notwithstanding any other law, means any scheme or arrangement established by or for a financial institution, or a group of financial institutions, in order to resolve a client’s complaint by an ombud—
(a) | and includes any arrangement in terms of which resolution of the complaint is to be effected by mediation, conciliation, recommendation, determination or arbitration; |
(b) | but does not include any internal complaint resolution arrangement established by a financial institution either with or without any affiliate or subsidiary of the institution, nor the activities of the Ombud for Financial Services Providers, the Adjudicator and statutory ombud; |