However, it would be stretching these powers too far to apply them to the "micro" region of individual consumer complaints about the cost or quality of banking services. We frequently receive complaints about fees and charges made by banks which appear unreasonable to the complainant - for example the imposition of charges on dormant or small deposit accounts. Our practice with such complaints is to refer them to the bank concerned and to ask it to reply direct to the complainant. As long as we are satisfied that the transparency standards in the Code of Banking Practice have been met, then we take the view that fees and charges are commercial decisions and we do not intervene. In handling complaints about bank services, the HKMA's role is limited to ensuring that the process by which the complaints are handled by AIs is fair and efficient. We have a very limited role in dispute  2  BIS Review 39/2002  resolution. Even if we wanted to intervene formally in such cases, it is difficult to see how, legally speaking, we could do so. The sanctions available in section 52 of the Ordinance - and the triggers specified for these sanctions - make it clear that intervention by the MA against an AI must be a response to issues affecting the health of the AI as a whole, or the interests of its depositors or creditors as a whole, or the broader public interest.
Less positively, a more difficult economic environment contributes to friction between banks and their customers, for example in the greater incidence of default on debt on the one hand and in the greater tendency among banks, in times of tighter margins, to go after that debt. Whether in good times or bad, a certain volume of complaints is a healthy phenomenon because it encourages improvements in service where complaints are upheld, and improvements in transparency where misunderstandings occur. On a subject so important as the way in which banks handle people's money, there will always be complaints, and we need to continue to develop our machinery for dealing with them. Let me deal quickly with the options identified by the HKMA in its survey last year which, if I read it correctly, the debate within the industry and the community is ruling out. The first option of these is the establishment of a separate banking ombudsman along the lines of the practice in some other jurisdictions. This is, in some senses, a Rolls Royce solution in that it would provide a separate agency, to process and resolve complaints, with powers to arbitrate in complaints and award compensation. It would, however, be a costly solution, and it would take a considerable time to implement. Under such a system, the process of handling complaints would probably also be quite resource-intensive, and it is by no means clear that it would be able to address the full range of complaints being made.