Samantha is a financial service licensee.

She sells insurance.

Antoine is unhappy with the home contents insurance product he received from Samantha and he lodges a complaint with Samantha about the services provided.

However, he does not receive an answer.

When he contacts Samantha enquiring about the dispute resolution process that the licensee has, Samantha mentions that she herself decides what is going to happen and she does not have a formal internal dispute resolution system in place.

Samantha usually deals with client's complaints and disputes when she has time.

On further enquiry, Antoine discovers that Samantha is not a member of any external dispute resolution body.

Did Samantha breach any of her duties as a financial services licensee?