The complaints process at work...
Matt (the customer) is unhappy with the late fees he has been charged on his (BNPL) account. He does not think that he received enough
information or notification about them.
Matt checks the BNPL Code of Practice website. He can see that his BNPL provider is a Code Compliant Member of the Code.
He reads the '9 Key Commitments' included in the Code. He thinks his BNPL provider is in breach of the Code because they did not show clear and prominent information about the fee amounts or how they will be charged.
He knows that there are three possible stages to the complaints process (see image above).
Matt makes a complaint to his BNPL provider and asks them to waive the fees he has been charged - this is 'Stage 1'.
In the BNPL provider's formal response to his complaint, they state that they will not waive the late fees, as they believe Matt received appropriate disclosure about them. Matt is also sent details about how to make a complaint to the Australian Financial Complaints Authority (AFCA), if he is unsatisfied with the BNPL provider's resolution – this is 'Stage 2'.
Dissatisfied with the outcome of his complaint resolution, Matt chooses to lodge a complaint with AFCA. AFCA reviews Matt's case and provides him with a determination stating that the BNPL provider has not breached the Code or their rules.
Matt still believes the BNPL provider has breached the Code and chooses to escalate his complaint to the independent BNPL Code Compliance Committee (CCC) - this is 'Stage 3'.
The CCC will determine whether his complaint is a breach, and will take appropriate action as required. If the CCC determines that the Code of Practice has been breached, they can take action against the provider (using their delegated powers).