Complaints handling is treated as a support problem and regulated as a governance one. The gap between those two views is where firms get into trouble, because the rules do not care which channel the message arrived on or whether the agent thought it was serious.
The definition is wider than firms assume
Across most regimes the working definition is close to this: any expression of dissatisfaction, oral or written, justified or not, about the firm's provision of a service, where the person is claiming to have suffered or may suffer a loss. Read it slowly. Oral counts. Unjustified counts. A potential loss counts. A message on live chat counts, and so does a public post the firm becomes aware of in some regimes.
That definition catches most of what a support desk handles on a busy day: a rejected withdrawal, a stop loss that filled worse than expected, a swap charge the client did not know about, a verification request the client thinks is unreasonable. The firm does not get to decide these are not complaints because it believes it did nothing wrong. It decides whether to uphold them, which is a different question answered later, in writing.
What the clock actually requires
The pattern is consistent even though the periods differ by jurisdiction. On receipt the firm must acknowledge, in writing, within a short defined period, and tell the client who is handling it. It then investigates, and must either resolve the matter or send a final response within a longer defined period. If it cannot meet that deadline it must write again explaining why and when it expects to conclude. At the end the client must be told, in writing, of any external escalation route available and the time limit for using it.
Two consequences follow. The receipt date has to be captured accurately, which means the complaint has to be recognised at the moment it arrives rather than when it reaches compliance three days later. And the person investigating should not be the person complained about, which for a small firm means the complaint moves out of the support queue rather than being resolved inside it.
Response deadlines, acknowledgement periods and escalation rights are set by each regulator and change over time. Read the rules that apply to your entity and take advice on them. Nothing here is a substitute for that.
The final response letter
This is the document the regulator reads. A usable one states what the client complained about in the firm's own words, what was investigated, what evidence was reviewed, the conclusion, whether the complaint is upheld in whole or in part, any redress offered, and the escalation route with its deadline. Redress that is offered should be paid, and the payment recorded against the complaint file.
The common defects are predictable. No clear statement of the complaint, so nobody can tell later what was actually decided. Evidence referenced but not retained, particularly platform logs and chat transcripts. Redress offered informally over chat and never recorded. And the escalation route omitted, which in some regimes restarts the client's clock entirely and turns a closed matter back into an open one.
Evidence retention deserves its own attention. A dispute about execution is decided on order and tick records, and those records need to survive long enough to be produced, which is why retention periods and complaints procedures are written together. Execution disputes in particular turn on whether the firm can show its execution arrangements were applied.
Escalation, and what the offshore reality is
Where a licensed entity is in scope, the client can usually take an unresolved complaint to a statutory or industry ombudsman, whose decision may bind the firm up to a limit. The firm pays a case fee in many schemes regardless of outcome, which is a real incentive to resolve well internally. The mechanics vary widely, and are described in financial ombudsman schemes.
For an entity registered in a territory with no such scheme, there is no ombudsman, and the honest thing is to say so in the terms rather than imply otherwise. What replaces it in practice is the card scheme dispute process. A client with no regulatory route who paid by card files a chargeback instead, and chargebacks carry consequences for the firm's merchant account that a complaint never would. Firms that handle complaints poorly on the offshore side tend to discover this through their acquirer, as covered in chargeback ratio thresholds.
The register and the pattern it shows
Every complaint goes into a register with the date received, the client, the category, the outcome, the redress and the date closed. Regulators ask for it during supervision, and several regimes require periodic returns summarising volumes by category.
The register earns its keep internally too. Categorise properly and it stops being a compliance chore and starts telling you where the product is broken. Thirty complaints about withdrawal delays in a month is not thirty support tickets, it is a payments problem. A cluster about slippage after news is a risk or liquidity problem. Root cause review is required in some regimes and useful in all of them, and it only works if the categories were chosen for analysis rather than for tidiness. Keeping the register inside the same system as the client record, the ticket history and the audit trail is what makes that analysis possible without a data project.
"Every complaint we lost badly started the same way: a support agent solved it kindly, closed the chat, and logged nothing."
— Roman Onta, Executive Director, SINGUARD
Key Takeaways
- A complaint is any expression of dissatisfaction about the service where loss is claimed or possible, including oral messages and ones the firm believes are unjustified.
- Acknowledge in writing on receipt, investigate away from the person complained about, and issue a final response within the period the regime sets.
- The final response must state the complaint, the conclusion, any redress and the external escalation route with its deadline.
- Where no ombudsman covers the entity, clients escalate through card chargebacks instead, which damages the merchant account rather than the compliance file.
Frequently Asked Questions
Does a message on live chat count as a complaint?
In most regimes yes. The definition covers oral and written expressions of dissatisfaction about the service where the client claims a loss or may suffer one, regardless of channel. That means front line staff need a way to flag one at the moment it arrives, because the response clock starts on receipt, not on escalation.
Who inside the firm should investigate a complaint?
Someone independent of the matter complained about, with authority to settle. In a small firm that usually means the compliance function or a director rather than the support agent who handled the original conversation. The point is that the person deciding is not defending their own work.
What if the firm cannot meet the final response deadline?
Write to the client before the deadline explaining why the investigation is not complete and when you expect to conclude, and keep the correspondence on the complaint file. Silence past the deadline is a breach in its own right and, in several regimes, gives the client an immediate right to escalate.
About the Author
Roman Onta is an Executive Director at SINGUARD. He builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals side by side with his brother Alex Onta, and he helped on the design of eTrader, the division Alex built and leads. His ground is worldwide payment processing, AML compliance and the corporate structures brokers are built on, work the two of them carry together, shaped by executive roles in the UAE and international corporates. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.