How to use SCORES for a Securities Complaint
Using the platform is a seven step process. Everything after the first step is wasted if the route cannot reach the grievance at all, so the first step is establishing that it can. The rest is gathering with dates, identifying one act, deciding one request, writing it narrowly, submitting and recording it, and reading the reply for what it settles rather than for whether it agrees.
The nature of the platform, and the path a complaint takes through it, are set out separately, as is the map of which route hears which kind of grievance. The procedure runs in a fixed order: first step, next step, and last of all what the reply at the end is actually worth.
Seven steps sounds like a lot for what is, in the end, three short paragraphs of writing. The count is misleading. Five of the seven are the natural things to do when something has gone wrong, and people do them without being told: collecting what there is, working out what happened, writing, sending, reading the reply. The two that are not natural are the two that decide how the whole thing goes.
Why is the order the whole method, rather than the steps themselves?
Think about what happens when a household discovers a problem with a bill. Somebody notices. There is a conversation about it at the table. Somebody looks for the paper, and either finds it or does not. Somebody drafts something in their head on the way to work. Eventually it gets written, or more often it does not, and the writing was never the obstacle.
The five natural steps are natural because they follow the feeling, and the two unnatural ones are unnatural because they interrupt it. Checking whether a route can even consider the grievance means pausing at the exact moment the household is most ready to act. Deciding to ask for one sum and not for everything lost means giving something up on paper before anybody has taken it away. Both feel like going backwards. Both are the steps that decide what comes back.
Here is a way to feel the shape of it. A person queues for an hour at the wrong counter. Nothing they did in that hour was careless. The person in the queue had their papers, their reasons, their patience and their politeness. The hour was still spent at the wrong counter, and the person at that counter cannot do anything about it however well the case is put. The first step is reading the sign above the counter, and it takes fifteen seconds, and almost nobody does it because the queue is right there.
What is step one, and why does it come before everything else?
Step one is establishing reachWhether a route can consider a grievance at all. No amount of good drafting fixes a route that was never able to look at the matter, so reach is tested before anything else.. Two questions, both answerable in about a minute, and both about the thing complained of rather than about how bad it was.
The first question is whether the entity involved is one this route covers. The second is whether the activity involved is one this route covers. Both have to be yes, and a yes on one of them is not half a yes overall. An entity that this route covers, doing something entirely outside the securities market, is not reached by this route. An activity inside the securities market carried out by somebody this route does not cover is not reached by it either.
The distinction sounds fussy until it fails in practice. The household this whole sequence follows is the Bhosale household. Meghna Bhosale earns Rs 46,000/- a month gross and takes home Rs 39,800/-, Ashok Bhosale runs a tailoring counter, and their daughter Ira is at school. Their grievance is a real one and it has a number on it. Their health floater settled a hospital bill of Rs 1,42,000/-. The insurer paid Rs 91,440/-. The household paid Rs 50,560/-, or 35.6 per cent of the bill, and inside that Rs 50,560/- sits a single deduction of Rs 24,000/- that turns on a mechanism nobody described to them.
Run step one on it. Is the entity one this securities market route covers? No, it is an insurer. Is the activity one it covers? No, it is a claim under a health policy. Two noes, established in under a minute, and the household has been saved from writing a careful complaint into a route that was never able to look at it. Their grievance is real, it has a route, and the route is not this one.
Beside the Bhosale grievance sits a second example. Because the household holds no securities of any kind, the seven steps below run on a specimenAn invented example. The household this sequence follows holds no shares, no scheme units and no securities at all, so it has no securities complaint of its own to make.: an invented household, an invented transaction, an invented sum. In the specimen, a household was told in writing that a particular charge would not apply to a transaction it was about to place, and the charge applied. The difference is Rs 3,200/-, invented.
Step one on the specimen: the entity is an intermediary in the securities market, and the activity is a transaction in the securities market. Two yeses. The route can reach it. The other six steps are worth doing.
What is step one, and why does it come first?
What do I gather, and why do the dates matter more than the paper?
