ASIC has released guidance to clarify dispute resolution requirements for unlicensed carried over instrument lenders (unlicensed COI lenders).
When a complaint is received, unlicensed COI lenders must be responsive to the complaint and their IDR system must handle it within the maximum timeframes and according to other requirements set out in RG 165.
While not compelled to do so, ASIC encourages all unlicensed COI lenders to join an external dispute resolution scheme – either the Financial Ombudsman Service Limited (FOS) or the Credit Ombudsman Service Limited (COSL).
UPDATE: see ASIC’s information page on pre-existing credit contracts and carried over lenders