What the #!@$?: Managing Customer Complaints
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Transcript of What the #!@$?: Managing Customer Complaints
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What the #!@$?...
Managing Customer Complaints
and Creating Positive Customer
Experiences
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Imagine If you could…
…identify competitors’
strengths and
weaknesses?
…detect and
address regulatory
risks before they
result in costly
fines?
…identify key
customer pain
points to improve
the customer
experience and
drive retention?
Analysis of the Consumer Financial Protection Bureau
(CFPB) complaint database can help you identify key
issues early on and uncover emerging trends to reduce
your risk and costs.
2
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Research is clear: increase in revenues for
card issuers driven by improved experience
Total
revenue
potential
Churn
reduced
Add’l
purchases
Word of
mouth
Temkin $246M $91.8M $82.3M $72M
Forrester $307M $83M $213M $12M
• Incremental purchases from existing customers in the same year.
• Revenue saved by lower churn.
• New sales driven by word of mouth.
3
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Many companies have voiced their concern
about the CFPB and the complaint database
Concerns about the database:
• Complaints are not verified for accuracy
• Not representative of the population as whole
• Cannot determine if complaints are related to dissatisfaction or misunderstanding terms of service
• However, analysis of issues in the CFPB can help you determine where the customer experience is falling short
4
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0%
2%
4%
6%
8%
10%
12%
14%
0%
5%
10%
15%
20%
25%
30%
35%
40%
January February March April May June July August September October November December
Social Media and CFPB comparison (percent of total)
Social media CFPBSources: Nilson report 2012, CFPB, Beyond the Arc
Social media comments about Citibank APR
show sharp spike in May
5
January 2012 – December 2012
So
cia
l M
ed
iaC
FP
B
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6
• How's this for cynical capitalism. Rang up Citibank to pay-off and close my credit card. The lovely lady in the Philippines asked me why and I said: your interest rate is far too High (21%) and she said Well I'm now willing to lower your rate because you are such a valuable customer .....Well if that's the case, why didn't you drop it earlier?‘
• Now that I am close to paying off almost all of my credit card debt, it feels so good to tell these credit card companies they have to drop my interest rate to something competitive… Citibank can kiss my a$$ with their terrible outsourced customer service.
Citibank APR sample comments
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Companies are responding more quickly
7
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Regions had double the % of untimely
responses as the #2 bank First Niagara
8
0
2
4
6
8
10
12
14
16
18
20
Regions (68) First NiagaraBank (9)
USAASavings (11)
People'sUnited Bank
(3)
Bank ofAmerica
(123)
PNC Bank(34)
Navy FCU(3)
Comerica (3) M&T Bank(4)
BMO Harris(1)
Untimely responses as a percent of issuer's total*
Sources: CFPB, Beyond the Arc*Minimum 30 complaints
Note: Number in parenthesis is number of untimely responses
Untimely Response = 60 days or more for company to respond to complaint
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Consumers are disputing fewer responses
9
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Referrals were the top method of submission
to the CFPB with over half of the complaints
10
Sources: CFPB, Beyond the Arc
0
1000
2000
3000
4000
5000
6000
7000
8000
Referral Web Phone Postal mail Fax Email
Submission method - number of complaints
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How do customer problems become complaints?
11
Customer experiences a
problem
Customer provides feedback
Bank addresses problem
Resolution
Files complaint with CFPB
Closes account(s)
and / or Customers often try
multiple time to resolve their problems
Bank does not address problem
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How can we identify and address these
issues so they don’t escalate?
