Pillar 7 – Consumer Complaints

7.01 - Consumer Complaints

The Company maintains procedures to receive and address consumer complaints to ensure that the Company maintains a high level of service and continue to operate in a compliant manner.

Each of the following criteria will be met to qualify as a consumer complaint:

(1)Submitted by or on behalf of a consumer

(2)Expresses verbal or written notice of poor service, dissatisfaction, non-compliance with the law, allegations, discrimination, litigation (or threat thereof)

(3)Relates to the agreed upon service that has been or is being provided

(4)A response or resolution is explicitly or implicitly expected

Applicable parties: All GATCO Personnel

7.01(a) - Recordation and Response


The Company’s single point of contact for complaints is the Company’s Complaint Department. The Company’s Complaint Department accepts consumer complaints regardless of source or method of submission. All complaints are appropriately documented using our standard (electronic/paper) form.

Complaint Routing:

Once validated, complaints are reviewed and routed to appropriate personnel. Upon receipt, identified personnel respond to, address and/or resolve the complaint promptly.

Evidence: Customer Complaint Form, Customer Complaint Handling Procedure,

Complaint Log

Complaint Register (Available upon written request)

Applicable parties: All GATCO Personnel

7.01(b) – Reporting


(1)Upon receipt, all consumer complaints are logged for reporting into a Complaint Log. Current status, actions taken and other relevant information is maintained for each complaint.

(2)Each complaint is maintained on the Complaint Log for least one year from the date the complaint was received.

(3)Information contained in the Complaint Log is confidential unless required to be disclosed under third party contracts.

Applicable parties: All GATCO Personnel

7.01(c) - Analysis and Self-Assessment

Management periodically reviews its complaint data to ensure complaints are addressed in a timely manner, identify process improvement opportunities and make adjustments to business practices as appropriate.

Consumer Complaints may result in retrospective corrective action when appropriate.

Evidence: Company Tracking Log (Available upon written request).

Applicable parties: All GATCO Personnel

7.01(d) – Training

Training is conducted for identified employees

At hire and annually all identified employees are provided training on Consumer Complaints policies and procedures.

Training completion and policy delivery is maintained on the Employee Tracking Log.

Evidence: Employee Training Acknowledgement Form (Available upon written request)

Applicable parties: All GATCO Personnel