Customer Complaints

Handling complaints is part of a firm's supervisory duty, and the exam tests three points: record everything, escalate to the right place, and adjust accounts fairly.

Record, Escalate, and Supervise Every Complaint

The core duty is to capture complaints and make sure someone with authority follows them to resolution.

• Both Futures Commission Merchants (FCMs) and Introducing Brokers (IBs) must keep a written record of every customer complaint received. Both oral and written complaints are captured, and an oral complaint is reduced to a written record. Complaint records are retained as required firm books and records.
• A complaint received at a branch office or by a guaranteed IB must be forwarded to the main office (or to the guarantor FCM), and its resolution must be supervised and reviewed.
• Firms periodically review the status of unresolved complaints to confirm they are being addressed promptly.

Exam Tip: Gotchas

• Oral complaints count too. A firm cannot ignore a verbal complaint just because the customer never put it in writing. The oral complaint is written up and recorded like any other. An answer that limits the recordkeeping duty to written complaints is wrong.

Options Complaints and Account Adjustments

Two special cases ride on the same process.

• Options-related complaints (complaints involving options on futures) are recorded, forwarded, and supervised under the same process as any other customer complaint. The firm keeps records of options complaints just as it does the rest.
• Adjustments to accounts (for example, correcting an error or reallocating a residual from an averaged or bunched order) must be made fairly to the customer and documented. A firm may not use an account adjustment to disguise an error, favor itself, or deceive the customer.

Think of it this way: an account adjustment is a correction the customer should be able to see and understand. If it is fair and written down, it is a fix. If it quietly moves money to hide a mistake or help the firm, it is a violation.

Exam Tip: Gotchas

• Options complaints get no special shortcut. They run through the same record-forward-supervise process as every other complaint. A choice that carves options complaints out of the standard handling is wrong.
• An account adjustment must help the customer, never hide a firm error. Misallocating funds or residuals in a customer's account can itself be a rule violation, even if the totals still balance.