Financial Rights submission to Australian Securities and Investments Commission: Consultation Paper 311 Internal dispute resolution: Update to RG 165. Financial Rights supports the expansion of the complaint issue categories into sub-categories of complaints and the publishing of internal dispute resolution data at both aggregate and firm level. However we recommend further consideration regarding the recording of multidimensional data, ensuring appropriate processes are in place with respect to the flagging of consumer vulnerabilities, the recording of systemic issues as a mandatory field and the recording of reasons for withdrawal of complaints.