This guide outlines what information paid representatives should provide to AFCA when lodging a complaint, including any specific information AFCA requires for different types of complaints. This guide is also useful for complainants who need to share AFCA’s requirements with their paid representative.  

If the information required is not sent, or our expectations of paid representatives are not met, it may be appropriate for AFCA to refuse to consider the complaint further under Rule C.2.2(g).  

This guide is not exhaustive and will be updated regularly. If you have a complaint about a topic that is not listed below, or you have questions about the information we require, please contact info@afca.org.au.

Making a complaint

Before making a complaint to AFCA, paid representatives should first complain to the financial firm through their Internal Dispute Resolution (IDR) process. You can search for the IDR contact information of a financial firm here.

We expect paid representatives to only make a complaint with AFCA after they have gone through the IDR process. If the paid representative is unable to resolve the issue with the financial firm directly, they can then make a complaint with AFCA.

AFCA strongly prefers paid representatives to use our online complaint form as their primary method of lodgment to support the efficient handling of complaints.

Information required for all complaints

Please provide:  

• The complainant’s name and contact details, including their address, telephone number and email address  
• Specific details, all key issues and all alleged errors or breaches by the financial firm with supporting documentation.  It is not acceptable to include only a generic template response alleging errors not specific to the complaint at hand  
• A signed and dated AFCA Agent Authority form
• If the complainant is a company, a signed and dated resolution of directors’ form, signed by the directors appointing the Paid Representative as the company’s representative at AFCA   
• Documentation to show a complaint has previously been raised with the financial firm and an explanation of why the complaint remains unresolved  
• If received, the financial firm’s IDR or EDR response  
• Details of the outcome the complainant is seeking which aligns with any AFCA approach.  

Along with the information required for all complaints, paid representatives should provide additional information by complaint type.

Information required by complaint type 

Contents 

• Responsible lending  
• Default listing/credit reporting 
• Financial difficulty  
• Motor vehicle / pleasure craft insurance 
• Home building and contents insurance 
• Consumer credit insurance 
• Travel / ticket insurance 
• Add-on insurance 
• GAP Insurance 
• Tyre and Rim Insurance 
• Extended Warranty 

Responsible lending  

Please provide:  

• A completed AFCA Statement of Financial Position form outlining the complainant’s financial position at the time any disputed credit application was approved 
• Supporting documentation to show the complainant’s financial position at the time that any disputed credit application was approved. This includes account statements or other information showing all existing liabilities and payslips or Centrelink statements showing income 
• A copy of the complainant’s complete tax assessment (not just the Notice of Assessment) from the year the disputed credit was approved – the TFN should be redacted   
• Information confirming what the complainant is seeking to resolve the complaint, which includes any claim for loss and supporting documentation to show how the loss is calculated. The claim for loss should be in line with AFCA’s approach to responsible or appropriate lending.  

If the credit facility refinanced an existing facility, please also provide:  

• Full details of the previous debt including the amount discharged  
• Documentation to show the funds have been repaid (i.e. the final statement)  
• Documentation to show the interest rate at the time of discharge.  

If the credit disputed was a business facility, please also provide:  

• Documentation provided to the financial firm by the complainant when applying for the credit including business plans, budget forecasts, statement of income and expenses, wage slips and tax returns.   

Back to top 

Default listing/credit reporting  

Please provide:  

• A current, complete copy of the complainant’s credit file with any government identifiers redacted  
• Clear reasons why the default listing, credit enquiry, repayment history information or other credit file entry is being disputed, with supporting documents  
• Correspondence exchanged between the parties and any other records of contact.  

If the complainant includes a claim that an address is incorrect, please provide:  

• An address history for the relevant time  
• Information to show the financial firm was on notice  
• Relevant supporting documents.  

If claiming compensation, please provide:  

• Information to show how they determined the amount of their claim  
• A direct causal connection between the error  
• The amount claimed . 

If the reason for disputing the listing is financial hardship, please provide:

• A completed Statement of Financial Position Form outlining the complainant’s financial position at the time they were experiencing financial hardship
• Correspondence between the parties showing that the complainant raised their financial difficulty with the financial firm at the time.

Back to top 

Credit enquiry  

If the complainant reports identity theft, please provide:  

• Information and documents supporting how their identity was stolen and/or used fraudulently (e.g. a police report).  

Back to top 

Financial difficulty   

In case of financial difficulty, please provide:  

• Records of correspondence to the financial firm that show what assistance was requested, and when  
• Details of why the complainant believes the financial firm has not met its obligations  
• For an individual, a completed AFCA Statement of Financial Position form showing full and accurate details of the complainant’s current circumstances 
• For a business, information relevant to the request being made of the financial firm
• Details of how the complainant expects their circumstances to change to enable them to make the required repayments
• A realistic repayment proposal that will see the debt, including any arrears, repaid within a reasonable timeframe
• If the complainant cannot afford a repayment arrangement, please provide details of their alternative proposal (for example, a timeframe for sale of an asset).  

