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Consumer Complaint System

Who Do I Talk To?

What is your company complaint system?  This is one of the questions that will be asked by the CFPB examiner.  Remember, they want to make sure you handle the consumer well and handling their complaint is one of those tasks that require a policy and procedure.  CFPB is listening to your consumers, even if you aren’t.  When consumers complain to the CFPB it hurts you either through word of mouth, or may trigger a “targeted exam” if you have too many complaints.
Following is a baseline of what some lenders have learned to implement after their exams:
1. When you develop materials for the consumer, keep it simple and convey the message in clear and easy to understand terms.  Take a look at the CFPB site, and you’ll see that they do this quite well.
2. Build a strong process for consumer feedback.  It is not just about the one person that complains, but also about those who don’t and are dissatisfied.
a. Assign a consumer advocate to each department.  This does not have to be their full time job, but they should have the ability to solve an issue. Communicate who this person is to your applicants.  This can be done in the introduction to the consumer about your company.
b. What is the escalation process for customer complaints?  Every consumer should have access to the executive team.  We all know what it is like to try to seek resolution, and get passed around to a bunch of people who only have scripts, or don’t fix the problem.  If the consumer does not like the answer they were given, make sure your procedure includes access to the executive who can fix it (any position that starts with “C” such as CEO).
c. What is the exact process for receiving a complaint?  Emails, web access, social media?  Who monitors all of that and makes sure complaints or issues are dealt with?  I saw a lender Facebook page that was up, but not monitored.  Several unfavorable items were posted and no one was monitoring the comments.  Needless to say, that could severely affect your business.
d. Have some sort of follow up with all consumers to find out about their experience with your company.  I’m not talking about a paper survey or email.  I’m referring to a real person calling them and asking them how things went.
3. Build reporting functionality to track the complaint, the resolution and the type of issue. It is important to take this data and review trends with your staff and management team.  These reports will probably tell you areas of weakness and training opportunities. Your reports should include.
a. Type of complaint b. Name of Client c. Resolution d. What employees/departments were involved? e. What was the time frame for resolution?
4. Have your consumer advocate contact the client to make sure the problem is truly resolved.  This allows one more level of consumer “intimacy” and a way for you to double-check your internal methodology.
Having a consumer complaint methodology creates a customer centric environment that will serve your business well and also satisfy the needs of the examiners.



Tammy Butler, Master CMB

Author Tammy Butler, Master CMB

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