Yesterday, I focused on the very basics. Today, I am moving onto the next 3 areas which are consumer oriented. The CFPB is highly sensitive to the consumer experience. After all, they were created to protect the consumer’s interest. Shining in this area of compliance makes you look like you are highly sensitive to the consumer experience as well.
Remember, that you need policies and procedures AND compliance management systems to monitor any consumer complaint, no matter where it comes from.
1. Customer Complaint System: A few months ago, I wrote about this topic and gave you some tips. If you did not get a chance to read it, look for the article called “I want to speak to your manager” in the discussion group or article archive. Or, you can just shoot me a message and I will send it to you.
In a nutshell, you will be required to demonstrate: How are complaints received? How are they compiled? How are they resolved? Within each of these questions there are many details. For instance, if you have an online presence how can a consumer get a complaint to the appropriate party?
To start this process, make a list of any possible ways a consumer may interface with your company. Some examples are online, loan originator, processor, bank lobby, etc. Do not forget to put the other ways a consumer can voice a complaint. Some examples are, social media, CFPB site, BBB, etc. Also, look for any barriers that may prevent a client from voicing their complaint or escalating their complaint. An example of this is “I want to speak to your manager” and that person hands the phone to the person beside them (co-worker). You are being “mystery shopped” so monitoring adherence to your policies and procedures is very important.
Next, put into place a complaint system anywhere one does not exist.
Once you have the list, break it down into written policies and procedures for complaint receipt, reporting, escalation and resolution. Also be sure to establish time frames that are consumer friendly.
2. Tracking and Acting on Consumer Complaints. It is not enough for the CFPB to see how you take in complaints. They also want to see how you monitor the handling of those complaints.
The CFPB wants you to show them how you use that data to take action on trending issues. This means someone needs to be responsible for taking in all of that data, reviewing it for trends, identifying problem areas and reporting that to compliance and executive management. Then compliance and executive management need to have a discussion as to what actions will be taken to correct any issues. This entire process should be documented.
3. Training: Employee education is another high priority area for the CFPB. They need to see:
a. What training is required or offered.
b. The required frequency.
c. How you manage attendance and comprehension.
d. Who does the training?
e. Do you have training sufficient for your staff to perform their duties to you and the consumer?
I am envisioning lots of spreadsheets and workflow models, how about you? P.S. the more visuals you have, backed up by written documents, the happier your examiner will be.