Step two is gathering what exists, with dates on it. Not what should exist. Not what would have been kept had anybody known. What exists.
In the specimen there are three artefacts. The instruction, meaning what the household asked and in what words. The confirmation, meaning what came back and in what words. And the statement, meaning the document that shows the charge was applied and at what amount. Each of those carries a date, and the three dates in the specimen are 9 April, 9 April and 30 April, all invented.
The dates are doing more work than the documents. A document on its own says a thing was said. Three documents in date order say a thing was said, then something was done in reliance on it, then something different happened. The order is itself a sequence, and a sequence is the only form in which a complaint can be checked by somebody who was not there.
What is the specific act, and how is it different from what I feel about it?
Step three separates the specific actOne thing that was said or done, with a date attached. A complaint is built on that unit and answered against it. from the general dissatisfactionA feeling about a whole relationship over a whole period. The feeling is often entirely justified, and there is still nothing in it for anybody to answer, so it cannot be filed.. Step three is where most people feel they are being asked to shrink something that was not small.
In the specimen, the specific act is this: a statement was made about a charge on 9 April, and a different charge was applied. That is it. Eleven words of substance, one date, one consequence.
The general dissatisfaction is bigger and truer. The household also felt rushed. The answers it got by phone were vague. Looking back over the whole period, the household felt it had not been told things it should have been told. All of that may be entirely fair, and there is nothing in it that anybody could check, agree with, or correct, so none of it can be answered.
What exactly is being asked for, and for what reason?
Step four is the second of the two unnatural steps. Step four decides, in advance and on paper, exactly what is being asked for, and holds it to one sum and one reason. The result is a narrow requestOne sum and one reason, stated plainly. A narrow request produces one answer, and a longer request usually produces no answer at all..
In the specimen the request is Rs 3,200/-, being the difference between the charge the household was told would not apply and the charge that was applied, and nothing else. The reason is one sentence: it was said in writing on 9 April that the charge would not apply.
| The specimen, all figures invented | Amount |
|---|---|
| What the household was told would be charged, in writing, on 9 April | Rs 0/- |
| What the statement of 30 April shows was actually charged | Rs 3,200/- |
| The difference, being the whole of the request and the end of it | Rs 3,200/- |
| Everything else about the relationship, not claimed and not mentioned | Rs 0/- |
The last row of that table is the step. Rs 0/- adds nothing to the arithmetic. The row is there because writing it down is what stops the request quietly growing while the writing happens.
What do I actually write?
Step five. Five components, in an order that reads naturally, and nothing else at all.
On 9 April I asked, in writing, whether a particular charge would apply to a transaction I was about to place. I was told in writing on the same day that it would not.
I placed the transaction on 9 April. The statement dated 30 April shows that charge applied, at Rs 3,200/-.
I am asking for Rs 3,200/-, being the difference between the charge I was told would not apply and the charge that was applied. My reason is the written answer of 9 April.
Three short paragraphs are the whole complaint. The complaint names no person. The household does not need to name one, and cannot be sure who typed the reply. The desk that answered is identified by the channel and the reference the household holds. The complaint carries no adjectives about how the household was treated. The treatment mattered, but an adjective cannot be checked.
What are the five components of a narrow complaint?
What happens when I submit it, and what do I keep?
Step six is submitting it and keeping the recordWhat was submitted and when, together with what came back and when. Any further step begins by asking for the record.. Three things go into the record: what was submitted, the date it was submitted, and what came back with its own date.
The record cannot be built afterwards, so it is built at the moment of submitting. A household that files something and keeps nothing has, a few weeks later, only a memory of having complained, and a memory is not a record.
How do I read the response I get?
Step seven, and the one that decides what the whole exercise was worth. The response is read for what it settlesWhat a response actually resolves. Whether it agrees with the household is a different question, and a reply that disagrees and explains why has still settled something., not for whether it agrees with the household.
Two replies can both be a no. One says the matter has been reviewed and is considered closed. The other says the transaction fell into the category a particular term describes, and the charge applied under that term of a document the household holds.
