Consumer Complaint Management System Best Practices
It is no longer enough to have a robust "culture of service" in place to manage consumer complaints. You need a strong complaint management system. Here's why...
The regulators have long held that a strong consumer complaint management program is an important component of your regulatory compliance management system. With the recent CFPB proposal regarding the publishing of consumer narratives, it is more important than ever to have a powerful complaint management program in place.
The CFPB's proposal would allow a consumer narrative to be published publically with the other complaint information that is currently published, at the consumer's discretion.
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Consumer Complaint Management Best Practices
"Complaints may be indicative of a compliance weakness in a particular function or department," according to the FDIC. "Therefore, a compliance officer should be aware of the complaints received and act to ensure a timely resolution. A compliance officer should determine the cause of the complaint and take action to improve the institution’s business practices, as appropriate. An institution should also monitor complaints to and/or about third parties that are providing services on behalf of the institution.”
As you assess your consumer complaint management program, note that best practices may include:
- Complaint Management Policy
- How is a complaint defined? Do you have agreement on a complaint vs. inquiry vs. error resolution?
- What are potential sources of complaints (verbal complaints, written complaints, regulatory submissions, social media)? Do you treat them the same?
- Are there special procedures in place for high-risk complaints (e.g., claims of discrimination)?
- Complaint Management Process/Procedure
- How does the bank investigate and respond to complaints? "An institution should be prepared to handle consumer complaints promptly," according to the FDIC. "Procedures should be established for addressing complaints, and individuals or departments responsible for handling them should be designated and known to all institution personnel to expedite responses."
- Do you employ a centralized process to lend optics into what is taking place?
- Is there an independent resource gathering and analyzing the complaints?
- Are there clear roles and responsibilities defined? Who is the owner of resolving the complaint?
- Are response timelines defined?
- Is there front-line training and consistent interpretation in place? None of it counts if you do not have front-line awareness, adoption, and consistent execution.
- What is the training plan? Are there training tools and resources to ensure execution?
- Tracking and Reporting
- When a complaint is received, where does it go? How is it tracked or reported, and are the trends being monitored?
- Who owns the reporting to management (frequency, reason/nature of complaints, issue owner, issue resolution)?
- Does management review root cause analysis?
- The establishment of channels through which the entity can receive consumer complaints and inquiries. Such channels may include telephone numbers or email addresses dedicated to receiving consumer complaints or inquiries;
- The proper and timely resolution of all complaints;
- The recording, categorization, and analysis of complaints and inquiries; and
- Reviews for possible violations of Federal consumer financial laws.
Entities should organize, retain, and analyze complaint data to identify trends, isolate areas of risk, and identify program weaknesses in their lines of business and overall CMS.
Concerns about the Proposed Public Database of Consumer Complaint Narratives
The CFPB’s proposed policy would allow consumers' narrative descriptions to be published with their complaint. These comments would only be published if the consumer opts in, and financial institutions will have up to 15 days to respond before the comments are published.
The four reasons that the CFPB provides for this change are: 1. It would provide context to the complaint, 2. It could spotlight specific trends, 3. It could help consumers make more informed decisions, and 4. It could inspire institutions to compete based on consumer satisfaction. However, the publication of consumer complaint narratives raises concerns for financial institutions.
Industry publications have commented that adequate protection of their employees is not provided, that the potential for unverified and unsubstantiated data is problematic, and that the companies' response process and timeline should be reconsidered.
As we consider how institutions may be affected by the public database, it's important to note that it is similar to social mediums. On social platforms, there is no editing or validation that takes place. With that said, the CFPB will still be confirming that there is relationship between the consumer and the company before posting the complaint.
A Culture of Service is Not Enough to Ensure Compliance
When we conduct Fair Lending risk assessments, we ask if our clients have any complaints regarding Fair Lending, including any pricing, underwriting, marketing or steering complaints. Complaints are one of the primary trip wires for Fair Lending investigations. Smaller institutions, in particular, rely upon their "culture of service." In today’s world, that reply may not be enough.
Even if you have a "culture of service," you need a proactive complaint management program, proper training, and complaint management, tracking and reporting. There are too many public forums in play today to leave the complaint management aspect of your organization unmanaged! Today, consumers can go to Facebook, Twitter, or Yelp and share their perspective with their world. It looks like they may also head to the CFPB to syndicate their concerns with the public. A "culture of service" alone may not be enough to address the requirements of today's regulatory environment.
- CFBP Press Release
- Proposed Policy
- CFPB Supervisory Highlights: Complaint Management
- CFPB's Consumer Complaint Snapshot