rulebase-co Complaint deadline clocks
Regulated complaint handling runs on deadlines that are not negotiable and not business-as-usual SLAs: missing a final-response deadline is a reportable failure in several regimes, not a dashboard amber.
The arithmetic looks trivial and is not. Almost every hand-rolled complaint clock is wrong in at least one of the ways below, and the errors are systematically in the optimistic direction — they make you look compliant when you are not.
This skill does not know your deadlines
Deadline lengths and rules vary by jurisdiction, sector, product and complaint type, and they change. This skill deliberately hard-codes none of them. It gives you the clock mechanics; the deadlines come from your compliance function or the applicable rules, as configuration.
If you do not have an authoritative source for the deadlines, that is the finding — stop and get one. Computing precise breach counts against a half-remembered deadline is worse than not computing them, because it produces a number people act on.
The same applies to interpretation: whether a specific case breached, and whether a breach is reportable, is a determination for compliance and legal. Produce the clock and the evidence; do not rule.
The clock decisions that change the answer
1. When does the clock start? Options that all exist somewhere in practice: when the complaint was received by anyone at the firm, when it was identified as a complaint, or when it reached the complaints team. These can differ by days.
The gap between "received" and "identified" is the single most common source of understated breach rates. A complaint expressed in an ordinary support ticket on the 3rd, recognised as a complaint on the 11th, and clocked from the 11th, understates the age by eight days — and in most regimes the clock started on the 3rd. Measure and report identification lag separately; it is both a compliance exposure and a training finding.
2. Business days or calendar days? Different deadlines in the same regime often use different units. Business-day counting needs the working-week definition and the holiday calendar, per market. A multi-market operation needs one calendar per market, and getting this wrong is worth days on every case.
3. Does day counting start on the day of receipt or the next working day? A one-day systematic error across every case. State the convention.
4. Can the clock pause? In many complaint regimes it cannot — waiting for information from the customer does not stop a final-response deadline, even though it stops an ordinary support SLA. Do not import a pause rule from your support SLA configuration. If your regime does permit pauses, they will have conditions attached.
5. What satisfies the deadline? Sent, or received? A response drafted on time and sent late is late. A holding response may satisfy one deadline and not another.
6. Which timezone? Deadline arithmetic across a timezone boundary is off by a day at the margin, and the margin is where breaches are.
Compute it
node scripts/complaint-clock.mjs --input complaints.jsonl --config clock-config.json
The config carries your working week, holidays per market, and one entry per deadline — its length, unit, what it runs from, and what satisfies it. See references/clock-config.md for the shape and the conventions each option implies.
The script reports, per complaint and per deadline: the due date, whether it was met, breached, or is still open, and how long is left. Open cases are bucketed by urgency so the output is a work queue rather than a report.
Monitoring, not reporting
A monthly breach count is an autopsy. The useful artefact is a daily queue of cases approaching a deadline, ordered by time remaining.
- Alert with enough lead time to act. A final response needs drafting, review and sometimes approval. An alert on the due date is not a control.
- Escalate on the approach, not the breach.
- Include cases with no owner. An unassigned complaint accrues deadline the same as an assigned one, and unowned cases are over-represented in breaches.
- Watch identification lag as its own metric. It is where the hidden breaches are.
Traps beyond the arithmetic
- Reopened complaints. Does a reopen restart the clock, continue it, or create a new complaint? A defensible answer is required and it must be applied consistently.
- Complaints spanning several conversations. One complaint may have three tickets. Clocking each separately understates age and multiplies the case count.
- Complaints arriving through channels nobody monitors — a review site, social, a regulator's portal, a letter. If they are not in the dataset they are not in your breach count, and their absence is not evidence of compliance. State which channels the data covers.
- Complaints closed without a final response. Check for cases closed with no response artefact. These are breaches that look like successes in a status-based report.
- The severity of a small number. Complaint volumes are low enough that a single breach can matter and percentage-based reporting hides it. Report absolute counts, always, alongside any rate.
- Retrospective reclassification. A case reclassified as a complaint after the fact inherits the original receipt date. Recompute historical breaches when classifications change, rather than freezing them.
Guardrails
- Do not assert a deadline length from memory, in the analysis or the config. Source it, and record the source in the config so the next person can check it.
- Do not determine whether a breach is reportable. Flag it, with the evidence, and say the determination belongs to compliance and legal, who may have a notification clock of their own that starts when they are told.
- Do not adjust a clock to avoid a breach. Changing a start date, applying a pause the regime does not allow, or reclassifying a complaint to move a deadline is a serious matter. If the data shows any of these happening, that is a finding in itself and it outranks the breach count.
- Read-only. Do not update complaint records.
- Cite ids; do not paste complaint content. Complaint files contain financial circumstances, health disclosures and vulnerability information.
Present results to the user
- The clock configuration used, including the source of each deadline, the working week, the holidays, the pause rule, and the start-date definition. Everything that follows is conditional on this.
- Channel coverage — which intake routes are in the data and which are not.
- Breaches, in absolute counts as well as rates, per deadline type.
- Identification lag, distributed, with the cases where it changed the deadline.
- The open queue, ordered by time remaining, with owners and the unowned called out.
- Cases closed with no response artefact, separately — the breaches a status report hides.
- Anything suggesting a clock was adjusted rather than a deadline met.
- What needs a compliance determination rather than an operational fix.