FHRA helps B2B lenders resolve disputes early through structured complaint handling, external review, and clear written outcomes.
FHRA works with lenders who operate outside consumer credit regulation, where ABN holders, companies, and directors as guarantors are the borrowers. We understand the commercial context and the specific nature of disputes that arise in this space.
Each service is designed to be practical, proportionate, and clearly documented. We do not provide legal advice.
Structured intake, evidence-based assessment, outcome letters, complaints register and trend reporting. Optional coordination with legal teams and mediation support.
A Step 2 review option if a complainant is not satisfied with the lender's internal response. Conducted by an external reviewer engaged to provide an impartial written assessment.
An external review of how a privacy complaint was handled. Focused on process, fairness, and practical improvement actions. Structured findings and recommendations, not legal advice.
Every matter follows a consistent structure so your team and the complainant know exactly what to expect at each stage.
We receive the complaint, confirm scope, acknowledge receipt, and prepare an initial handling plan. Your team is briefed within two business days.
We review all relevant documentation, correspondence, and contractual terms. We apply an evidence-based approach and identify key findings.
A clear written outcome letter is produced, including findings, rationale, and resolution options where applicable. A register entry is created.
FHRA is designed for lender compliance managers, operations leaders, and executives who need clear documentation and defensible process, not just advice.
FHRA is available on a retainer basis for lenders with ongoing complaint volumes, or on a per-matter basis for individual matters. Retainer options include bundled registers, reporting, and template access.
Confidentiality is standard. All matters are handled with strict confidentiality. Engagement terms set out information handling, reporting obligations, and access controls from the outset.
Any organisation that has received a privacy complaint and handled it internally can engage FHRA to conduct an independent review of that process. We assess whether the complaint was handled fairly, what findings are supported by the evidence, and what practical improvements can be made.
This service is not limited to lenders. Any company seeking an external review of a privacy complaint handling outcome can engage FHRA directly.
FHRA provides structured findings and recommendations. This is not legal advice.
FHRA offers flexible engagement structures suited to the size and complexity of your complaint volume. Contact us for a tailored proposal.
For individual complaint matters or one-off reviews
For lenders with ongoing or periodic complaint volume
For standalone independent privacy complaint review
"Having a structured, written outcome for each complaint has made a real difference to how we manage escalations. The process is clear and our compliance team now has a consistent record."
"We needed something between our internal team and full litigation. FHRA gave us a credible independent review option that the borrower found acceptable."
"The privacy complaint review was exactly what we needed. Clear findings, practical recommendations, and completed quickly. We updated our process within a fortnight."
If you have a question not covered here, contact us directly and we will respond within one business day.
Book a call with our team to discuss your complaint handling needs and how FHRA can support your lender.
Three clearly scoped services designed for B2B and commercial lending environments.
FHRA manages the end-to-end complaints handling process for B2B lenders. This includes receiving and triaging complaints, conducting an evidence-based assessment, producing written outcome letters, and maintaining a structured complaints register. We can also coordinate with your legal team and provide optional mediation support.
If a complainant is not satisfied with the lender's internal response, FHRA provides a Step 2 independent review option. The review is conducted by an external reviewer engaged to provide an impartial assessment of the complaint handling outcome and the substantive issues raised.
The review is conducted at arm's length from the lender's internal team. The reviewer considers all available documentation and produces a written review outcome summary setting out findings and reasoning. This is not a legal determination and does not bind either party, but provides a credible and structured basis for resolution.
FHRA provides an external review service for organisations that have handled a privacy complaint internally and want an independent assessment of how that process was conducted. We review for fairness, process adherence, and practical improvement opportunities.
FHRA provides structured findings and practical recommendations. This service does not constitute legal advice, legal representation, or a determination under the Privacy Act 1988 (Cth) or applicable state legislation.
It is important to understand the limits of our service so you can engage us with accurate expectations.
Engagements are structured as follows. The lender contacts FHRA to discuss the service scope. A proposal is provided within 2 business days. On acceptance of terms and engagement letter, FHRA begins service delivery at the agreed scope.
Whether you are handling a single complex matter or want an ongoing support structure, FHRA can scope a service that fits.
