“I am not making a complaint, but…” The client starts politely.
They explain that they have already sent the requested documents twice, waited more than a week for an update, and then found themselves repeating the entire story to another team member. Their tone remains calm and respectful. In fact, they may even soften the conversation by saying, “I’m not making a complaint, I just thought you should know.” The team member apologises, locates the documents, provides the update that has been outstanding for days, and the client seems satisfied. By the end of the conversation, the immediate issue has been resolved.
For many businesses, that would appear to be the end of the matter.
However, from a Financial Advice Provider (FAP) perspective, an important question remains: was the concern recognised, recorded, and handled through the appropriate complaints process? The fact that a client does not explicitly use the word complaint does not necessarily mean a complaint has not been made. In many cases, clients simply want their issue addressed and may not realise that what they have raised falls within the regulatory definition of a complaint. If organisations focus only on solving the immediate problem and fail to document the concern, valuable information about service quality, client experience, and operational weaknesses can easily be lost.
Listen to the Concern, Not Just the Language
One of the most common misconceptions in complaint handling is assuming that a complaint only exists when a client explicitly labels it as one. In reality, clients often express dissatisfaction in far more subtle ways. They may mention being disappointed, explain that they have already followed up several times, question why information has not been provided, or ask to speak directly with the adviser. While these comments may appear casual, they can indicate a level of dissatisfaction that requires formal recognition.
For FAP regulatory purposes, a complaint is generally an expression of dissatisfaction relating to a financial advice service or the complaints-handling process where a response or resolution is either explicitly or implicitly expected. A complaint can be communicated through a phone call, email, letter, social media post, website message, or face-to-face conversation. What matters is not the specific language used, but whether the client is expressing dissatisfaction and expecting the business to address it.
Research consistently shows that many dissatisfied customers never formally complain at all. Instead, they quietly leave or share their negative experiences with others. According to customer experience studies, only a small proportion of unhappy customers lodge formal complaints, meaning every concern that is raised represents valuable feedback and an opportunity for improvement. Organisations that identify and manage concerns early often prevent larger issues from developing later.
The Responsibility of Frontline Team Members
When a concern is raised, frontline staff do not need to determine whether the adviser or business has made a mistake. That assessment should remain with the appropriately authorised person responsible for the complaints process. The responsibility of the team member receiving the concern is far more practical, but equally important.
They should listen carefully without becoming defensive, acknowledge the client’s experience, document what was raised, record when the concern was received, and note any actions already taken. They should then escalate the matter through the FAP’s approved complaints process, explain what the client can expect next, and ensure that all future actions, communications, and deadlines are monitored appropriately.
These steps sound simple, yet they are often overlooked during busy periods. When staff are dealing with high workloads, there can be a natural temptation to resolve the issue quickly and move on. While this may satisfy the client in the short term, it can also result in missed opportunities to identify recurring problems, improve internal processes, and meet regulatory expectations.
One Concern May Reveal a Much Larger Pattern
A delayed response, a missed email, or a forgotten document request may initially appear to be a one-off administrative mistake. However, when similar concerns start appearing across multiple clients, a broader issue may be emerging beneath the surface.
Perhaps no individual has clear responsibility for monitoring a shared inbox. Maybe client communications are being completed but not properly recorded in the CRM. A handover process between advisers and administrative staff may exist on paper but break down in practice. In some cases, technology systems may not provide adequate reminders or visibility of outstanding client requests.
Without effective recording and reporting, these patterns remain hidden.
This is where a well-maintained complaints register becomes invaluable. Rather than viewing concerns as isolated incidents, the register allows the business to identify trends, recurring service failures, bottlenecks, and operational risks. In many organisations, complaint analysis has become an important source of business intelligence. Studies in customer service management suggest that organisations that actively analyse complaint data identify service improvement opportunities significantly faster than businesses that only address issues on a case-by-case basis.
Learning from Regulatory Expectations
The Financial Markets Authority (FMA) has repeatedly emphasised the importance of effective complaints handling as part of good customer outcomes. The FMA’s September 2025 complaints information sheet encourages providers to make it easy for consumers to raise concerns, ensure staff understand what may constitute a complaint, treat consumers fairly, and use complaints information as a valuable source of learning and continuous improvement.
Importantly, the guidance is not simply about compliance. It reflects a broader principle that businesses should use complaints data to understand the customer experience and strengthen their systems and controls. A complaint that is properly identified, documented, and reviewed can provide insights far beyond the circumstances of a single client interaction.
The Value of Dependable Support
Effective complaints handling depends on structure, consistency, and accountability. In a busy advice practice, concerns can easily become buried among meetings, emails, client calls, reviews, and administrative tasks. Without a clear process and appropriate support, important actions can be delayed, forgotten, or overlooked altogether.
A trained support person can play a critical role in maintaining that structure. They can accurately document concerns, ensure they are entered into the correct register, direct matters to the authorised person responsible for complaint assessment, track follow-up actions, and monitor deadlines. They can also help ensure clients receive updates throughout the process so they remain informed about what is happening and what to expect next.
This does not transfer responsibility away from the FAP. Decisions regarding liability, remediation, complaint outcomes, and regulatory obligations must always remain with the appropriately authorised person. What strong support provides is visibility, consistency, and follow-through.
When complaints are properly recorded and managed, clients gain confidence that they have been heard. Staff have a reliable record of events and actions taken. Management gains visibility over emerging issues and recurring themes. And the business develops a stronger understanding of where its systems, processes, and client experience can be improved.
A-Perform works within the FAP’s approved complaints-handling process to help maintain this structure and administrative discipline. The FAP remains responsible for ensuring complaints are handled fairly, transparently, and within regulatory requirements. However, with dependable support in place, concerns are far less likely to be overlooked, allowing the business to focus not only on resolving individual issues but also on learning from them and continuously improving the client experience.
