SD-15.16 — Complaint & Client-Case Management

Business Domain: BD-15 Distribution, Product & Client Management (Commercial) · Applies: BOTH

Purpose

The regulated handling of client and investor complaints and cases — acknowledging a complaint, investigating it, issuing the final response within the regulated deadline, providing the Financial Ombudsman Service referral rights, and retaining the records — together with complaint root-cause analysis: categorising complaints by cause, trending them, and identifying the recurring or systemic problems to put right. SD-15.16 is a first-line conduct control, prescribed by the FCA DISP sourcebook and raised in standing by the UK Consumer Duty — both already cited across the OpenIM model. It is wider than the closing of a single complaint: the value of the capability is the loop from individual case to root cause to systemic remediation.

It is not SD-15.13 Client Relationship Management & Servicing — SD-15.13 handles unregulated client queries, requests and the commercial relationship; a query SD-15.13 cannot resolve, or an expression of dissatisfaction that meets the regulatory definition of a complaint, is handed to SD-15.16. BIAN carries this as two discrete service domains — Customer Case Management and Case Root Cause Analysis; OpenIM models it as one Service Domain with root-cause analysis as a Service Operation, consistent with OpenIM’s deliberately shallower hierarchy.

Service Operations

Handle formal complaints — acknowledge a complaint, investigate it, issue the final response within the regulated deadline, and provide the Financial Ombudsman Service referral rights and the records retention.
Manage client cases and disputes — own and progress the client and investor cases and disputes that are not point-of-sale complaints — the case workflow, ownership and resolution.
Run complaint root-cause analysis — categorise complaints and cases by underlying cause, trend them, and analyse the cause behind the volume.
Identify and remediate systemic problems — identify the recurring or systemic problems the root-cause analysis surfaces, and drive their remediation across the responsible parts of the firm.
Produce complaints management information — produce the complaints MI and the regulatory complaints return for the regulator and the governing bodies.
Feed conduct and outcomes evidence — feed the complaints MI, the root-cause findings and the outcomes evidence to the corporate conduct function.

Inputs and outputs

Inputs: the client and investor complaints and dissatisfaction handed from SD-15.13; the regulatory definition of a complaint and the DISP deadlines; the case and complaint history; the advice, product and servicing records the investigation draws on.
Outputs: the final responses, the complaint and case records, the root-cause findings, the systemic-remediation actions, and the complaints MI and regulatory return — consumed by the complainant, by SD-14.2 Corporate Compliance & Conduct (the complaints MI and RCA findings), by the governing bodies, and by the Financial Ombudsman Service.

Entities

Consumes: E-01 Legal Entity (the complainant client / investor); the SD-15.13 client and investor complaints and dissatisfaction handed.
Owns: E-35 Complaint Record — the regulated complaint record: the complaint, the acknowledgement, the investigation, the final response, the FOS-referral note, the redress, the root-cause classification and the systemic-finding flag. The FCA DISP record an inspection runs against, and the Consumer-Duty outcomes-evidence record. The unregulated client query, request or commercial dispute that does not meet the regulatory definition of a complaint sits on SD-15.13’s client-servicing case record; E-35 is the regulated subset.

Standards

The FCA DISP (Dispute Resolution: Complaints) sourcebook — the prescribed complaint-handling process, the final-response deadline and the records requirement.
The UK Consumer Duty — the standing obligation to act on complaints and outcomes evidence.
The Financial Ombudsman Service referral regime — the referral rights and the eligible-complainant scope.
BIAN’s Customer Case Management and Case Root Cause Analysis service domains — the structural precedent OpenIM consolidates into one Service Domain.

Open extensions

The root-cause-analysis and systemic-remediation sub-model.
The boundary with SD-14.2 — first-line case handling and RCA versus second-line conduct oversight — to full depth.