A consistent, documented process gives your team and the complainant confidence at every step.
FHRA receives the complaint directly or from the lender. We confirm receipt and log the matter into the complaints register.
Same business dayWe send a formal acknowledgement to the complainant confirming receipt, reference number, and expected timeframes.
Within 1 business dayWe assess the nature and complexity of the complaint, identify documents required, and provide the lender with an initial handling plan.
Within 2 business daysWe gather all relevant documents from the lender and, where appropriate, request a response from the complainant. All material is reviewed against the issues raised.
Days 3 to 6We conduct a structured, evidence-based assessment. Key findings are documented and the position on each issue is determined.
Days 5 to 9A clear outcome letter is produced, setting out the findings, the reasoning, and available resolution options. This is provided to the lender first for review before dispatch.
Typically 5 to 10 business daysIf the complainant is not satisfied with the outcome, they may request an independent review. The review is conducted by a separate reviewer and a written review outcome summary is produced.
On requestThe lender engages FHRA to manage the complaint on their behalf. FHRA conducts intake, assessment, and produces a written outcome. The lender remains the responsible party and the outcome reflects FHRA's structured review conducted under the lender's complaints framework.
If the complainant is unsatisfied, a separate external reviewer conducts a fresh assessment of the complaint and the Stage 1 outcome. The reviewer is engaged to provide an impartial review and is independent from the Stage 1 process. A written review outcome summary is issued directly to both parties.
The availability of a Stage 2 independent review pathway is a significant factor in reducing escalation to litigation or external bodies. It provides the complainant with a credible option for review without the cost and delay of formal proceedings.
| Milestone | Target |
|---|---|
| Acknowledgement | 1 business day |
| Initial handling plan to lender | 2 business days |
| First response (simple matter) | 5 business days |
| First response (complex matter) | 10 business days |
| Independent review outcome | 10 to 15 business days |
Timeframes depend on document availability and matter complexity. We will notify you promptly if a delay is anticipated.
To ensure efficient handling, have the following documents available at the time of engagement.
| Document | Notes | Status |
|---|---|---|
| Signed loan or facility agreement | Including all schedules and annexures | Required |
| Guarantee documents | If director or third party guarantors are involved | Required |
| Full correspondence history | Emails, letters, and notes from all channels | Required |
| Complaint in writing | Original written complaint or transcribed oral complaint | Required |
| Internal notes and decision records | Credit notes, approval records, call logs | Required |
| Account statements or loan ledger | Covering the period in dispute | Required |
| Any previous response to the complainant | Internal responses already issued | If applicable |
| Legal correspondence received | Solicitor letters or formal demands | If applicable |
| Valuation reports | If the matter involves security property | If applicable |
| Broker or introducer correspondence | If relevant to the origination of the facility | If applicable |
Bring a matter to us or ask about setting up an ongoing retainer arrangement. We will respond within one business day.
An external, impartial assessment of your internal privacy complaint handling process. Structured findings, clear recommendations, not legal advice.
When an organisation receives a privacy complaint and handles it internally, there are circumstances where an independent external review of that process provides significant value. This may be because the complainant disputes the outcome, because the organisation wants to demonstrate good practice, or because there is a concern that the internal process may not have been consistent or well-documented.
FHRA provides an external review service that assesses the process used to handle the privacy complaint, the fairness and clarity of the outcome, and identifies practical improvements. We do not provide legal advice and we do not represent the organisation or the complainant.
Was the complaint acknowledged promptly? Did the organisation follow a documented process?
Was the investigation structured and evidence-based? Were the relevant facts gathered and assessed?
Was the outcome supported by the evidence? Was the complainant's position properly considered?
FHRA produces a structured written findings report and practical improvement recommendations.
Important: FHRA provides structured findings and practical recommendations. This service does not constitute legal advice, legal representation, or any determination under the Privacy Act 1988 (Cth) or applicable state legislation. If you require legal advice, please consult a qualified Australian lawyer.
You contact FHRA and provide a brief summary of the privacy complaint and what you have done internally. We confirm scope and fee and issue an engagement letter.
