Purpose/Objectives

(NCCP Obligation)

This policy sets out our approach to dispute resolution.

Scope/Application

This policy applies to the General Manager and all staff/representatives.

This policy is based on the NCCP legislation and on ASIC Regulatory Guides:

RG 205: Credit Licensing: General Conduct Obligations; and

RG 165: Internal and External Dispute Resolution

Definition(s)

Dispute resolution is the process by which we consider, assess and resolve, where possible, complaints raised by   consumers, lenders or any other person associated with our business

Internal dispute resolution is our complaints management policies and procedures that meet ASIC’s requirements and standards outlined in its RG 165.

External Dispute Resolution Scheme is an ASIC approved scheme under the Corporations Act and/or the NCCP Act

Policy Statement

Our business is committed to excellent customer service and the resolution of any concerns or complaints quickly, fairly and efficiently.

• We welcome complaints as a positive means of reviewing and improving our customer services. All complainants will be treated with respect, courtesy and consideration.
• Our internal dispute resolution scheme is open to anyone who deals with us: customers, dealers, lenders, other brokers, contractors or any other person.

• All representatives are expected to inform complainants about our IDR/EDR processes as soon as they become aware of a concern, to give high priority to resolving complaints quickly and to assist any complainant through the process.

• The General Manager will manage complaints.

• Our Internal Dispute Resolution Manual complies with ASIC’s requirements and details how we manage and report complaints.

• We are a member of the Financial Ombudsman Service (FOSL)/ External Dispute Resolution (EDR) Scheme (Member No: 41164), as approved by ASIC. We accept EDR scheme decisions and implement their recommendations as soon as we are informed of them.

• The General Manager holds information on complaint statistics and any associated compliance breaches.

• We will report to ASIC annually any compliance breaches indicated through the complaints process and the policies and procedures subsequently implemented to ensure there is no re-occurrence.

Supporting Procedures

• Internal Dispute Resolution Manual
• COSL Membership Terms and Conditions

Responsibility – Implementation

The General Manager is responsible for approving the IDR scheme and EDR

Membership, allocating adequate finance to support those processes and for regularly reviewing

complaint data.

The General Manager and partners are jointly responsible for ensuring the IDR scheme meets ASIC’s standards, the EDR scheme is ASIC approved, representatives are trained in dispute resolution management and complainants are made aware of both IDR and EDR schemes.

Responsibility – Monitoring & Reporting

The General Manager is responsible for ongoing monitoring of the effectiveness of both the IDR and EDR schemes.

The General Manager and partners are jointly responsible for monitoring of the adequacy of our IDR and EDR framework and on any factors that may compromise their adequacy.

The General Manager will review complaint statistics quarterly and address any systemic issues they may identify.

Communication

This policy will be available through:

• Electronic copy – held by the General Manager

Related policies, documents & forms

• Risk and Compliance Manual
• Internal Dispute Resolution Manual
• COSL Membership Terms and Conditions

Review

The General Manager will review this policy annually.

Policy date

1 January 2018

Reviewed

1 May 2018