FMA turns spotlight on complaints

Complaints happen. And while it’s everyone’s least favourite topic, we all know it's the putting it right that really matters.

In its recent Financial Conduct Report, the Financial Markets Authority (FMA) included a section on complaints data, why it's important to thoroughly record any issues, and how complaints can be one of the best tools the industry has for lifting standards, learning the curveballs, and protecting customers in the years ahead.

FMA’s Head of Financial Advice, Ramil Ghelani, let us in on the latest. 

What’s the problem? 

The FMA’s Financial Conduct Report is developed using a mix of monitoring, supervision and enforcement activity across the sector. It’s designed to flag where the regulator’s attention will be focused in the year ahead, and this year, complaints handling made the list.

It’s not that complaint volumes have spiked dramatically, Ramil says. It’s the changing nature of complaints that’s caught the FMA’s eye. 

Reports of mortgage fraud, for example, have climbed sharply. “Up until 2023, we received one complaint a year about mortgage fraud. In 2024 that went up to seven, and then in 2025 that went up to 21.

“For life insurance Advisers specifically, issues at the serious end of the scale have included fictitious customers submitted through insurers’ straight-through processing systems, non-disclosure of medical information, or policies switched unnecessarily - sometimes timed just after the 24-month clawback period, to trigger a fresh commission payment.”

But mostly, it’s far less dramatic. “Two words spring to mind, and that’s misunderstanding and miscommunication.” 

Ramil says the more common complaints include lack of clarity around a fee, or a policy condition like a premium loading or exclusion that changed during underwriting but wasn’t clearly communicated back to the customer.

What counts as a complaint? 

The official line is that a complaint is an expression of dissatisfaction that relates to financial advice service, or the complaints handling process itself, where a response is either explicitly or implicitly expected.

The part that can be challenging, Ramil says, is the word ‘implicitly.’ Explicit dissatisfaction is easy to spot, a customer says outright they're unhappy. But implicit expectation is more of a judgement call: does a frustrated comment, or an unanswered question about a fee count? It’s why having thorough records and clear processes is vital.

“We tell organisations to have a good process, have a well-defined, structured, and repeatable complaints process for staff and contractors, to help them apply that definition consistently, but also to be able to tailor that process to their context, their service, their business model.”

Must-do reminders: 

• Record every complaint: the date it occurred and any action taken, whether that’s in a simple register or a Customer Relationship Management tool.
• Disclosure after two days: If a complaint takes longer than two working days to resolve, you’re required to provide complaints disclosure, including information about how the process works, what the customer can expect, and how they can access an independent dispute resolution service if they are unhappy with the outcome. 

Turning complaints into an advantage

“Complaints handling is a priority across all the sectors we oversee, not just financial advice. And we get it - we know that complaints are not always welcome, but complaints are actually a major opportunity to understand what might need to improve.”

He notes that the FMA’s own monitoring has found individual Advisers still have work to do when it comes to properly capturing complaints, a reminder that recording obligations aren’t always front of mind day-to-day. For larger organisations, complaint data can lead to valuable improvements not just for one business, but for the industry as a whole. 

“There could be trends and themes that can be picked up and translated back into how services and communications are improved. Complaints are really a treasure trove of insights.”

How Chubb Life handles complaints

What happens once a complaint lands with us? Chubb Life’s Customer Resolutions Manager, Deb Roughton, walks through the basics. 

“Advisers have good working partnerships with their customers, and if it’s something that can be resolved quickly and directly, they can do it straight away and don’t need to loop us in formally.” 

When it involves something bigger or a Chubb product or process, Deb says there are several avenues open to Advisers, including reaching out to Chubb’s Customer Care team, your key relationship consultant, or your BPM. This doesn’t have to be in writing, a phone call is enough to get things moving.

Every complaint that comes through is logged in Chubb’s system, with reports made every month to identify trends. 

“We evaluate the level of each complaint, and anything that's escalated, that’s where I get involved. My role is to look at things independently from the team that the complaint came through from. I review all the information to see if it's fair and reasonable and in accordance with the policy wording. There is a formal process before a customer can go to the ombudsman if they're still not happy with that outcome.”

A few practical tips for Advisers:

• Keep a record: if you and the customer can sort it out directly, there’s no need to involve Chubb formally, but keep all correspondence for your records. 
• Know your three avenues: customer care, your key relationship consultant, or your BPM - pick whichever fits the issue.
• No paperwork required: a phone call is enough to raise something with us,  it doesn’t need to be in writing.
• Flag it early if you’re unsure: if something feels like it could be brewing into a complaint, let your BPM know straight away so it can be tracked, or actioned if needed.
• Expect an independent check: anything escalated is reviewed separately from the team it came through, against the policy wording, before it would ever reach the Ombudsman.

While the FMA says complaints related to the use of AI tools have yet to reach their reports, Deb can see it becoming a trend.

“We're already seeing issues with AI leading people down the wrong path, not giving them the right information or the right legislation. We are also seeing the use of AI in written complaints, you can tell as they often have a similar tone and wording. That’s something I think we'll get more of, too.” 

Click here to find out more on Chubb Life’s complaints policy, process, and where to direct customers.