A dispute without evidence is a dispute that resolves based on who the institution believes — which is a governance and fairness problem as well as a regulatory one. A dispute with complete, source-attributed, timestamped evidence is a dispute that resolves based on what the records show — which is the standard the EU ADR Directive and national financial ombudsman framework was designed to enforce. The Dispute Manager Agent AI gathers evidence from eight different source systems within 24 hours of a dispute being filed — automatically, without requiring the Complaints Officer to call five different departments and wait for email attachments. When the Complaints Officer receives the dispute file, the evidence is already assembled, cross-referenced, and marked with a preliminary assessment of whether the evidence supports or contradicts the borrower's claim.
The 8 evidence sources — and what each contributes to a dispute file
A complete dispute file requires evidence from sources that typically live in different systems, managed by different teams, with different access controls. Call logs are in the collections management system. SEPA Direct Debit return codes are in the payment gateway portal. KFS and eSign records are in the document repository. CBS payment history is in the core banking system. Bureau consent records are in the KYC / AML and onboarding system. open banking / PSD2 aggregator data is in the AA integration layer. Property valuation records are in the legal and property management system. Training and conduct records are in the HR and compliance system. The Dispute Manager Agent AI has read access to all 8 sources and retrieves the relevant evidence from each, simultaneously, within minutes of the dispute being filed.
"A Nodal Officer who spends 3 days gathering call logs, payment records, and consent documents is a Nodal Officer who has 3 fewer days to assess the dispute and draft the resolution. The evidence gathering is not the job — it is overhead that prevents the job from being done."
The evidence file: DIS-2025-1848 · Collections conduct · Sunita de Vries
Evidence Assembly — DIS-2025-1848 · Sunita de Vries · Collections Conduct Dispute
Dispute filed: Nov 12 · Evidence assembled: Nov 12 · 4h 18m · 8 sources checked · Preliminary assessment: FPC violation confirmed
BorrowerSunita de Vries · Barcelona
ClaimCalled at 7:42 PM on Nov 8 (past 7 PM limit) by collections agent
ProductSME Term Loan · LA-2025-4218 · DPD 35
Requested remedyApology · Remove DPD-related charges
Evidence retrieved — 8 sources · Nov 12 · 4h 18m assembly time
Call log retrieved for LA-2025-4218, November 8, 2025. Outbound call placed by Agent CA-148 (Rohit Dubois) at 19:42:14 IST. Call duration: 3 min 44 sec. Borrower picked up. This is 42 minutes after the FPC-permitted contact window (8 AM – 7 PM). A second call at 19:58:02 (same agent) was placed but was unanswered.
→ FPC violation confirmed: 2 calls placed after 7 PM by the same agent on the same date
Recording ID REC-CA148-20251108-1942. Duration 3m 44s. Reviewed: agent identified themselves correctly. Tone: firm but not abusive. No prohibited language detected. Agent did not contact family members or employer. The FPC violation is the timing — not the content of the call.
→ Call content: no additional violation beyond timing · FPC violation: timing only · Agent conduct during call: within policy
Agent CA-148 (Rohit Dubois): FPC training completed August 14, 2025 (Module M05 — Collections Conduct). Score: 82%. FPC permitted hours were covered in Module M05, Section 3.2. Agent was trained on the time restriction — this is not a training gap, it is a conduct failure.
→ Agent was trained on FPC hours · Violation is wilful or negligent, not a training gap · Escalate to collections head for disciplinary note
Account LA-2025-4218: DPD 35 as of Nov 12. instalment of €24,800 was due Nov 5. SEPA Direct Debit return on Nov 5: R01 (insufficient funds — borrower side). No payment received since Oct 5. Penal interest accrued: €1,080 (35 days × per-day rate). The DPD and the penal charge are correctly applied per the loan agreement terms.
→ DPD and penal interest are correctly applied · Borrower's request to "remove DPD-related charges" is not supported by the payment record · Partial remedy only
KFS issued Nov 14, 2024 — acknowledged by Sunita de Vries (eSign). KFS Section 8 specifies: "Collections contact permitted between 8:00 AM and 7:00 PM IST only, in accordance with the institution's EBA consumer protection standards." Borrower acknowledged this disclosure. Call at 7:42 PM violates a term the borrower explicitly acknowledged.
