Internal Dispute Resolution Process

1. Our commitment

Morbanx is committed to providing mortgage-broking clients with a high standard of service. If at any time we have not met our obligations, or you are dissatisfied with the service we have provided, please tell us so that we can work with you towards a resolution.

We will endeavour to deal with your complaint promptly, thoroughly, fairly and without charge.

2. Who this process applies to

This Internal Dispute Resolution process applies to complaints made by mortgage-broking clients about credit assistance, mortgage-broking services or related conduct provided by Morbanx.

It does not govern complaints made by mortgage brokers about aggregation services. Aggregation-related concerns should be raised directly with Morbanx under the applicable aggregation arrangements.

3. How to make a complaint

You may make a complaint verbally or in writing. You do not need to use any particular form or use the word “complaint”. You may also have another person make the complaint on your behalf, provided they are authorised to do so.

Please provide as much relevant information as possible, including:

• your name and contact details;
• a description of the issue;
• the outcome you are seeking; and
• copies of any relevant documents or correspondence.

4. First contact

In the first instance, please contact Andrew Larcombe:

We will acknowledge receipt of your complaint within one business day, or as soon as practicable.

5. Escalation to the Complaints Officer

If Andrew Larcombe is unable to resolve your complaint to your satisfaction within five business days, we will escalate the complaint to the Complaints Officer. You may also contact the Complaints Officer directly.

There may be situations where the Complaints Officer is also your broker. This will not affect the ability to deal with your complaint effectively, fairly or appropriately.

6. How we will investigate

We may ask you for additional information to ensure that the complaint is properly understood and investigated.

Our review may include:

• considering the information and documents you provide;
• reviewing relevant file notes, records and communications;
• obtaining information from the broker, lender, service provider or other relevant party;
• considering applicable laws, regulatory requirements, policies and procedures; and
• assessing an appropriate outcome or remedial action.

7. Response timeframes

We will aim to resolve your complaint as quickly as possible.

Unless a shorter timeframe applies under law, we will provide you with a written response within 30 calendar days from the date the complaint was received.

The written response will explain the outcome of our investigation, the reasons for the decision and, where relevant, any action we propose to take.

If we are unable to provide a final response within the applicable timeframe, we will write to you explaining the reasons for the delay and advise you of your right to refer the complaint to the Australian Financial Complaints Authority.

8. Possible outcomes

Depending on the circumstances, an outcome may include:

• an explanation or further information;
• an apology;
• correction of information or records;
• assistance to address an administrative or service issue;
• reconsideration of a decision where appropriate;
• remedial action; or
• another outcome considered appropriate in the circumstances.

9. External Dispute Resolution

If you are not satisfied with our response, or we have not provided a response within the applicable timeframe, you may refer the complaint to the Australian Financial Complaints Authority (AFCA).

AFCA provides a free and independent external dispute resolution service for eligible financial complaints.

You may contact AFCA at any time. However, AFCA may ask that our internal dispute resolution process be completed before it considers the complaint further.

10. Accessibility and assistance

You may ask another person to assist you with your complaint, including a family member, friend, legal representative, financial counsellor or other authorised representative.

Please tell us if you need assistance because of language, literacy, disability, financial hardship or another circumstance. We will take reasonable steps to support accessible communication.

11. Privacy and confidentiality

We will handle personal information provided in connection with a complaint in accordance with our Privacy Policy and applicable law.

Information may be disclosed to Specialist Finance Group, relevant brokers, lenders, insurers, professional advisers, regulators, AFCA or other parties where reasonably necessary to investigate or resolve the complaint, or where disclosure is authorised or required by law.

12. No charge and no adverse treatment

There is no charge for making a complaint or using our internal dispute resolution process.

You will not be treated adversely merely because you have made a complaint in good faith.

13. Record keeping

We will maintain records of complaints, investigations, responses and outcomes in accordance with applicable legal, regulatory, licensee and record-keeping requirements.

14. About Morbanx

Morbanx means Morbanx Pty Ltd as trustee for the A R Larcombe Family Trust ABN 93 362 515 953. Morbanx Pty Ltd is a corporate credit representative of Mortgage Specialists Pty Ltd ABN 48 612 422 178, trading as Specialist Finance Group, Australian Credit Licence 387025.

15. Changes to this process

We may update this Internal Dispute Resolution process from time to time to reflect changes to our services, business arrangements, legal obligations or regulatory requirements.

The current version will be published on the Morbanx website and will state its effective date.