{
  "service": "Creditcrest Complaints",
  "version": "1.0.0",
  "not_a_decision": "This is a record of the dates and contents of a complaint under ASIC Regulatory Guide 271. It does not decide whether a complaint should be upheld, does not write the response and does not decide whether an issue is systemic. Creditcrest Technologies is not a credit provider, is not a credit assistance provider, and does not hold an Australian credit licence. Its software produces evidence; the licensee makes the decision.",
  "stores": "nothing",
  "events": {
    "received": "The complaint arrived, by any channel, spoken or written. `channel`, `kind`, `category`, `complainant`.",
    "acknowledged": "Receipt was acknowledged, verbally or in writing. `how`.",
    "information requested": "Hardship or postponement only: the lender asked for information to decide.",
    "information received": "The information asked for arrived.",
    "agreement reached": "Hardship or postponement only: the lender and the complainant agreed. Terms are then confirmed in writing.",
    "terms confirmed": "The agreed terms were confirmed in writing.",
    "delay notified": "An IDR delay notification: `reasons`, `afca: { rights, contact }`.",
    "response given": "The written IDR response: `outcome` (resolved | partially rejected | rejected), `afca: { rights, contact }`, `reasons: { issues, findings, detail }`.",
    "written response requested": "The complainant asked for the outcome in writing.",
    "referred to AFCA": "The complainant took the complaint to AFCA.",
    "closed": "The complaint was closed. `how`: resolved to satisfaction | explanation or apology | after response."
  },
  "kinds": {
    "standard": {
      "days": 30,
      "source": "standard",
      "words": "a standard complaint"
    },
    "default notice": {
      "days": 21,
      "source": "default_notice",
      "words": "a complaint involving a default notice"
    },
    "hardship": {
      "days": 21,
      "source": "hardship",
      "words": "a complaint involving a hardship notice"
    },
    "postponement": {
      "days": 21,
      "source": "hardship",
      "words": "a complaint involving a request to postpone enforcement"
    }
  },
  "channels": {
    "face to face": 1,
    "phone": 2,
    "email": 3,
    "web chat": 4,
    "online form": 5,
    "social media": 6,
    "referral from AFCA": 7,
    "letter": 8,
    "other": 8,
    "unknown": 9
  },
  "sources": {
    "complaint": {
      "cite": "ASIC RG 271.27 (enforceable)",
      "quote": "AS/NZS 10002:2014 sets out the following definition of ‘complaint’ at p. 6: [An expression] of dissatisfaction made to or about an organization, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required."
    },
    "credit_licensees": {
      "cite": "ASIC RG 271.29 (enforceable)",
      "quote": "Credit licensees’ IDR processes must cover ‘disputes in relation to the credit activities engaged in by the licensee’: see s47 of the National Credit Act."
    },
    "any_channel": {
      "cite": "ASIC RG 271.136",
      "quote": "The process should be flexible about how complaints are lodged and offer multiple lodgement methods—including telephone, email, letter, social media, in person, or online. Complaints do not need to be in writing—in some cases, insisting that complaints are in written form can be a disincentive to the complainant."
    },
    "acknowledge": {
      "cite": "ASIC RG 271.51 (guidance, not marked enforceable)",
      "quote": "A financial firm should acknowledge receipt of each complaint promptly. We expect that firms will acknowledge the complaint within 24 hours (or one business day) of receiving it, or as soon as practicable."
    },
    "idr_response": {
      "cite": "ASIC RG 271.53 (enforceable)",
      "quote": "An ‘IDR response’ is a written communication from a financial firm to the complainant, informing them of: (a) the final outcome of their complaint at IDR (either confirmation of actions taken by the firm to fully resolve the complaint or reasons for rejection or partial rejection of the complaint); (b) their right to take the complaint to AFCA if they are not satisfied with the IDR response; and (c) the contact details for AFCA."
    },
    "reasons": {
      "cite": "ASIC Regulatory Guide 271, RG 271.54 (enforceable)",
      "quote": "If a financial firm rejects or partially rejects the complaint, the IDR response must clearly set out the reasons for the decision by: (a) identifying and addressing the issues raised in the complaint; (b) setting out the financial firm’s findings on material questions of fact and referring to the information that supports those findings; and (c) providing enough detail for the complainant to understand the basis of the decision and to be fully informed when deciding whether to escalate the matter to AFCA or another forum."
    },
    "standard": {
      "cite": "ASIC RG 271.56 (enforceable), and its Note",
      "quote": "A financial firm must provide an IDR response to a complainant no later than 30 calendar days after receiving the complaint. … Note: Section 36 (Calculating time) of the Acts Interpretation Act 1901 is to be applied in construing the timeframes in RG 271. The timeframes begin on the day that the complaint is received, regardless of whether the day of receipt is a business day. As per s36, the timeframes do not include the day of receipt."