→ Borrower acknowledged permitted hours in KFS · Violation confirmed against a term the borrower knew about · Strengthens the institution's acknowledgement of the breach
SEPA Direct Debit return code R01 on Nov 5: Axis Bank confirmed insufficient funds. No technical failure or bank-side error. SEPA Direct Debit mandate: active and correct account details. The instalment non-payment is a borrower-side event — penal charges are correctly applied.
→ Penal charges are correctly applied · Cannot be waived on the grounds of the FPC violation · These are separate matters
Preliminary assessment — evidence-based
Partial resolution: FPC violation confirmed · Penal charges correctly applied
Remedy: formal apology · Agent disciplinary note · Penal charge NOT waived (instalment non-payment is separate from FPC call timing)
Assembly time
4h 18m from dispute receipt
8 sources retrieved simultaneously
Manual equivalent: 3–4 working days
The 8 evidence sources — retrieval scope and typical assembly time
| Evidence source | System | What it provides | Retrieval time | Most relevant to |
|---|
| Collections call log | Call Management System | All outbound/inbound calls with timestamps, agent IDs, duration, call status (answered, missed, dropped) | Instant | Collections conduct, permitted hours, third-party contact |
| Call recording | Collections Management / Third-party CCaaS | Audio recording of the specific call — language, tone, content, third-party presence | 1–48 hours (depends on platform) | Abusive language claims, third-party contact claims |
| CBS payment history | Core Banking System | Full payment ledger — debit dates, amounts, DPD classification, penal interest accrual | Instant | Penal charge disputes, payment attribution, DPD claims |
| SEPA Direct Debit return codes | Payment Gateway / NPCI | Specific return code per failed debit — distinguishes bank-side technical from borrower-side insufficiency | Instant (24h for aged records) | Penal charge disputes — bank fault vs borrower fault |
| KFS and eSign records | Document Repository | KFS with creation timestamp, borrower eSign timestamp, approval letter date, MITC signed document | Instant | Disclosure disputes, rate disputes, prepayment charge disputes |
| Borrower consent records | KYC / AML / Onboarding System | Consent forms signed, AA consent status, bureau consent date, digital consent with timestamps | Instant | Data disputes, bureau consent disputes, KFS acknowledgement disputes |
| Agent training records | HR / Compliance System | Training modules completed by specific agent, scores, dates — determines whether violation is training gap or conduct failure | Instant | Collections conduct disputes — distinguishes wilful violation from training gap |
| Borrower bank statement (via AA) | open banking / PSD2 aggregator Integration | Bank account credits and debits for the dispute period — requested from borrower via WhatsApp if AA consent not active | Instant (AA active) / 24–48h (requested) | Payment attribution disputes, double debit claims |
4h 18mEvidence assembly for DIS-2025-1848 — 8 sources · Simultaneous retrieval · Manual equivalent: 3–4 working days · Nodal Officer gets complete file day of receipt
8Evidence sources retrieved for every dispute — call log, recording, CBS, SEPA Direct Debit, KFS, consent, training, bank statement · All simultaneously
PartialDIS-2025-1848 remedy — FPC violation confirmed (apology + agent discipline) but penal charge correctly applied (separate matter) · Evidence separates the two claims
PreliminaryAI generates preliminary assessment with evidence — Nodal Officer reviews and approves · Final decision always human · AI gathers, human decides
The evidence that distinguishes a bank-side SEPA Direct Debit failure from a borrower-side instalment skip is a 2-digit return code in a payment gateway log — and the institution that cannot retrieve it within 24 hours cannot defend the penal charge it applied
A borrower who disputes a penal charge for a SEPA Direct Debit bounce needs one piece of information to resolve their dispute: the SEPA Direct Debit return code. If it is R29 (bank network error) or R01 with a bank-flagged technical note, the penal charge should be reversed — the borrower did not skip the payment, the bank system failed to process it. If it is R01 without a technical note, the borrower had insufficient funds. These two outcomes have entirely different remedies. An institution that does not retrieve the return code within 48 hours of the dispute is an institution that either applies a blanket reversal policy (expensive and incorrect) or maintains the charge regardless of cause (a potential FPC violation if the bounce was bank-side). The Dispute Manager Agent AI retrieves the return code within minutes and documents which type of failure caused the bounce — the most consequential piece of evidence in the most common dispute category, retrieved automatically, so the Nodal Officer can resolve correctly rather than guessing.