The second reply has settled the matter and taught the household something true, and it is a better outcome than the first even though both refused. The household now knows which term did it, where that term lives, and what would have to be different for the answer to be different. The household did not have that knowledge on 30 April, and did not have to pay for it.
There is a real reason this is hard, and it is not stubbornness. People treat an outcome they consider settled as closed and rarely reopen it, an observation that belongs to Kahneman and Tversky, and the same instinct that makes a household accept a settlement without reading it also makes a household read a reply as a verdict rather than as information. The instinct is efficient most of the time. Here it costs the one thing the whole exercise produced.
The response explains exactly why the charge applied, citing a term the household holds. Which of these has the household got?
What do all seven steps look like run on one example?
Here is the whole thing on the specimen, in one place. The Bhosale household holds no shares, no scheme units and no securities of any kind, so it has no securities complaint of its own to bring. Saying that plainly is better than handing the household a holding it does not have.
| Step | What is done | What it produces on the specimen |
|---|---|---|
| One | Establish reach | Intermediary in the securities market, activity in the securities market. Two yeses. |
| Two | Gather, with dates | Instruction 9 April, confirmation 9 April, statement 30 April. |
| Three | Identify the act | A statement was made about a charge, and a different charge was applied. |
| Four | Decide the request | Rs 3,200/-, being the difference, and nothing else. |
| Five | Write it narrowly | Five components, three short paragraphs, no adjectives. |
| Six | Submit and record | The text, the date, and whatever comes back with its date. |
| Seven | Read for what it settles | Which term, why, and what would have had to be different. |
Why is the specimen an invented one?
Before the control below. Which produces a more useful reply: one act with a sum, or a full account of the relationship?
How much does the complaint cover, and how many questions has the reader been asked?
One variable: how wide the submission is, across five settings, from the single act with its sum to the whole account of the relationship. One consequence: how many separate questions the reader on the other end has now been asked, and how many of those attach a sum that is actually being asked for, with a reason. The narrowest setting is exactly what step four produces: one act, Rs 3,200/-, one reason.
- Establish reach: can this route consider the entity and the activity at all.
- Gather what exists, with the date on each document.
- Identify the specific act: one thing said or done, with a date.
- Decide the request: one sum, one reason, and nothing beyond it.
- Write it narrowly: what was said, when, by whom, what happened instead, what is asked for.
- Submit it, and keep the text, the date and whatever comes back.
- Read the response for what it settles rather than for whether it agrees.
I asked in writing on 9 April whether a particular charge would apply to a transaction I was about to place, and was told in writing the same day that it would not. I placed the transaction on 9 April. The statement dated 30 April shows that charge applied, at Rs 3,200/-. I am asking for Rs 3,200/-, being the difference between the charge I was told would not apply and the charge that was applied. My reason is the written answer of 9 April.
The error that gets made, and what it costs
The first error is writing the grievance rather than the complaint. A submission that describes how a household felt about a whole relationship gives whoever reads it nothing to answer, so what comes back is correspondingly general, and the household reads that general reply as evasion. Evasion is usually not what happened. The shape of the question comes back as the shape of the answer.
The second error is reading the response for agreement rather than for content. A reply that explains exactly why a charge applied, citing a term the household holds, has settled the matter and told the household something true. A household reading only for whether it won files that as a rejection and learns nothing from it, and that is the expensive way to loseGetting a true and complete answer and filing it as a rejection. The one thing the exercise produced is thrown away..
The cost is not the sum. A household which concludes it was brushed off stops writing things down, and the next time something goes wrong there is no record at all.
A reply comes back general and unhelpful. Where did the general reply come from?
What do I do if the answer is unsatisfactory?
Two different situations hide under the word unsatisfactory, and separating them is most of the work.
The first is a reply that answers the question and answers it against the household, with reasons. There is nothing left to ask that route. The household is left with a decision about whether to take the matter somewhere else, and where that somewhere else is, and on what basis anything further would be considered. The forum concerned sets all three.
