The final step for IDR

On 30 March 2022 ASIC released the final requirements for the internal dispute resolution (IDR) data reporting framework ASIC Corporations (Internal Dispute Resolution Data Reporting) Instrument 2022/205. Instrument 2022/205 sets out the IDR data requirements for relevant financial firms.

Since the commencement of RG 271 on 5 October 2021 which we considered in our article Are you ready for RG 271?, financial firms have been required to record all complaints received and have an effective system for recording information about complaints. The IDR data reporting framework will be implemented in 2023 starting with a group of 11 large financial firms that will have to report IDR data to ASIC for the first time by 28 February 2023. ASIC also released an IDR data reporting handbook that sets out:

• an overview of the data reporting process;
• the IDR data dictionary, which describes the data elements firms must report on;
• the IDR data glossary, which defines terminology used in the data dictionary; and
• step-by-step instructions on how to submit IDR data to ASIC via the ASIC Regulatory Portal.

The handbook incorporates the data dictionary and data glossary which were included in the data reporting pilot last year. ASIC Deputy Chair Karen Chester said in a formal statement ‘We all want to see consumers benefit when firms use this data to benchmark, even compete on, their IDR performance.’

The IDR data reported to ASIC must include specified data in relation to each complaint made to the financial firm, including:

• the product or service that the complaint is about;
• the issue raised by the complaint; and
• the complaint outcome.

The product or service categories listed in the IDR data dictionary include some products that firms are not legislatively required to report to ASIC (e.g. some business credit products). These products have been included in accordance with RG 271.44, which encourages credit licensees to deal with complaints from small businesses under the IDR procedures, and accords with ASIC’s general view that firms should take an expansive approach to what complaints their IDR procedures cover.

A consultation paper regarding the publication by ASIC of the complaints data will be issued in the coming months.