    },
    "default_notice": {
      "cite": "ASIC RG 271.86 (enforceable)",
      "quote": "If a complaint involves a default notice, the credit provider or lessor must provide an IDR response to the complainant within 21 calendar days."
    },
    "hardship": {
      "cite": "ASIC Regulatory Guide 271 Internal dispute resolution, RG 271.93 (enforceable)",
      "quote": "Where a complaint involves a hardship notice or request to postpone enforcement proceedings, the following maximum IDR timeframes apply: (a) the credit provider or lessor has 21 calendar days to consider and determine whether to agree to: (i) a change in the terms of the credit contract or lease for hardship (under s72 and 177B of the National Credit Code) …"
    },
    "urgent": {
      "cite": "ASIC Regulatory Guide 271, RG 271.92 (enforceable)",
      "quote": "Credit providers, credit service providers, lessors and unlicensed COI lenders must treat complaints involving hardship notices or requests to postpone enforcement proceedings as urgent matters."
    },
    "hardship_table": {
      "cite": "ASIC RG 271, Table 2 (credit-related complaints involving hardship notices or requests to postpone enforcement proceedings)",
      "quote": "If the credit provider or lessor does not have sufficient information about a hardship notice to make a decision, they must request the information no later than 21 calendar days after receiving the complaint. The complainant must provide the information within 21 calendar days of receiving the request. Once the credit provider or lessor has received the requested information, the credit provider has a further 21 calendar days to provide an IDR response. If the credit provider or lessor does not receive the requested information within 21 calendar days of requesting the information, the credit provider or lessor has 7 calendar days to provide an IDR response. … If agreement is reached about a hardship notice or request to postpone enforcement proceedings, the credit provider or lessor has 30 calendar days to confirm the terms or conditions in writing."
    },
    "delay": {
      "cite": "ASIC RG 271.65–271.66 (enforceable)",
      "quote": "First, there must be no reasonable opportunity for the financial firm to provide the IDR response within the relevant maximum IDR timeframe because: (a) resolution of the individual complaint is particularly complex …; and/or (b) circumstances beyond the financial firm’s control are causing complaint management delays … Second, before the relevant maximum IDR timeframe expires, the financial firm must give the complainant an ‘IDR delay notification’ that informs the complainant about: (a) the reasons for the delay; (b) their right to complain to AFCA if they are dissatisfied; and (c) the contact details for AFCA."
    },
    "five_days": {
      "cite": "ASIC RG 271.71 and 271.75 (enforceable)",
      "quote": "A financial firm does not need to provide an IDR response to a complainant if the firm closes the complaint by the end of the fifth business day after receipt because the firm has: (a) resolved the complaint to the complainant’s satisfaction …; or (b) given the complainant an explanation and/or apology when the firm can take no further action to reasonably address the complaint … A financial firm must provide a written IDR response, even where the complaint is closed by the end of the fifth business day: (a) if the complainant requests a written response; (b) if the complaint is about: (i) hardship …"
    },
    "systemic": {
      "cite": "ASIC RG 271.117 and 271.120",
      "quote": "A systemic issue is a matter that affects, or has the potential to affect, more than one consumer. … Financial firms must: (a) encourage and enable staff to escalate possible systemic issues they identify from individual complaints; (b) regularly analyse complaint data sets to identify systemic issues; (c) promptly escalate possible systemic issues to appropriate areas within the firm for investigation and action; and (d) report internally on the outcome of investigations, including actions taken, in a timely manner."
    },
    "record": {
      "cite": "ASIC RG 271.179",
      "quote": "Firms must record all complaints that they receive. They must have an effective system for recording information about complaints. The system must enable firms to keep track of the progress of each complaint."
    },
    "data_reporting": {
      "cite": "ASIC IDR data reporting handbook (1 December 2025), paras 9–11 and Table 2; ASIC Corporations (Internal Dispute Resolution Data Reporting) Instrument 2022/205",
      "quote": "Financial firms must lodge an IDR report with ASIC every six months. The reporting periods are: 1 January to 30 June; and 1 July to 31 December. … [Due date] 31 August … Last day of February.",
      "note": "ASIC’s page on IDR data reporting says all Australian credit licensees must report, and that firms first submit under the updated handbook in the July to August 2026 window, covering complaints received or closed from 1 January 2026. Element names and the channel, status, complainant-type and yes/no codes below were read from the handbook; the product, issue and outcome code lists were not transcribed, so those columns carry the codes the lender supplies and are not checked against ASIC’s lists."
    }
  },
  "endpoints": {
    "POST /v1/complaints/clock": "{events, asAt, reference?} — one complaint replayed",
    "POST /v1/complaints/register": "{complaints: [{reference, events}], asAt, window?, threshold?} — the register with systemic grouping",
    "POST /v1/complaints/extract": "{complaints: [{reference, events, report}], period: \"YYYY-H1\"|\"YYYY-H2\", brand} — the IDR data extract"
  }
}