of an annual compliance review.. Aligned to ASIC Regulatory Guidelines RG 271 and AS/NZS 10002 - Guidelines for complaint management in organisations.
CSIA’s Complaint Management Compliance Review (CMCR) is an assessment of a company's complaint management system to ensure that it complies with ASIC regulations [RG 271], and industry standards [ASNZS ISO 10002]. The goal of the review is to identify any deficiencies or areas for improvement in the company's complaint handling processes, and to make recommendations for remedial action.
The review typically involves an analysis of the company's policies, procedures, and documentation related to complaint handling, as well as interviews with key personnel involved in the process. The review team will also examine a sample of complaints to evaluate how effectively they were handled and whether the company followed its own procedures and regulatory requirements.
During the review, the following areas are typically examined:
Complaint handling policies and procedures - this includes reviewing the policies and procedures to ensure that they are clear, complete, and comply with regulatory requirements.
Complaint recording, categorisation and tracking - the review team will examine how complaints are recorded, categorised and tracked to ensure that they are properly recorded and addressed in a compliant timeframe.
Staff training - the review will assess whether staff members who handle complaints are properly trained and have the necessary knowledge and skills to effectively manage complaints.
Investigation and resolution - the review will evaluate the company's process for investigating and resolving complaints to ensure that they are addressed appropriately and within regulatory timeframes.
Reporting and analytics - the review team will examine how complaints are reported (where and when required) and analysed to identify trends, recurring issues, and areas for improvement.
Continuous improvement – the review team will look at processes in place to review, survey and improve the company’s complaint managing framework.
After the review is complete, a report will be issued that outlines any deficiencies or areas for improvement identified during the review, along with recommendations for remedial action. The company will be given a timeframe to address any identified issues, and a follow-up review may be conducted to ensure that the company has taken appropriate action.
The Complaints Handling Framework
Effective complaints handling is one of the cornerstones of a customer-centric organisation – it’s critical that an organisation, no matter its size or sector, successfully addresses and resolves its customers’ complaints when they arise and learns from the experience.
The CSIA Complaint Handling Framework (CSIA-CHF: 2025) is structured around multiple tenets of a customer-centric philosophy:
That prompt and successful complaints resolution can build customer satisfaction and loyalty, as well as building an organisation’s reputation.
That by better understanding customer complaints, an organisation can improve both its relationship with its customers, but also the quality of its products and services.
That successful complaint handling is an all-of-business exercise – a commitment to complaint handling needs to be driven from the top of the business as much as from the front-line worker.
The Framework is structured around three layers of business processes:
The organisational foundation elements on which a successful complaint handling process is built. - the business culture and resources on which complaints are managed.
The complaints process itself - the customer and business journey of receiving, investigating and resolving a complaint, and
The organisational outputs - how an organisation manages complaints handling, understanding both the broader trends and how they impact the business, and learns from them
This framework has been designed with versatility in mind. It can be applied to large corporates through to smaller organisations, across a range of sectors both public and private. It’s with this versatility that all organisations can use this framework as the basis of designing, implementing, and managing a best-practice approach to complaint management.
The Framework consists of 25 elements across these three layers