CLIENT COMPLAINTS POLICY AND PROCEDURE – Aspira Capital

ASPIRA CAPITAL GROUP, LLC
CLIENT COMPLAINTS POLICY AND PROCEDURE
MAY 2023

I. Introduction

The purpose of this document is to document the procedures at Aspira Capital Group, LLC (“Aspira” or “Company”) for handling consumer complaints. It is the intention of Aspira’s management team to ensure that all clients are provided with professional, friendly and courteous client service and support. As such, Aspira’s management team takes complaints seriously and is committed to addressing any complaints promptly.
II. Designation of the Responsible Officer
Aspira’s Operations Officer has been designated as the person to receive the complaints made by clients.
III. Methods of Complaints
Complaints may be received through many methods, channels, or through agencies. Some of these are mentioned below.
IV. Methods of delivery
1. By mail
2. By email
3. Orally on the phone
Agencies
1. Better Business Bureau
2. Consumer Finance Bureau
3. Statutory agencies
V. Obligations
It is not necessary that a complaint should be received directly. Even if a complaint is made through a secondary source (e.g., media) against the Company or its operations, Aspira’s management team will address the complaint in a timely manner. Anyone who receives or becomes aware of a complaint about Aspira from a secondary source, the Operations Officer and the Chief Executive Officer should be notified.
VI. Recording of Complaints
The designated officer will record a complaint in a “Client Complaints Log. The log shall maintain the information listed below.
1. Date of complaint
2. The source of complaint
3. The Client’s name
4. Description of complaint ( specify if the complaint is a potential violation of consumer law or regulation)
5. Responsible person assigned to address the complaint.
6. Date that the complaint was address
7. Description of steps taken to remediate the complaint
8. Date of closure of the complaint

VII. Processing the Complaint (Procedures)

1. Upon receiving a complaint, the operations officer shall be notified.
2. The operations officer will brief management about the nature of the complaint. If a complaint relates to a potential violation of law or regulations, the operations officer shall contact the appropriate regulatory agency in the jurisdiction where the complaint arose from.
3. An acknowledgement will be sent to the complainant and anyone else included in the original complaint stating that the Company is addressing the complaint.
4. Provide a time frame to the client within which the Company will advise them about the status of resolution of the compliant.
5. If the complaint was received through a regulatory agency, the operations officer shall notify the agency of the steps that the Company will take to address the complaint.
6. A final resolution should be advised to the complainant with details.
7. Update the Client Complaint Log
8. Document and inform management of the final disposition of the complaint.
All complaints must be addressed no later than 10 business days from the time the complaint is received. If for any reason, the complaint cannot be resolved within this time frame, the operations officer shall document the reasons why further time is warranted.

VIII. GLB ACT (Privacy)

Consistent with Aspira’s policies and business practices, management makes every effort to ensure the privacy of its clients and no confidential information is disclosed to any third party, other than to manage the daily operations of the business. It is of utmost importance that all correspondence exchanged with the complainant and any other party involved will be conducted with decorum and courtesy.

IX. Conclusion

This document shall be reviewed on an annual basis or more frequently as needed.

CLIENT COMPLAINTS POLICY AND PROCEDURE