A financial firm moved to a “digital first” Internal Dispute Resolution (IDR) model which was impacting its customers’ ability to make complaints.

Consumers impacted

714

Financial remediation

$51,597

Sample title

The digital model substantially moved customers to written form complaint lodgement methods only via mobile app and web and removed the ability to make inbound calls.
RG 271 has enforceable paragraphs which require a firm to have IDR processes that are accessible, including for people with disability or language difficulties, and flexible, with multiple complaint lodgement methods (including telephone, email, letter, in person and online).

Soon after the firm implemented its digital strategy, AFCA started to receive many complaints reporting stressful experiences dealing with the firm at IDR. For example, customers said they could not contact the firm by phone, had issues logging into the firm’s mobile app to contact it digitally, needed to engage in lengthy email correspondence to assist the firm to understand the issue, were requested to provide information multiple times, had to deal with multiple staff on a complaint, were provided with different complaint reference numbers and received responses which did not address the issues raised in the complaint, often being automated and templated responses.

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The firm disagreed with AFCA’s view that the digital model was the cause of the poor experience for customers at IDR, despite AFCA providing key insights from customer complaints, and did not commit to making any improvements. As the firm and AFCA were unable to reach agreement, AFCA reported the systemic issue to the regulator for it to action as appropriate.

Take note

Failure to provide helpful, easy to use and accessible complaint processes can lead to increased escalation of complaints to External Dispute Resolution (EDR). This can result in non-compliance with a financial firm’s obligations, as well as exposure to potential risk to corporate brand and reputation. When a financial firm implements a change, such as a change to how a customer can contact or communicate with a firm, customer processes and experiences need to be closely tested and monitored end-to-end to identify potential impacts to customers and unintended consequences.

What we are seeing?

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Hardship applications and financial difficulty

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Dealing with complaints about financial difficulty

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Credit Reporting

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Last updated: 11 Mar 2025