Tips & Traps: Complaints Register – To Log or Not to Log?
We are frequently asked about what needs to be entered into an insurance broker’s Complaints Register. The answer is that insurance brokers only need to log complaints made about their own services into the Complaints Register.
Some examples of what should be recorded include complaints about:
- Advice and product recommendations made
- The conduct of your employees or Authorised Representatives
- Delays in paying premium refunds
- Your role in the claims handling process
There is no need to log complaints about an insurer’s products and services or about product pricing (although you should record complaints about any broker fees that you charge on top of premium). Similarly, complaints about an insurer’s claims decision do not need to be logged (but a complaint about your failure or delay in notifying an insurer about a claim should be). Complaints about an insurer’s product/s and services or claims decisions should be forwarded to the insurer.
Complaints about your lack of response where you are waiting on an insurer will depend on the substance of the complaint. If the client is complaining about not having a response on a claim, that is a complaint about the underwriter’s service as it is something outside your control. If the client complains about your failure to advise them that you are awaiting information from the insurer, that would be a complaint about your service.
Another area of confusion is whether all complaints, no matter how trivial, need to be logged in the Complaints Register. If a client expresses dissatisfaction, but is readily satisfied with the information or explanation that you provide, that does not need to be logged. If the client is not satisfied with the explanation, then of course, you need to log the complaint.
A grey area arises in situations where the client’s dissatisfaction has some validity. For example, if your service was actually less than the client’s expectations (and your service standards), but the client accepts the information or explanation that you provide. In most circumstances, these complaints should be logged – you can to use your judgment. Remember that this type of information can be very useful for quality management as it provides a record of departures from your desired service standards and client satisfaction levels that, over time, could point to a systemic problem that you can then address.
Keeping your Complaints Register up to date and ensuring that your employees and Authorised Representatives are familiar with your internal and external complaints policies and procedures – including the types of complaints that should be logged, are important parts of your AFS license obligations.