"While nobody suffered any financial loss, Co-op's actions meant that a significant number of people had the resolution of their valid complaints delayed for no good reason, " she added.
The reason behind the rise in customer complaints is unclear, but some franchisees say it could be partly because customers now have more ways to supply feedback.
The main reason for the rising number of complaints - to banks, insurers and then the Financial Ombudsman Service (FOS) - is that the possibility of this sort of change was sometimes not made clear in the first place.
Not surprisingly, the vast majority of complaints stem from issues regarding the handling of claims, which is the reason that people take out insurance in the first place.
Plaintiffs will be hard pressed to present sufficient proof to make a convincing argument on this point, which is likely the main reason that NFL member clubs have been kept out the majority complaints that have been filed.