Layer 4 - Issue Identification Model & Log
Consistent classification (A/B/C/D) and mandatory issue log for all DCAs
Executive summary
All issues arising from or related to DCA activity must be classified using a consistent structure and logged in a central register. This ensures comparability across DCAs and over time, correct escalation per Layer 6, trend analysis, and an audit trail. No DCA is exempt; every issue is assigned exactly one primary category (A, B, C, or D).
1. Purpose
Every issue is assigned exactly one primary category. Categories and escalation are summarised below.
2. Issue classification structure
Category A - Conduct & Regulatory
| Code | Description | Examples |
|---|---|---|
| A1 | Hardship delay | Late referral; failure to refer; incentive discouraging referral |
| A2 | Contact breaches | Contact outside 6am-9pm; > 6 contacts per week; F2F on Sunday |
| A3 | Misleading statements | Incorrect claim about legal action; misrepresentation of balance or rights |
| A4 | Disclosure failures | Collection before s 132A disclosure; disclosure not within 10 working days |
| A5 | Harassment / coercion / unconscionable conduct | FTA breach; undue pressure; inappropriate language |
| A6 | Privacy / data breach | Unauthorised disclosure; use of data outside purpose; loss of data |
| A9 | Other conduct & regulatory | Any other conduct or regulatory issue not listed above |
Escalation: Category A issues are escalated per Layer 6 (e.g. immediate escalation to Risk).
Category B - Delegation & Authority
| Code | Description | Examples |
|---|---|---|
| B1 | Settlement outside threshold | Settlement above delegated limit without bank approval |
| B2 | Unapproved legal escalation | Referral to legal without bank approval or outside process |
| B3 | Unauthorised waiver | Waiver above delegated limit or without approval |
| B4 | Other delegation breach | Any other exercise of authority outside Delegated Authority Schedule |
Escalation: Delegated authority breach may trigger suspension of authority (Layer 6).
Category C - Operational Leakage
| Code | Description | Examples |
|---|---|---|
| C1 | SLA miss | Failure to meet performance or conduct SLA |
| C2 | Non-treatment | Account not treated within required period; non-treatment > X days |
| C3 | Incorrect routing | Account sent to wrong team/segment; wrong product or DCA |
| C4 | Reporting failure | Late pack; wrong format; material error in reported data |
| C5 | System / data error | Assignment file error; duplicate assignment; data corruption |
| C9 | Other operational | Any other operational failure not listed above |
Escalation: Repeated SLA miss (e.g. > 2 months) triggers formal remediation plan (Layer 6).
Category D - Financial & Commission
| Code | Description | Examples |
|---|---|---|
| D1 | Overpayment | Commission or fee overpaid; duplicate payment |
| D2 | Clawback failure | DCA did not repay clawback after reversed recovery or breach |
| D3 | Misaligned incentive | Structure or payment that conflicts with Commission & Incentive Standard |
| D4 | Other financial | Billing dispute; reconciliation error |
Escalation: Material financial issue may be escalated to Risk Committee and/or CRO.
3. Issue log - mandatory fields
The following fields must be completed for every issue. Log may be maintained in a system or spreadsheet; format must allow filtering by DCA, category, date, and status.
| Field | Description | Mandatory |
|---|---|---|
| Issue ID | Unique reference (e.g. ISS-YYYY-NNNN) | Yes |
| Date identified | Date issue was identified | Yes |
| Identified by | Bank / DCA / Customer / Regulator | Yes |
| DCA name | DCA concerned | Yes |
| Category | A / B / C / D | Yes |
| Code | A1-A9, B1-B4, C1-C9, D1-D4 | Yes |
| Short description | One-line summary | Yes |
| Detailed description | What happened; account/volume if applicable | Yes |
| Root cause | Known or preliminary root cause | If known |
| Impact | Customer impact; financial; regulatory; reputational | Yes |
| Status | Open / In progress / Closed | Yes |
| Remediation | Actions taken or planned | Yes (for closure) |
| Escalation | Whether escalated per Layer 6; to whom; date | If escalated |
| Closed date | Date issue closed | When closed |
| Owner | Person responsible for tracking (bank side) | Yes |
4. Workflow
- Identify: Any party identifies an issue.
- Classify: Bank (or designated role) assigns Category and Code.
- Log: Issue is entered in the central Issue Log with all mandatory fields.
- Escalate: If Layer 6 triggers apply, escalation is executed and recorded.
- Remediate: Owner drives remediation; status updated until closed.
- Report: Open and closed issues are reported in Monthly Pack and governance meetings.
5. Reporting
Monthly Pack (Layer 3) Section 5 - Risk Indicators includes count of open issues by Category (A/B/C/D). Significant issues are discussed in Monthly Performance & Conduct Review; trends and closure rates in Quarterly Risk & Attestation Review; material issues (Category A breach, suspension) reported to Risk Committee.