Complaint v Breach – what do you do?

A verification program by the Insurance Brokers Code Compliance Committee (IBCCC) has revealed several topics where brokers are looking for guidance on.

Common issues include the distinction between a complaint, code breach and licensing requirement.

IBCCC has provided some recommendations to brokers here.

Briefly, when a complaint is received, in order to achieve good industry practice, the IBCCC recommends that Code subscribers:

  • record all complaints you receive from clients, even if you consider that the complaint relates to the conduct of an insurer.
  • review each complaint raised about an insurer to identify potential gaps in your internal process or sale of each product.
  • be clear to your clients about what capacity you are acting: whether on the insurer’s behalf or the client’s behalf.
  • if appropriate, assist your client to engage in the insurer’s internal dispute resolution process and provide guidance to them about the external dispute resolution process.

To ensure effective breach monitoring and reporting, the IBCCC recommends that Code subscribers:

  • review your complaints register to identify whether any complaints may also have caused a breach of the service standards of the Code.
  • be proactive in identifying breaches by undertaking regular file audits or process reviews.

Other useful tips from the IBCCC can be found here.