12
Customer experiences a
problem
Customer provides feedback
Bank addresses problem
Resolution
Bank does not address problem
Files complaint with CFPB
Closes account(s)
and /or Customers often try
multiple time to resolve their problems
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We need to focus on collecting, analyzing,
and tracking customer feedback
13
Customer experiences a
problem
Customer provides feedback
Bank addresses problem
Resolution
Bank does not address problem
Files complaint with CFPB
Closes account(s)
and /or Customers often try
multiple time to resolve their problems
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Voice of the Customer analysis is the key to
preventing feedback from escalating
• Voice of the Customer (VOC) analysis allows you to:
– Identify customer pain points to improve the customer
experience and drive retention
– Detect regulatory risks and
address them before the CFPB
takes punitive action
14
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Include external measurements to create an
integrated view of the customer
InternalData from across the enterprise
o Customer feedback
o Frontline notes
o Transactional data
o Behavioral data
SocialSocial media about you and your competitors
o Twitter
o Facebook
o Blogs
RegulatoryCustomer complaints
o Federal
o State
o CFPB
The CFPB database is a meaningful data
source to incorporate into your VOC
program
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• Determine key metrics
– # of CFPB credit card complaints
– # of untimely responses
– Volume of credit card related customer feedback
– Call volume to credit card customer service
• Translate metrics into ROI– i.e. Savings = (Reduction in call volume) * (average call time) * (employee hourly wage)
Measuring your results is the key to a successful VOC
program
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Flagstar Bank leads all other banks in the number
of mortgage complaints per $ billion in mortgages
17
0
10
20
30
40
50
60
70
80
90
100
Flagstar Bank Bank ofAmerica
EverBank JPMorganChase
HSBC Wells Fargo SunTrustBank
M&T Bank PNC Bank Citibank
Co
mp
lain
ts p
er
bill
ion
do
llars
Company complaints per billion dollars in mortgages
Sources: Beyond the Arc, CFPB, www.ffiec.gov/
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Flagstar also leads all banks in mortgage
complaints per $ billion on a monthly basis
18
0
1
2
3
4
5
6
7
8
9
10
Apr2012
May2012
Jun2012
Jul2012
Aug2012
Sep2012
Oct2012
Nov2012
Dec2012
Jan2013
Feb2013
Mar2013
Apr2013
May2013
com
pla
ints
pe
r b
illio
n d
olla
rs in
mo
rtga
ges
Monthly trend - number of complaints per billion dollars
Flagstar Bank
Bank of America
EverBank
JPMorgan Chase
HSBC
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Customer reviews of Flagstar Bank on social
media reflect a negative mortgage experience
• Flagstar Bank received only 2 out of 5 stars on mybanktracker.com
• Many negative customer comments referenced mortgages:
– What a horrible experience it has been to buy my first house thank you Flag Star for that. They will do anything to benefit themselves and make your life miserable. So many things that I find hard to believe are even legal.
– We have had nothing but problems from this our Flagstar mortgage. I don't have the characters to explain all of our complaints, but I can't even imagine half of what they've done is even legal.
– If anyone suggests to use Flagstar as your mortgage company - run as fast as you can. They are a nightmare!
19
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A poor customer experience causes attrition, hurts
the brand, and can lead to financial penalties
• Flagstar Bank has paid over $200 million due to the quality mortgage and home equity backed securities:
– $105 million to Assured Guaranty to “settle allegations it misrepresented the quality of loans backing securities”
– $110 million to MBIA Insurance Corporation for “lying about the quality of loans backing $1.1 billion in securities”
• By monitoring social media, the CFPB database, and other publicly available data, Flagstar Bank can address gaps in the customer experience and prevent:– Damage to the brand and the ability to attract new
customers
– Further potential legal penalties20
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Citibank leads all other banks in the number
of student loan complaints per $ billion
21
0
20
40
60
80
100
120
140
160
180
Citibank AES/PHEAA KeyBank NA Discover JPMorganChase
Wells Fargo Sallie Mae U.S. Bancorp Bank ofAmerica
SunTrustBank
Co
mp
lain
ts p
er
bill
ion
do
llars
Company complaints per billion dollars in student loans
Sources: Beyond the Arc, CFPB, www.citigroup.com
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Citibank’s student loan issues are reflected
in social media as well• Customers expressed difficulties with the transferal of their
loans from Citibank to Discover *:
– Unbeknownst to me, a portion of this additional payment was going towards interest! So basically, I am paying the minimum payment and 10% of the additional I am adding to principal was going into Discover's pocket as interest!!! It's ridiculous!
– I got a notice yesterday that Citibank somehow made a mistake and forgot to add the appropriate amount of interest to my principal loan balance to the tune of almost $4,300. Really? I have a huge problem with this
• Citibank can monitor the CFPB database and social media to identify customer experience issues and take action before they escalate into negative brand sentiment
22
* Comments taken from Citibank student loan page on Consumer Affairs.com
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Complaint volume shifts in September, when
Citibank notified its customers of the transfer
23
0
10
20
30
40
50
60
Mar2012
Apr2012
May2012
Jun2012
Jul2012
Aug2012
Sep2012
Oct2012
Nov2012
Dec2012
Jan2013
Feb2013
Mar2013
Apr2013
May2013
Number of complaints per month
Citibank
Discover
September 2012, Citibank
sends notice out to its
customers informing them
about their student loan
transfers to Discover
Sources: Beyond the Arc, CFPB
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The 5 bank account and servicing issues
trended form March 2012 to March 2013
24
Sources: CFPB, