On 9 August 2019, the AICD made a submission to ASIC on its proposed updates to Regulatory Guide 165 (Internal dispute resolution).
The AICD supports ASIC in updating its existing internal dispute resolution (IDR) requirements to improve the way that consumer complaints are dealt with across the financial system. We agree that it is essential for consumers and small businesses to have access to transparent, fair and timely IDR processes.
In regard to systemic issues and the role of the board, the AICD supports the requirement that boards must set clear accountabilities for complaints handling functions, including setting thresholds for, and processes around, identifying systemic issues that arise from consumer complaints. It is important that boards have discretion to set these thresholds as this will ensure that they are appropriate and workable for the relevant financial institution.
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