We receive the relevant documents including the complaint, your response, your internal investigation records, and any correspondence. We assess the process and outcome.
We produce a structured written findings report covering process, fairness, and practical recommendations. This is provided to the engaging organisation.
Guides, checklists, and process documents to support better complaint handling in commercial and B2B lending.
A step-by-step checklist covering intake, assessment, response, and escalation protocols for commercial lenders.
Practical guidance for lenders on managing director and guarantor complaints before they reach litigation.
A structured guide for organisations on how to receive, investigate, and respond to privacy complaints in a fair and documented way.
A plain English letter template for acknowledging commercial complaints in writing, including reference number and timeframe guidance.
An overview of how lenders can use complaint trend data to identify systemic issues before they become material risks.
A plain English explainer on the difference between Stage 1 internal handling and Stage 2 independent review for commercial lenders and their borrowers.
We release practical guides and articles for commercial lenders. Enter your details to receive these when published.
FHRA exists to improve complaint handling quality and reduce escalation in Australian commercial lending.
FHRA was established to address a gap in the Australian commercial lending market. B2B lenders and their borrowers often face disputes that benefit from structured complaint handling and an independent review option, but fall outside the scope of consumer credit regulation or approved external dispute resolution schemes.
Commercial lenders have a genuine need for a credible, third party support structure that handles complaints professionally, produces clear written outcomes, and provides an independent review pathway when needed. FHRA fills that role.
Our service is not about imposing outcomes or acting as a regulator. It is about providing a structured, evidence-based approach to complaint handling that works for lenders, their borrowers, and the integrity of commercial lending relationships in Australia.
Every engagement is handled with the same principles: fairness, clarity, evidence, and practical outcomes. We do not take sides. We do not provide legal advice. We assess what has happened, what the evidence supports, and what a reasonable and fair outcome looks like.
We write clearly, in plain English. Our outcome letters and findings reports are designed to be understood by compliance managers, operations teams, and executives, not just lawyers.
Confidentiality is not optional. Every matter we handle is treated with strict confidentiality, and our engagement terms make those obligations explicit from the outset.
We assess both sides of every matter on its merits. No party receives preferential treatment.
Our findings are written in plain English. Every outcome has a clear rationale.
Outcomes are grounded in the documents and facts of each matter, not assumptions.
Every matter is handled with strict confidentiality. Our obligations are explicit and documented.
Recommendations are designed to be actionable. We focus on what can actually be done.
FHRA's team has backgrounds in commercial dispute resolution, compliance, and lending operations. Our reviewers operate independently of each matter and are engaged to provide impartial assessments.
Specialist in commercial dispute resolution and complaints handling. Former lender compliance and operations experience.
Engaged to conduct Stage 2 independent reviews. Operates at arm's length from Stage 1 handling and has no connection to the lender or the Stage 1 process.
Focused on privacy complaint process reviews. Background in compliance, privacy program management, and regulatory engagement.
FHRA's independence is maintained through structural separation between the Stage 1 complaint handling function and the Stage 2 independent review function. The reviewer conducting a Stage 2 review has no involvement in the Stage 1 process for that matter.
Engagement terms are agreed with each lender client before any matter is handled. Those terms include clear obligations around independence, confidentiality, and the scope of service. We do not accept instructions that would compromise the independence of a review.
FHRA does not hold or exercise any regulatory or statutory power. Our services are provided under contract. No outcome we produce is legally binding on either party, though it may be used as evidence of a fair and structured complaints process.
Book a call or contact us to discuss your complaint handling needs.
We respond to all enquiries within one business day. All enquiries are treated in confidence.
Thank you for contacting FHRA. We will respond within one business day. All enquiries are treated in confidence.
If your matter is urgent, please call us during business hours.
enquiries@fhra.com.au
Monday to Friday, 9:00 am to 5:30 pm AEST. Enquiries received outside business hours will be responded to on the next business day.
We respond to all enquiries within one business day. For urgent matters, please indicate this in your message.
Confidentiality: All enquiries and matters are treated with strict confidentiality. We will not share your information with any third party without your consent.
Select "General enquiry" and describe your situation. We will recommend the most appropriate service and provide a scoped proposal.