Response to ASIC’s update to internal dispute resolution requirements for financial firms (RG165)

It is critical that the process to make and resolve complaints with a bank, insurer, or super fund is timely, fair, and accessible, including for people experiencing vulnerability and disadvantage.  Our casework experience reveals that internal dispute resolution (IDR) is highly variable between financial firms and often of poor quality. 

Consumer Action Law Centre strongly supports ASIC’s work to improve the quality, transparency and oversight of IDR in our response to ASIC Consultation Paper 311, Internal Dispute Resolution: Update to Regulatory Guide 165 (May 2019). 

ASIC Report 604 estimated nearly 270,000 complainants dropped out of the complaints process due to barriers and obstacles.  Improvements to the oversight and reporting on IDR performance can’t come soon enough for Australians struggling to get a fair outcome. 

We broadly support the proposed updates in Draft Regulatory Guide 165.  ASIC’s proposed26 updates will enable accessible and faster dispute resolution, more consistent outcomes, and improved data collection and systemic issues insights. 

This submission also comments on the role and regulation of ‘Customer Advocates’. 

You can read the full submission here [PDF].


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