Internal Disputes Resolution (IDR) processes

This section describes our business approach to the management of complaints and the framework within the business that supports this.

Our IDR processes are aligned with our membership of the External Dispute Resolution (EDR) scheme which is managed by Australian Financial Complaints Authority (AFCA), previously known as Credit and Investment Ombudsman (CIO)

We adopt the definition of ‘complaint’ in AS ISO 10002-2006, namely ‘an expression of dissatisfaction made to an organisation, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected’. This means we will treat informal complaints seriously and refer them to IDR unless they are resolved by the end of the next business day.

Receiving complaints

Complaints can be lodged by contacting Narelle Davies, the Complaints Officer by:

  • telephoning (07) 55243133
  • e-mailing
  • writing to PO Box 846, Banora Point NSW 2486
  • or by speaking to any representative of our business who will refer complainants to the Complaints Officer.

Complaints must be resolved as expeditiously as possible.

Complainants must be:-

  • treated with respect and provided with all documentation and evidence in support of their concerns;
  • informed of the complaints handling process, including the avenues for further review of decisions such as an External Dispute Resolution Scheme (EDRS); and
  • informed of decisions and the reasons for those decisions.
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Complaints handling officer

The Complaints Officer reports directly to the business owners. The Complaints Officer will their best to consider complaints fairly and equally with due regard to our EDR guidance. If they are unable to resolve a complaint, we will consider seeking outside assistance to resolve the dispute. I will review these procedures at least annually.

Investigating complaints

The Complaints Officer will review the complaint carefully and promptly, taking such steps and reviewing such documents as a reasonable person would do.

Responding to complaints within appropriate time limits and referring unresolved complaints to an EDR scheme

The Complaints Officer will provide a written ‘final response’ to the complainant within 45 days, which states:

  • the final outcome of the dispute at IDR
  • the right to take their dispute to EDR (no matter what the result of the investigation was at IDR)
  • the name and contact details of your EDR scheme.
  • If the Complaints Officer is unable to give a final response within the specified period, the Complaints Officer will, before the end of the period:
  • inform the complainant of the reasons for the delay
  • advise the complainant of their right to complain to EDR
  • provide the complainant with the name and contact details of your EDR scheme.

Annual Review

The IDR process will be reviewed annually by our complaints officer. The review will ensure continuing compliance with applicable laws, the requirements of any Licence issued to our business and relevant industry standards. The review will also ensure the guidance remains applicable to our business and continues to achieve its purpose.

Any amendments to the IDR process will be communicated to staff via email and updated in our internal guidance document


Where a complaint or dispute is resolved to the customer’s satisfaction by the end of the next business day from when the complaint or dispute was received, we understand that we will not be required to apply the full IDR process with respect to capturing and recording the complaint or dispute and providing a final response on resolution of the complaint.

However, if a complaint or dispute is received and not resolved by the next business day, the incident must be recorded as a complaint.

If the complaint discloses a systemic issue, the Complaints Officer will immediately bring the matter to the attention of the business owners.

The types of remedies available for resolving complaints or disputes

If a complaint is justified, the Complaints Officer will recommend a solution comprising one or more of the following:

  • an apology
  • compensation
  • vary contractual obligations
  • a free service.
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Guiding Principles

Visibility – We will take reasonable steps to ensure customers know about the existence of our IDR procedures and how to make a complaint or apply for hardship or postponement. This information will be readily available, not just at the time a consumer wishes to make a complaint or dispute. All staff who deal with customers, not just complaints or disputes handling staff only, should have an understanding of our IDR procedures.

Objectivity – We will address each complaint in an equitable and objective manner. Where possible, the complaint should be investigated by staff not involved in the subject matter of the complaint.

Charges – The IDR procedures are free of charge.

Confidentiality – We will keep information confidential.

Customer focused approach – We will be helpful, user friendly and communicate in plain English, showing our commitment to resolving complaints.

Commitment – We are actively committed to efficient complaint handling. Our procedures are published on our website.

Analysis and Evaluation of Complaints – All complaints will be classified and then analysed to identify systemic recurring and single incident problems and trends.


External Dispute Resolution

If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority, or AFCA. AFCA provides fair and independent financial services complaint resolution that is free to consumers.



Telephone: 1800 931 678 (free call)1

In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001