Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
MAS's 20 October 2026 information paper found banks and insurers have basic complaints arrangements in place but board oversight is uneven. Complaint patterns are a governance signal, not a volume table.
I once sat in a board meeting where the customer complaints update was presented as a single metric: 492 complaints this quarter, down from 511. The board appeared reassured -- the trajectory was right. When I asked what the top three complaint categories said about underlying product design, the room went quiet. Nobody had looked at it from that angle. [CONFIRM with Raymond -- replace with a real episode if possible]
What MAS found
On 20 October 2026, MAS published an information paper on complaints management practices, based on thematic inspections of selected banks and insurers. The headline finding is that basic arrangements are in place but maturity varies considerably across institutions. The specific expectations are aimed at boards and senior management, not just operations teams.
MAS wants boards and senior managers to look past case volumes and procedural compliance metrics, and to use complaint patterns and root-cause analysis to shape products, services and controls. It also flagged that staff implicated in a complaint should not be the ones deciding its outcome, and that complaints resolved quickly should still be recorded even if they do not escalate into formal disputes.
Why this matters at board level
Complaints are a leading indicator. They arrive before the regulatory citation, before the press headline and before the class action. An institution that tracks complaint volume has a monitoring function. An institution whose board understands what each complaint category says about a product's design, a sales incentive structure or a claims-handling process has governance.
“When complaints are reported as a volume table, boards see the symptom. When they are reported as a pattern analysis, boards can act on the cause.”
This is consistent with what I see when advising boards: most complaints reporting is backwards-looking and upward-facing. It tells the board what happened last quarter. It rarely tells the board what the pattern means for the risk appetite framework or the product approval process. MAS's paper is a signal that it expects the latter.
Three questions to ask management this month
- What are the top three complaint categories this quarter, and what product design, incentive structure or operational failure does each one point to?
- Who is responsible for translating complaint patterns into changes to products or procedures, and when did the board last see evidence of that loop closing?
- If a staff member was implicated in a complaint, who decided the outcome -- and does your governance framework explicitly separate those roles?
MAS information papers based on thematic inspections have consistently preceded supervisory follow-up. Boards that wait for a formal finding have read the calendar wrong. The right response is to ask for a root-cause complaints report at the next meeting and to review whether board-level oversight of conduct risk is embedded in the corporate governance framework -- not just present in the compliance policy.
Common Questions
What did MAS find in its 2026 thematic review of complaints management?
MAS's October 2026 information paper found that banks and insurers generally have basic complaints arrangements in place, but that maturity differs across institutions. MAS expects boards and senior management to go beyond tracking complaint volumes and use complaint patterns and root-cause analysis to identify and fix underlying issues in products, services and controls.
What does MAS expect boards to do with complaints management?
MAS expects boards to ensure that complaints are used as an input to improving products and controls, not just resolved procedurally. Key expectations include separating the role of staff implicated in a complaint from the role of deciding its outcome, recording all complaints including quickly resolved ones, and ensuring senior management reports complaint patterns and root causes to the board rather than only volume metrics.
Why are customer complaints a board governance issue in Singapore?
Under MAS's fair dealing and market conduct frameworks, boards of banks and insurers are responsible for customer outcomes, not just operational procedures. Complaint patterns are a direct signal about whether products are designed fairly, whether sales incentives are appropriate and whether the organisation prioritises customer outcomes. A board that only sees complaint volumes is missing the governance information it needs to act.
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About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.