Back to top 

Motor vehicle / pleasure craft insurance  

Please provide:  

• Cost of repairs (quotation)  
• Supporting colour photographs of the asset.  

If challenging method of repair:

• A detailed explanation and supporting information demonstrating why the alternate is required.  

If challenging method of settlement, relevant supporting information such as:  

• Evidence of the fair market or insured value (jurisdiction depending) of the asset immediately prior to the loss  
• Assessment of salvage amount  
• Relevant state legislation and how this applies to complainant’s circumstances.

If challenging claim liability:

• A written version and detailed diagram depicting how the complainant says the accident occurred and why they are not liable

Back to top 

Home building and contents insurance  

Please provide:  

• Cost of repairs (quotation)  
• Supporting colour photographs of the asset  

If disputing the decline or scope of a claim: 

• Expert report(s) detailing the cause of damage and extent of damage.  

If a complaint involves concerns of ground movement or flooding:

• An appropriately qualified expert (such as an engineer) detailing the cause and extent of damage.  

If disputing loss of rent:  

• Copy of rental agreement  
• Copy of rental ledger  
• Copy of bond deposit  
• Copy of inspection reports  
• Copy of any action taken against tenant (such as through Administrative Tribunals)  
• Explanation of what dates complainant says rent should be paid from and to.   

Back to top 

Consumer credit insurance  

Please provide:  

• Details of when the policy commenced, including how it was purchased
• Details of when the complainant says they became aware of the policy and/or their loss.

If disputing policy inception:   

• Supporting information such as recollections of  the conversation(s) at the time the credit facility commenced  
• An explanation about what steps consumer took to remedy issue prior to AFCA involvement.  

If disputing claims decline – supporting information such as:   

• Employment termination records   
• Medical records  
• Credit facility repayment history  

If its alleged alternative insurance was held elsewhere, the following must be provided: 

• was this discussed with the sales agent? If yes,  
• what was specifically discussed about the alternative insurance(s)?  
• what was the agent’s response about the alternative insurance(s)?  
• confirm if the complainant had any events over the policy period which may be claimable and if so, confirm the event and duration. 

Back to top 

Travel / ticket insurance  

Please provide:  

If disputing claim decline – supporting information such as:   

• Medical records  
• Evidence of ownership – for instances valuations for jewellery, receipts  
• Colour photographs of the asset(s).  

Timelines from of events including:  

• Date travel purchase – if over multiple instalments, all relevant dates  
• Date policy purchased  
• Date travel commenced / was due to commence  
• Date of incident giving rise to the claim  
• Date claim declined  
• Any other dates relevant for the consumer.  

Back to top 

Add-on insurance  

Please provide:  

• Details on why the add-on insurance product(s) is/are in dispute  
• If misleading conduct and/or pressure sales are being alleged, please explain in detail how this occurred and how the complainant relied on it  
• The salesperson(s) name (or description) who sold the add-on insurance(s)  
• How the policy was sold e.g., in person, online or in branch  
• A detailed statement from the complainant about their recollections of add-on insurance discussions up to and including the point of signing the contract  
• Details (and copies, if possible) of the document(s) the complainant signed, relating to add-on insurance  
• Details of if and how (e.g., via post, in person etc) the complaint received their add-on insurance policy documents, including the product disclosure statement (PDS)
• Details of when the complainant says they became aware of the policy and/or their loss.

If possible, please provide:  

• A copy of the loan contract the add-on insurance was financed into (if applicable), showing the amounts financed, interest rate and loan term. If the loan was paid out early, provide documentation in support 
• If the paid representative has read the PDS and considers the complainant had limited or no cover, please explain in detail why the paid representative considers this, with reference to the PDS and supporting evidence  
• Details of any claims made on the policy. If there were, please explain in detail why a refund of the premium is being sought   
• The resolution sought by the complainant.  

Back to top 

GAP Insurance 

Confirm if the vehicle was comprehensively insured during the GAP Insurance policy period and if so, please provide:  

• The type of cover (agreed value, market value)  
• If there was a ‘new for old’ benefit in a total loss claim  
• Supply the certificates of insurance and applicable PDS covering the full period of the GAP Insurance policy 
• Any supporting evidence (e.g., market value data and loan statements) to demonstrate there would be little to no GAP over the loan term
• Details of when the complainant says they became aware of the policy and/or their loss.

Back to top 

Tyre and Rim Insurance  

Confirm if the vehicle was comprehensively insured during the GAP Insurance policy period and if so, please provide: 

• The certificates of insurance and applicable PDS covering the full period of the Tyre and Rim Insurance policy, demonstrating the tyres and/or rims were covered
• Details of when the complainant says they became aware of the policy and/or their loss.

Back to top 

Extended Warranty  

Confirm if the vehicle had any manufacturer or statutory warranty provided at point of sale. If so, please provide supporting documents. Please also provide details of when the complainant says they became aware of the policy and/or their loss.

Back to top