The second is a reply that does not answer the question at all, and the response to that is to ask the same question again in the same words rather than a different question in stronger words. If it went out narrow and came back wide, the narrow version is still the strongest thing the household has, and repeating it costs nothing.
Which of the two a household has is for the household to judge, what to do next is for the household to decide, and what any further route would decide is for that route. The route has been described. Only the household can decide whether to walk the route further, spending its own time and its own energy on a matter only the household can value.
What is the record worth afterwards, whatever the answer was?
Suppose the answer was a flat no with no reasons. The natural feeling is that the exercise produced nothing. The record is worth more after an unsatisfactory answer than before it, and that is the reverse of how it feels.
Consider what a household holds afterwards. A dated submission stating one act, one sum and one reason. A dated reply. And a clear, evidenced statement of what has already been tried. Before any of it existed, the household had a grievance and a memory. Now it has a sequence.
Anything further, anywhere, begins with the same question: what was asked, and when, and what was said in reply. A household that can answer that in three sentences is in a different position from a household that says it complained some time ago and thinks somebody said something. The second household is not careless. Complaining by phone and remembering it is what everybody does, and that is all the second household did.
The answer was unsatisfactory. How much is the record worth now?
What does the platform not do for me?
A complaint platform is a channel and a record. The regulator sets the purpose of the platform, the grievances that fall inside it and the way it works, and the regulator is where those questions get answered.
The platform is not a person who will do the work for the household. Four of the seven steps are finished before the platform is ever opened, and the platform performs none of them. The platform does not gather the papers. Nobody at the platform decides which act the complaint is about. The request is decided at the household's table. The narrow writing is the household's own. And no route anywhere makes any answer come out one way rather than another.
Will the platform get the Rs 3,200/- back?
Who else works this way, and where else does the shape hold?
The five components are not a securities market invention. The five components are how anybody whose job is to answer complaints is able to answer one at all.
A person on a complaints desk, wherever it sits, has a queue and a duty to respond to each item in it. Given a submission naming one act, one date and one sum, they can go and look, find the transaction, read the term and write back about that thing. Given eleven paragraphs about a relationship, they cannot do any of that. The only reply available is that the matter has been reviewed. The narrow complaint is not a trick played on the reader. A narrow complaint is the one form of it the reader can act on.
The same shape works at a hospital billing counter, with a landlord over a deposit, with a utility over a meter reading, and inside a household when two people are arguing about money. One thing, one date, one sum, one reason. The difference is between saying nothing is ever explained and saying this was not explained on Tuesday and it cost Rs 800/-.
Where the scope and the procedure are actually set
For the securities market complaint platform, the Securities and Exchange Board of India at sebi.gov.in is where scope, procedure, forms and every period are set, and all of them change. For grievances outside the securities market, the corresponding regulator or statutory forum sets its own, and which one applies to a given grievance is what step one establishes.
References
| Source | Document | Where |
|---|---|---|
| Securities and Exchange Board of India | Material on the complaint platform for the securities market, on the entities and activities it covers, and on the procedure and periods that apply to it | sebi.gov.in |
| Insurance Regulatory and Development Authority of India | Material on grievance arrangements for insurance, the route for a health claim deduction of the kind the Bhosale household is holding | irdai.gov.in |
| Reserve Bank of India | Material on banking grievances and the ombudsman arrangements attached to them | rbi.org.in |
| Pension Fund Regulatory and Development Authority | Material on grievance arrangements where a pension arrangement is involved | pfrda.org.in |
| Department of Consumer Affairs | Material on the consumer redressal commissions established under consumer protection law, one of the places a grievance may be considered | consumeraffairs.gov.in |
The Bhosale household, Meghna Bhosale, Ashok Bhosale and Ira Bhosale are invented, as are the specimen household, its transaction, the sum of Rs 3,200/-, the dates of 9 April and 30 April, and both of the replies compared above.
Educational material. Not advice on any investment, tax, budget or market position.
