Investigate a complaint and assess a breach

You are the Compliance Officer in Compliance, Risk and Client Services.

Simulated workplaceAdvanced missionCAQA Ledger and Lane Financial

What is going on

Complaint CR-26-057 was received on 4 September from a client who refinanced a fixed rate home loan through the firm and was charged 9,200 dollars in break costs he says he was never told about. The file shows a signed credit proposal that mentions break costs in a standard paragraph but no file note of a conversation. Separately, breach entry CR-26-054 records that the August file sample found two loan applications submitted without the second-person review recorded in the pipeline; both loans were approved and one is the complainant's. The Compliance Manager wants a written response to the complainant within the 30-day timeframe and a breach assessment with a recommendation on whether it is reportable to the regulator.

Grace Whitmore, Compliance Manager
Subject: Fixed rate break cost complaint and the file review breach

I need you to investigate complaint CR-26-057, where a client says he was not told about fixed rate break costs before refinancing, and to assess CR-26-054, the two broking files submitted without second-person review. Read the Complaints Handling Policy and the Responsible Lending and Best Interests Policy, review both files, interview the brokers, and draft the written response to the complainant and a breach assessment with your recommendation on whether it is reportable. Both are due before the end of the month.

Your brief

Investigate complaint CR-26-057 and breach entry CR-26-054 under the Complaints Handling Policy and the Responsible Lending and Best Interests Policy, review the files, interview the brokers, decide whether the firm made an error and what remedy is fair, draft the written response and produce a breach assessment with root cause, actions and a reportability recommendation.

Work through it

You do not need to do it all. Doing a few of these will show you what the work is like. Your ticks and notes stay on this device.

Read the Complaints Handling Policy and the Responsible Lending and Best Interests Policy and set out the timeframes, standards and remedies that apply to this complaint.
Review the complainant's loan file: the needs analysis, preliminary assessment, credit proposal, file notes and the pipeline record, and list what is and is not evidenced.
Interview or simulate interviews with the broker and the credit analyst, record their accounts and compare them with the file.
Decide whether the firm met its obligations to explain break costs and act in the client's best interests, and determine a fair remedy with reference to the policy.
Draft the written response to the complainant explaining the findings, the reasons, the remedy and the right to go to the external dispute resolution scheme.
Assess the second-person review breach: how many files, what harm, root cause, whether it is significant and reportable, and what actions and owners will prevent recurrence.
Update both entries in the Complaints, Breaches and Compliance Register and prepare a one-page briefing for the compliance committee on 7 October.

My notes: what did I enjoy, and what surprised me?

What someone in this role would produce

Investigation file review and interview records
Draft written response to the complainant
Breach assessment with reportability recommendation
Updated register entries and committee briefing

Printing this is a record of what you explored. It is not a certificate or a qualification.