Complaints Management Framework

Complaints Management Framework – Effective date for full implementation

The General Code of Conduct was significantly amended in June 2020. This is particularly true of Section 17 which requires the establishment of a complaints management framework.

Most of the new requirements had to be implemented by 27 December 2020. These changes included

  • the actual establishment of the framework
  • the allocation of responsibilities for effective complaints management
  • the establishment of an internal complaints escalation and review process, and
  • requirements relating to record keeping, monitoring and analysis of complaints.

The remaining provisions of Sections 17 will become effective on 26 June 2021. These are S 17(2), S 17(4) and S 17(7)(b)(iii), (c) and (d).

S 17(2) details the minimum requirements for the complaints management framework. These include, inter alia:

  • appropriate performance standards and remuneration and reward strategies for complaints management
  • documented procedures for the categorisation of complaints
  • complaint record keeping, monitoring and analysis
  • processes for managing complaints relating to the provider’s representatives and service suppliers.

In terms of S 17(4) providers must categorise reportable complaints (i.e. complaints that have not been upheld) into a number of specified categories. These categories include, inter alia:

  • complaints relating to the design of a financial product, financial service or related service, including the fees, premiums or other charges related to that financial product or financial service
  • complaints relating to information provided to clients
  • complaints relating to advice.

S 17(7) sets out the requirements relating to the record keeping, monitoring and analysis of complaints. Most of S 17(7) became effective in December 2020. Certain of the more complex requirements will be come effective on 26 June this year.

S 17(7)(b)(iii) provides that each complaint must be categorised as provided for in S 17(4) referred to above.

In terms of S 17(7)(c), a provider will now be required to maintain certain data relating to reportable complaints. Such data must include, inter alia:

  • number of complaints received
  • number of complaints upheld
  • number of rejected complaints and reasons for the rejection
  • number of complaints referred to an ombud and their outcome.

In terms of S 17(7)(d), all recorded complaints information must be scrutinised and analysed by a provider on an ongoing basis so as to manage conduct risks and to ensure improved outcomes and processes for its clients.

This article is intended as a heads-up only and does not contain the details of all the required changes that have been imposed by the amended S 17.

In this regard the writer falls back on the old adage: When in doubt, consult the handbook. A copy of the amended General Code of Conduct (Board Notice 80 of 2003) is available with all amendments highlighted.

It’s worth a read.

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