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DISP 1.5 Record keeping and reporting

Making and retaining records of complaints


A firm must make and retain records of complaints subject to DISP 1.4-DISP 1.6 for a minimum period of three years from the date of its receipt of the complaint.


The records required by DISP 1.5.1 R are for the purposes of monitoring by the FSA and also to ensure that the firm is able to cooperate, as necessary, with the Financial Ombudsman Service. They should include:

  1. (1)

    the name of the complainant;

  2. (2)

    the substance of the complaint; and

  3. (3)

    any correspondence between the firm and the complainant, including details of any redress offered by the firm.

DISP 1.5.3G

DISP 4.2.3 R covers record keeping by VJ participants.

Reporting complaints to the FSA


A firm must provide the FSA, twice a year, with a report in the format set out in DISP 1 Annex 1R which contains (for the relevant reporting period) information about:2

  1. (1)

    the total number of complaints subject to DISP 1.4 to DISP 1.6 received by the firm, broken down according to the categories and in respect of each of the generic product types described in DISP 1 Annex 1R which are relevant to the firm;2

  2. (2)

    the total number of complaints subject to DISP 1.4 - DISP 1.6 closed by the firm:

    1. (a)

      within four weeks or less of receipt;

    2. (b)

      within four to eight weeks of receipt; and

    3. (c)

      more than eight weeks after receipt; and

  3. (3)

    the total number of complaints subject to DISP 1.4 - DISP 1.6 outstanding at the end of the reporting period.


Where a complaint could fall into more than one category, the complaint should be recorded in the category which the firm considers to form the main part of the complaint.


For the purposes of DISP 1.5.4 R:

  1. (1)

    the relevant reporting periods are from 1 April to 30 September and from 1 October to 31 March each year; and

  2. (2)

    reports are to be submitted to the FSA within one month of the end of the relevant reporting period.

Reporting: when is a complaint closed?


For the purpose of DISP 1.5.4 R (2), a closed complaint is a complaint:

  1. (1)

    where the firm has sent a final response; or

  2. (2)

    where the complainant has indicated in writing acceptance of the firm's earlier response; or

  3. (3)

    where DISP 1.4.9 R applies, provided that the complainant has not responded to the firm within eight weeks of the written response referred to in that rule.

DISP 1.5.8G

Where a complaint is reported as closed under DISP 1.5.7 R (3) because the complainant has not replied to the firm within eight weeks of a written response which meets the requirements in DISP 1.4.9 R, the firm may treat the date of that response as the date when the complaint was closed for the purposes of the reporting requirements in DISP 1.5.4 R (2).

Reporting: complaints subject to the FSAVC review

DISP 1.5.9G

Where a complaint is subject to the FSAVC review, the record keeping and reporting requirements in DISP 1.5.1 R and DISP 1.5.4 R apply only where the complainant is dissatisfied with the outcome of that review (under DISP 1.4.15 R and DISP 1.4.16 R).

Method of submission of reports

DISP 1.5.10R

A report under this section must be given or addressed, and delivered, in the way set out in SUP 16.3.6 R - SUP 16.3.16 G (General provisions on reporting), except that:

  1. (1)

    instead of the firm's usual supervisory contact, the report should be given to or addressed for the attention of the Contact, Revenue and Information Management of the FSA; and

  2. (2)

    in addition to the methods of submission of reports in SUP 16.3.9, a firm may submit a report under this section through, and in the electronic format specified in, the FSA's Complaints Reporting System.

DISP 1.5.10AR

A firm that has started but intends to stop submitting reports in electronic format under DISP 1.5.10 R (2) must first notify the Contact, Revenue and Information Management of the FSA in writing of this intention.


Failure of electronic submission

DISP 1.5.10BR

1If a firm is unable to submit a report in electronic format because of a systems failure of any kind, the firm must:

  1. (1)

    submit its report under this section through one of the alternative methods of submission or reports in SUP 16.3.9 R; and

  2. (2)

    notify the FSA, in writing and without delay, of that systems failure.

Notification of contact point for complainants

DISP 1.5.11R

For the purpose of inclusion in the public record maintained by the FSA, a firm must:1

  1. (1)

    provide the FSA, at the time of its authorisation, with details of a single contact point within the firm for complainants; and1

  2. (2)

    notify the FSA of any subsequent change in those details when convenient and, at the latest, in the firm's next report under DISP 1.5.4 R.1

DISP 1.5.12G

The contact point can be by name, job title or department and may include, for example, a helpline telephone number.