--- title: "Complaint to a trustee or life insurer about a disability decision" url: "https://ailawframework.com/precedents/superannuation/super-disability-internal-complaint" type: "precedent" site: "AI Law Framework" id: "a27-super-disability-internal-complaint" area_id: "A27" kind: "letter" ai_level: "yellow" version: 1 task_ids: ["A27-PU20261022-1", "A27-TP20261023-4"] law_stated_as_at: "2026-10-23" --- # Complaint to a trustee or life insurer about a disability decision > A complaint to the trustee, or to the life insurer, about a decision on income protection or disablement cover held in superannuation, asking for the written response the Life Code describes.… Canonical page: https://ailawframework.com/precedents/superannuation/super-disability-internal-complaint Law stated as at: 2026-10-23 Site index for agents: https://ailawframework.com/llms.txt A complaint to the trustee, or to the life insurer, about a decision on income protection or disablement cover held in superannuation, asking for the written response the Life Code describes. It is not a complaint to AFCA. ## Key facts - Kind: Letter. A letter or email you adapt and send. - Practice area: [Superannuation](https://ailawframework.com/precedents/superannuation.md) - Jurisdictions: Victoria, Queensland, New South Wales - AI level: Yellow. You and the tool draft together, with you directing. You check every statement you rely on. - Law stated as at: 2026-10-23 - Status: Maintained. Checked on 2026-10-23 against the 5 authorities it cites, for Victoria, Queensland and New South Wales. ## When to use it Use when the member wants the trustee or the insurer to review a decision on cover held in the fund, before any complaint to AFCA. Do not use it as the AFCA complaint, or as a complaint about general insurance under the General Insurance Code. ## Used for these tasks - [Run the internal dispute resolution timetable for a fund complaint](https://ailawframework.com/practice/superannuation/run-the-internal-dispute-resolution-timetable-for-a-fund-complaint.md) - [Ask the trustee to pursue the insurer and to give reasons for a disability decision](https://ailawframework.com/practice/superannuation.md#A27-TP20261023-4) ## How AI may be used The lawyer and the tool draft the complaint from the decision and the instructions, and the lawyer checks each issue and the outcome sought before it is sent. **AI may:** - Identify the decision, its date and the issues the member wants reviewed - State the outcome sought in the words the lawyer has approved - Ask the trustee for a final written response within 45 calendar days where the policy is one the trustee owns **AI must not:** - Must not lodge this letter with AFCA or call it an AFCA complaint - Must not add an issue that is not in the instructions or the documents - Must not say the original decision is stayed - Must not promise that the 45 days will be met where the Code says "where possible" **The lawyer checks:** - The complaint goes to the trustee, the insurer, or both, matching who made the decision - The person asked to handle it was not the person who made the decision, as clause 7.5 describes - The AFCA time limit is diarised from the current Rules and is not calculated in this letter - Draft only in the firm's approved tool. In Victoria and New South Wales, do not disclose confidential client information without authority under Australian Solicitors' Conduct Rules r 9.2.1. A Queensland solicitor checks the local conduct rules. - If client information leaves the approved environment, check APP 11 and whether there is an eligible data breach under the Privacy Act notifiable data breach scheme. ## Authorities - [Life Insurance Code of Practice, applicable from 1 March 2025 (claims timeframes, reasons and documents, and complaints about cover a superannuation trustee owns)](https://lifeccc.org.au/resources/life-insurance-code-of-practice/) - [Superannuation Industry (Supervision) Act 1993 (Cth) s 52(7)(d) (covenant to do everything reasonable to pursue an insurance claim for a beneficiary if the claim has a reasonable prospect of success)](https://classic.austlii.edu.au/au/legis/cth/consol_act/sia1993473/s52.html) - [Legal Profession Uniform Law Australian Solicitors' Conduct Rules 2015 r 9 (confidentiality of client information)](https://legislation.nsw.gov.au/view/html/inforce/current/sl-2015-0244) - [OAIC, Australian Privacy Principles guidelines, Chapter 11 (APP 11: reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure)](https://www.oaic.gov.au/privacy/australian-privacy-principles/australian-privacy-principles-guidelines/chapter-11-app-11-security-of-personal-information) - [OAIC, Data breach preparation and response, Part 1 (Notifiable Data Breaches scheme in Privacy Act 1988 (Cth) Part IIIC: notify individuals and the Commissioner of an eligible data breach)](https://www.oaic.gov.au/privacy/notifiable-data-breaches/preventing-preparing-for-and-responding-to-data-breaches/data-breach-preparation-and-response/part-1-data-breaches-and-the-australian-privacy-act) ## Full text and drafting notes The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/superannuation/super-disability-internal-complaint and through the signed-in MCP connector https://ailawframework.com/mcp/firm. *Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*