■ ■ ■ Response status (in process, closed with explanation, closed
with monetary relief, closed with non-monetary relief, etc.)
■ ■ ■ Tags (to help identify categories of consumers such as service-members or elderly customers)
■ ■ ■ Date of bank response to consumer
■ ■ ■ Was response timely? If not, why?
■ ■ ■ Customer satisfied with response? If the answer is no, document follow-up or escalation.
■ ■ ■ Bank assigned risk rating (definitions for risk ratings may differ
by bank—it is suggested that any regulatory related complaints
regardless of source be rated “high” and escalated for compliance and/or legal department review prior to responding to
■ ■ ■ Other fields of data may be collected based on the bank’s products and services.
Whether collecting the information in person or through a
customer call center, make sure that documentation about the
complaint itself is clear. If abbreviations and shortcuts are used
in documenting issues, be prepared to define them for the outside reviewer. Keep in mind that auditors and regulators will
view the information and will need to readily understand what
transpired. Calls that are received through customer service or
a call center are typically recorded and should be periodically
reviewed to assess consistency in call handling among customer
Centralizing complaints and their processing will help ensure
that customers are receiving consistent and timely responses and
that potential changes to processes are based on the most comprehensive data.
By now, most banks are sorting complaint data by the various fields
collected and are reporting on trends and key issues identified by
month, quarter, and year to senior management and its Board
of directors. To manage complaints and their associated risks
effectively, management and the Board must understand what
gave rise to the complaints. Understanding “why” a complaint
surfaced will help identify needed process changes to mitigate
future complaints, retain customers, and limit regulatory risk.
One method of investigating complaints is The Five Whys,
a technique used in the Analyze phase of the Six Sigma Define,
Measure, Analyze, Improve, Control (DMAIC) methodology. It
is a simple technique that does not require the use of statistics or
other advanced mathematical tools. Basically, repeatedly asking
“Why?” enables one to weed through the layers of symptoms
and get at the problem’s root cause or the interdependent root
causes–certainly, a problem may have more than one root cause. It
may take fewer or more than five times of asking why to identify
the root cause, but once identified any needed process changes
can be implemented to prevent the problem, issue, or complaint
from recurring. Below is an illustration of how asking “Why?”
until the root cause is identified will provide more value than just
addressing the complaint on its surface. The end result may be
the same–the customer will receive a fee refund and the account
set-up will be corrected, but the bank should be able to avoid
future complaints by understanding how the complaint came
about and make adjustments to its process to prevent similar
future occurrences (See Table 1).
In most cases, the final “whys” should identify a root cause that
leads to a process improvement that if implemented will reduce
the bank’s complaints and its regulatory risk–in this case–citation
for non-compliance with the requirements for overdraft services
under Regulation E–Electronic Fund Transfer Act and potential
for Unfair, Deceptive, or Abusive Acts or Practices (UDAAP).
Once enough data has been accumulated, sorted, and patterns
identified, start asking “why”. For example, why are there so many
more complaints about the foreign ATM fee in one of the five
states your bank operates in than the other four? Is it coincidence
or is there an issue with the fee set up in your system for that
geography? Take a closer look at complaints that are similar in
nature to understand why they may be occurring. Chances are
if an issue happens for one customer, other customers are also
affected, but just have not complained…yet. Root cause analy-
sis has another added benefit. It shows employees the bank is
focused on making sure it is striving to do the right thing for its
customers and it inspires employees to do their best.
A comprehensive consumer complaint
management program is critical
for banks not only to meet their
strategic business objectives, but to
manage their regulatory risk.
Bureau Examination Objectives
■ ■ Consumer complaints and inquiries, regardless of where
submitted, are appropriately recorded and categorized.
■ ■ Complaints and inquiries, whether regarding the entity or its
service providers, are addressed and resolved promptly.
■ ■ Complaints that raise legal issues involving potential consumer
harm from unfair treatment or discrimination, or other regulatory
compliance issues, are appropriately escalated.
■ ■ Complaint data and individual cases drive adjustments to business
practices as appropriate.
■ ■ Consumer complaints result in retrospective corrective action
to correct the effects of the supervised entity’s actions when
■ ■ Whether weaknesses in the compliance management system exist,
based on the nature or number of substantive complaints from
Excerpt from Consumer Financial Protection Bureau Supervision
and Examination Manual, Version 2.0—October 2012