■ ■ origin: A complaint can come through various channels. It can
go directly to a frontline employee, through executive management, from a regulatory or consumer protection agency, or
even from Facebook or Twitter (if the bank does have a social
media presence, be sure to acknowledge that channel in the
complaint management program). A program’s definitions
should help shrink the “gray area” so that employees know
when and how to appropriately handle and/or escalate a
complaint or inquiry.
■ ■ roles and responsibilities: A complaint management program will not function unless everyone understands her or
his role and is held accountable. The program must define
who responds to a complaint, when a complaint should be
escalated, who it is escalated to, and what steps should be
taken when it is received.
■ ■ strict submission and response timelines: After a bank
decides what complaints need to be escalated
and whether they are handled in the field or
No one expects an
error-free environment
and perfect compliance
all of the time, but
there needs to be a
mechanism in place
to recognize when
an error is isolated or
when there is a bigger
issue to be addressed.
by the individual business unit, it must set standards about
how quickly they are escalated, when research or investigation
is initiated, and what the timeframes are for responses to the
consumer. A bank should have a standard response time for
complaints, even if it has different levels of complaints. This
response time should mirror the bank’s strictest regulatory
timeline or a consumer protection agency’s timeline. For example, if X Bank’s response timeline is within 10 days and that
is the shortest timeframe out of all outside parties processing
complaints against it, then the bank’s standard response time
for all complaints should be within 10 days.
■ ■ system to receive complaints from across the Bank: Even
if a bank doesn’t send every complaint to a centralized area,
a system must be set up to escalate high-risk complaints in a
repeatable manner. Because complaints can come through
many different channels, a system to funnel them to one place
is also important. Depending on its size and diversity of business units, a bank can implement a simple online survey tool
or complex interfacing database to log complaints. If some
complaints aren’t escalated and submitted to a centralized
area, each business unit should have a way to capture them
for more general oversight.
■ ■ centralized tracking, trend Analysis, and reporting: After complaints are recorded, investigated, and handled, there
needs to be a process for analyzing and monitoring them to
determine trends. Banks must determine whether complaints
revolved around the same issue, how they stacked up year
over year, how they were received, whether they were fault or
no-fault, and whether they were of the service or regulatory
variety. Timely and ongoing reporting to management and
the board is critical. No one group should be the only keeper
of complaint information. It needs to be shared.
■ ■ record retention: Banks need to look at who’s retaining the
complaints, what is being retained, and how long it’s held.
Those issues should be addressed in the program’s record
retention standards for all complaints, including complaints
that might be handled in the field or by a business unit and
not be escalated to a centralized area.
■ ■ training, tools, and resources: A program can’t be rolled out
with the expectation that it will just work and be understood by
everyone. The bank needs to continually train employees and
provide ongoing tools and resources to ensure that standards
are continually met.
■ ■ monitoring: Just as the complaint activity must be monitored,
so does the program. A bank must annually review the effectiveness of the program and make adjustments as needed.
Monitoring should include a review of a business unit’s non-escalated complaints to ensure they were categorized correctly
and that red flags or trends were not missed.
