mandate. They specifically require financial service providers to
be responsive to complaints and inquiries received from consumers. They also advise entities to monitor and analyze complaints
to understand and correct weaknesses in processes that could
lead to potential consumer harm and violations of law. A strong
complaint management process that incorporates the following
methods will help a bank achieve more effective regulatory risk
mitigation and better customer satisfaction.
Banks have long embraced customer satisfaction as an integral
component of their strategic business objectives. Making sure a
customer receives satisfactory resolution to a complaint is the
subject of many training courses. Clarity of the customer satisfaction message is more important than ever—bank employees need
to understand the customer’s issue, be able to accurately respond,
or know how and to whom an issue should be escalated. A clear
standard definition of what the bank considers a “complaint” is
critical. Banks typically track all expressions of customer dissatisfaction, including those made in person, by phone, through
social media or through a third-party such as the Better Business
Bureau. These are in addition to those made in writing to the bank
and to the Bureau. Tracking consumer complaints is not easy as it
requires a clear understanding of how to recognize a complaint at
the front lines and within call centers, and a disciplined process for
capturing complaint information. Once a complaint is received,
it should be addressed swiftly and in a way that is acceptable to
the customer. In the process of addressing the complaint, the root
cause of the issue should be identified and necessary corrective
action taken before others have the same complaint.
Complaints are a form of customer feedback and the ability to
analyze them will allow a bank manage customer satisfaction and
regulatory risk more effectively. Collection of relevant information is imperative and maintaining a central repository for the
information is preferred, even in a small bank. Collecting the
right information and entering it into a complaint management
database or other system will help provide consistency of documentation, tracking, response, and analysis. Small banks may
implement database solutions in lieu of the software solutions
that handle larger volumes of data. Whatever type of system is
chosen, it should be sufficient to handle and facilitate analysis of
the number of complaints received by the bank.
The information that should be collected to facilitate analysis
should include the following in addition to the customer specific
■ ■ ■ Date the complaint was received by the bank
■ ■ ■ Channel (branch/in-person, customer service/phone, mail,
regulatory agency, Better Business Bureau, social media, website, other)
■ ■ ■ Type of product identified in the complaint (consumer loan,
mortgage loan, checking account, debt collection, loss mitigation, etc.)
■ ■ ■ Type of sub-product identified in the complaint (more specific type of loan such as automobile loan, mortgage refinance,
credit card, etc.)
■ ■ ■ Issue(s) identified in the complaint (e.g., continued attempts
to collect debt not owed)
■ ■ ■ Sub-issue identified in the complaint (e.g., debt was paid)
■ ■ ■ Consumer complaint narrative
Problem Customer complained about a $35 overdraft fee on a one-time debit transaction when they did not opt-in for overdraft services.
Why? The system is showing the “opt-in” field is checked so the customer must have affirmatively opted in.
In the case of in-person transactions, the bank’s procedure is to have the customer sign the disclosure checking the box that they
agree to opt-in for overdraft services or checking the box that they do not wish to opt-in. In this case, the bank could not locate the
imaged copy of the signed disclosure or evidence that it provided the consumer with confirmation of their consent in writing.
Why? The banker thinks the box for the customer opt-in consent was checked on the deposit platform system at account opening, but signed customer opt-in disclosure was not uploaded to the system.
Why? The banker forgot to image a copy of the consent disclosure and the system did not prompt the upload to the system.
The bank does not have evidence that the customer really did opt-in for overdraft services on ATM and one-time debit
transactions. The fee was refunded and the system box for overdraft opt-in unchecked. How many other customers may have
this same issue?
Yes. In the case of an in-person interaction, the system should be programmed to include a prompt for the banker to upload
a copy of the Overdraft Opt-In disclosure to provide evidence of the customer’s affirmative consent. If the upload cannot be
made mandatory, an exception report should be generated to identify instances where the transaction does not have an imaged
affirmative consent. Affected customers should be contacted to confirm their preference and the documentation and system
updated. Bankers should be provided training on the system enhancements and ongoing monitoring of performance.