ASIC has released the results of a recent survey in relation to industry preparedness for the new enforceable internal dispute resolution (IDR) obligations. The results highlight some important areas which ASIC consider require further work. Whilst the results are particularly important for the superannuation industry who were the focus of the survey, all licensees should take note of ASIC’s comments.
ASIC identified some important areas requiring additional effort:
|Attention to Governance Arrangements||It is extremely important that all licensees brief their Board of Directors, or senior management on the obligations which apply under Regulatory Guide 271. There are significant changes included in RG271 which will require changes to the processes and procedures of all licensees at all levels of the organisation.
It’s also important to remember that the obligations in RG271 apply to the licensee, not an outsourced provider. If you outsource your complaint management procedures – you will need to ensure the provider’s compliance with the new obligations.
|Implementation of the New Maximum Timeframes for IDR Responses||Licensees need to consider carefully how they triage complaints and who within the organisation is responsible for:
• acknowledging a complaint;
• investigating the complaint;
• responding to complaints;
• determining remedies.
ASIC’s guidance to superannuation trustees notes that licensees should consider whether there are barriers or risks across the business which will impact meeting these new timeframes. All licensees should ensure they have appropriate reporting lines and responsibilities to ensure that delays are avoided in investigating and responding to complaints.
|Identification, Ownership and Reporting of Systemic Issues||This is a major change to the obligations on licensees and ASIC noted that of all the new IDR requirements, trustees preparedness for this item was not as advanced.
All licensees can take note of this and ensure they:
• communicate appropriate definitions of systemic issues to the staff involved in investigating and assessing complaints;
• have appropriate methods of escalation in place;
• have appropriate internal reporting procedures in place;
• providing training in relation to the definition and management of systemic issues to relevant staff.
|Data Capture and Integration||Licensees should consider how data from the various systems utilised in their business can be integrated or extracted to give a holistic view of complaints management.|
If you require assistance with implementing your IDR procedures in light of the changes to RG271, please contact us.