The dispute resolution arrangements in the National Credit Act are causing concern, with some credit providers saying the protocols that govern the way complaints are handled are skewed to give too much control to the external dispute resolution schemes.The Australian Securities and Investment Commission regulatory guidance on handling disputes (RG 165) says licensees and credit representatives must have internal dispute resolution processes and be members of an EDR.The complainant can lodge their complaint with the credit provider or go straight to the EDR. If the EDR receives the complaint it will register the complaint and provide details to the credit provider. The credit provider has 45 days to deal with the complaint (or 21 days if it is a hardship case) before it goes back to the EDR.Credit Corp chief executive Thomas Beregi said: "It is a big change in our industry to have everyone in an EDR, and with all the publicity about the move to a national consumer credit scheme more people are going to EDR."In terms of dispute resolution we are not seeing anything adverse but we are having to commit a lot of resources to it."I don't see why the complainant can go straight to EDR and there is no protocol for internal dispute resolution as a first step."Financial Ombudsman Service banking ombudsman Philip Field said the rules were designed to set limits on the time available for resolving disputes. He said: "When we receive a complaint we notify the credit provider but we also start the clock."Field said credit providers could do more to ensure that complaints went to them first; they could communicate their dispute handling procedures better and they could put more resources into that part of their business."People tell us it is hard to find the credit provider's IDR and that is often because resources have not been put into it," Field said.Field said the Financial Ombudsman Service had not seen a big jump in complaints since June, but it is early days. He rejected a suggestion from one quarter that there were a large number of frivolous complaints. "That would be where there is no breach of the law or obligation and where there is no course of action."There are a very, very small number of cases where people are using the system to delay the inevitable."While Field believes some credit providers have under-resourced their dispute resolution schemes, mortgage market consultant Kym Dalton, a director of Saks Consulting, believes the EDRs are also stretched.Dalton said it was an issue that needed to be watched. "At the extreme, things getting bogged down in EDRs could impact the security enforcement process and negatively impact bond and RMBS investors' view of Australian lenders."