The MFAA has warned that fresh guidance from AFCA shows how routine process failures can escalate into serious complaint risks for brokers.
The Mortgage and Finance Association of Australia (MFAA) has unpacked the Australian Financial Complaints Authority’s new Systemic Issues Insights report, explaining how its findings on process breakdowns should prompt a close look at how client files are handled from first contact through to settlement and beyond.
AFCA’s report draws on complaint data to identify recurring weaknesses in financial firms’ operations, from poor complaint handling to breakdowns in hardship support.
A recurring theme in the report is that problems often do not arise due to a business lacking policies or procedures, but rather due to the fact that day‑to‑day processes do not operate as designed or fail to deliver fair customer outcomes.
In response, the MFAA is urging brokers to move beyond a tick-the-box approach and regularly test whether what occurs on the ground matches what is on paper.
“Having documented processes is important, but they should also be reviewed regularly to ensure they are delivering positive client outcomes. Regularly reviewing how client information is recorded, recommendations are documented, applications are managed and issues are escalated can help ensure consistent service and positive client outcomes,” the MFAA said.
“The key question is not just whether a process exists, but whether it is delivering the right result for clients.”
Complaints as a diagnostic tool
AFCA’s report found that complaint data is often the first place emerging issues appear, long before they are flagged in formal audits or regulatory reviews.
Reflecting this, the MFAA encouraged businesses to treat complaint records as a valuable source of intelligence rather than a compliance obligation.
“Complaints can highlight areas where communication, client expectations or internal processes may need improvement. Recording complaints, responding clearly and looking for recurring themes can help identify issues early and support continuous improvement,” the association said.
By building structured logs of complaints, the MFAA said brokerages could identify recurring themes and accordingly adjust their systems.
Communication, hardship, and vulnerable clients
AFCA also listed poor communication during key stress points – like lender delays, valuation disputes, and hardship applications – as a key driver of dissatisfaction and disputes.
In response, the MFAA placed strong emphasis on timely and proactive communication throughout the client journey.
“Clients should understand what is happening, what the next steps are and any factors that may affect their application,” the MFAA said.
The report further underlined the need for robust practices around vulnerability and financial hardship.
While lenders are responsible for formal hardship decisions, the MFAA said that brokers were often closest to the client and best placed to recognise when someone was struggling.
“Brokers can help by identifying clients who may need support, encouraging early engagement with their lender and helping them navigate available assistance options,” it said.
Technology help – and harm
AFCA said that a growing share of complaints across financial services now stem from technology and automation.
The MFAA said that digital tools were critical for efficiency but warned that they could amplify risk if left unchecked.
“Brokers should regularly review automated communications, CRM workflows, AI-generated content and outsourced work to ensure they remain accurate and appropriate,” the MFAA said.
“Technology can support good client outcomes, but professional judgement remains essential.”
[Related: MFAA warns investor tax shake-up could sideline FHBs]
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