The Auditor General’s 2022 RECO Audit: What Are Consumer Complaints Telling Us?
Featured Author: Leigh Morris | Educator and Consumer Advocate
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A consumer complaint is not just a file to investigate and close. It is data.
Each complaint contains information about what a consumer experienced, where a transaction may have broken down, whether professional obligations were understood, and whether a similar problem could affect someone else.
When complaints are examined only as separate files, the immediate issue may be addressed, but the larger lesson can be lost. When they are categorized, analyzed, and reported, they can become an important source of evidence about the health of an entire regulatory system.
That distinction was central to the Auditor General of Ontario’s 2022 value for money audit of the Real Estate Council of Ontario.
Significant Progress Since 2022
The 2022 audit contained 25 recommendations with 63 action items directed to RECO and the Ministry responsible for its oversight.
In the 2024 follow up, the Auditor General reported that 50 of the 63 actions, or 79%, had been fully implemented. One action, or 2%, was in the process of being implemented, while 12 actions, or 19%, showed little or no progress.
That is significant progress, and it should be recognized.
Recommendation 3, which dealt specifically with complaint data and systemic learning, was found to be fully implemented.
The original audit had examined approximately 11,700 complaints handled by RECO between 2017 and 2021. The Auditor General found that RECO did not track complaints meaningfully by type and therefore could not analyze them to identify systemic issues or trends.
In 55% of the complaints reviewed, RECO had not categorized the complaint or recorded any description of it. In the remaining 45%, the recorded category indicated only that the complaint involved an alleged violation of the Code of Ethics.
Without more useful categories, RECO could not determine which issues occurred most often, whether certain problems were increasing, or where corrective action might be needed. It was also unable to report publicly on the most common issues identified through the complaint process.
The Auditor General therefore recommended that RECO assign a descriptive category to each complaint, periodically analyze complaint data, address identified systemic issues, and report common and emerging trends publicly each year.
What Changed?
According to the 2024 follow up, RECO developed 50 descriptive complaint categories in August 2023. These included abuse and harassment, false and misleading advertising, care of property concerns, inadequate supervision during property viewings, and commission and remuneration issues.
RECO trained staff to use the new categories and created a standard operating procedure for reviewing complaint information. Monthly and quarterly reports were established for management review, along with a process for identifying statistically significant systemic issues and trends.
RECO also advised the Auditor General that it had begun quarterly analysis in the fall of 2023. Action plans arising from that analysis included targeted communications to the real estate sector and additions to mandatory continuing education. Complaint trends were then reported publicly in RECO’s April 2024 annual report.
These are important changes. They create the structure needed to move from processing complaints to learning from them.
What Could Complaint Data Tell Us?
Good complaint data can reveal much more than the number of files opened or closed.
It can show whether consumers repeatedly experience problems with disclosure, representation, advertising, deposits, offer processes, property information, communication, or supervision. It can help identify whether concerns are concentrated among individual registrants, within particular brokerages, or across the sector.
It can also help distinguish an isolated error from a recurring weakness in education, brokerage oversight, regulatory guidance, or enforcement.
That is why categorization matters. If complaints are not described consistently, patterns remain hidden. If patterns remain hidden, the regulator is left reacting one file at a time instead of identifying where broader preventive action is needed.
From Individual Complaints to Systemic Learning
The real value of complaint analysis lies in what happens next.
If a pattern is identified, does RECO issue clearer guidance? Does it revise mandatory education? Does it change an inspection priority? Does it examine whether broker of record supervision is contributing to the problem? Does it adjust enforcement or recommend a policy change to government? Most importantly, does it later measure whether the intervention worked?
A completed recommendation tells us that a system or process now exists. It does not, by itself, tell us whether consumers are better protected.
The stronger accountability test is whether the new complaint system leads to fewer repeated problems, earlier intervention, more consistent practice, and clearer public information.
Can Consumers See the Results?
Public reporting is a critical part of this recommendation because complaint information belongs to the public interest side of regulation, not only to internal management.
Consumers should be able to see the leading complaint categories, how those patterns change over time, what corrective actions were taken, and whether those actions produced improvement.
The information should be clear enough for an ordinary person to understand and detailed enough to support meaningful accountability.
Reporting totals without explaining categories, trends, responses, and outcomes would provide only a partial picture.
Transparency does not require publishing private details from individual complaint files. It requires publishing enough aggregated information for the public to understand what the regulator is learning and how it is responding.
The Next Accountability Question
The Auditor General’s follow up establishes that RECO created the complaint classification and analysis process it was asked to create. That is an important achievement.
The next stage is to demonstrate impact.
What patterns are emerging from the 50 complaint categories? Which concerns appear most often? What action has been taken in response? Have education, supervision, inspection, or enforcement practices changed? Are recurring problems declining? Can the public see the connection between the evidence, the regulatory response, and the result?
Strong governance does not simply measure activity. It uses evidence to improve decisions, tests whether those decisions worked, and reports the results honestly.
A complaint system should do more than bring individual files to a close. It should help prevent the next consumer from experiencing the same problem.
The question now is not only whether RECO is collecting better complaint data. It is whether that information is producing measurable improvements in consumer protection.
What are consumer complaints telling us, and how is that learning improving the system?
Leigh Morris | Educator and Consumer Advocate
Sources
Office of the Auditor General of Ontario, 2022 Value for Money Audit: Real Estate Council of Ontario
Office of the Auditor General of Ontario, 2024 Follow Up on the 2022 Performance Audit: Real Estate Council of Ontario
Office of the Auditor General of Ontario, November 30, 2022 news release
From my perspective, this is also why continued education and professional development matter. It is one of the reasons I recommend The Sharp Advantage. By helping REALTORS® strengthen their knowledge, judgment, and professional practices, programs like this can support not only stronger businesses, but better experiences for the consumers they serve.
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