DISP 1 (complaints data flow)

DISP 1 governs complaints handling. Under FSMA s.39, the principal is the regulated firm for AR-originated complaints, and the principal’s DISP 1 obligations apply. The AR is the operational point of receipt; the principal is the FCA-facing complaint owner.

The product’s data model and reporting flow encode this relationship.

The legal position

Section 39 makes the principal responsible for AR conduct within scope of the appointment. DISP 1 obligations attach to the regulated firm, which for AR-originated complaints is the principal. Three operational consequences:

The AR records the complaint at the point of receipt, but the complaint is the principal’s complaint for regulatory purposes.
The principal owns FCA reporting obligations under DISP 1.10.
The Financial Ombudsman Service has jurisdiction over the principal, not the AR. An ombudsman award is enforceable against the principal.

Operational independence between AR and principal is not relevant to the regulatory position. The principal is the regulated firm regardless of the AR’s commercial structure or independence from the principal’s operations.

How the product handles AR-originated complaints

The complaint object is structurally a child of the principal (the tenant) with an originating_ar_id reference. Fields the product captures at point of receipt:

Complainant identifiers (within data minimisation rules).
Originating AR.
Complaint category against a controlled taxonomy.
Vulnerable customer indicators (FG21/1 outcome breakdown; see Vulnerable customers).
Receipt timestamp.
Final response timestamp.
Outcome (upheld, partly upheld, not upheld).
Redress amount where applicable.
Whether the case proceeded to the Ombudsman.

The AR-side surface allows the AR to log the complaint at receipt and attach evidence. Once logged, the complaint enters the principal’s complaint queue with the AR retaining read access on its own record.

DISP 1.10 reporting

DISP 1.10 requires firms to submit a half-yearly complaints return covering volumes, categories, and outcomes. The return is at the regulated-firm level, which means AR-originated complaints aggregate at the principal level. The product:

Aggregates all complaints across the AR network into the principal’s half-yearly return shape.
Surfaces the AR-by-AR breakdown on the principal home page so the compliance officer can see which ARs are driving complaint volume before the return is filed.
Holds the underlying record set against the SYSC 9 retention floor; see SYSC 9.
Produces a draft return preview at the right point in the calendar (Q2 and Q4 close); submission is documented as a future API integration.

The principal home page tile that shows complaints is calibrated to the half-yearly return calendar, not to a rolling-12-months window, because the regulatory deadline drives the operational rhythm.

Vulnerable-customer outcome breakdown

DISP 1 reporting overlays with FG21/1 expectations on outcome equivalence for vulnerable customers. The complaint object captures a vulnerable-customer outcome breakdown per complaint:

Was the customer flagged as potentially vulnerable at intake.
Did the AR or principal record adjustments to the handling of the complaint.
Was the outcome (upheld rate, redress level) consistent with the firm’s outcome equivalence target.

This data feeds the vulnerable-customer MI tile on the principal home page; see Vulnerable customers for the roll-up logic.

Complaint object versus breach object

The product keeps complaint and breach objects distinct because the regulatory pathways diverge:

A complaint may never trigger a SUP 15 notification, even if upheld with redress.
A SUP 15 notification rarely originates as a complaint. SUP 15 trips on the firm’s awareness of a regulatory matter, which can be internal.
DISP 1 reporting aggregates at the half-yearly return; SUP 15 reporting is event-driven.

A complaint can promote into a breach if triage indicates a SUP 15 trigger (for example, a complaint alleging the AR operated outside scope). The promotion creates a linked breach object; the complaint object remains in the DISP 1 flow.

Cross-links

SUP 15 for the breach reporting flow that runs in parallel with DISP 1 for the subset of complaints that promote.
Vulnerable customers for the FG21/1 outcome breakdown.
SYSC 9 for complaint record retention.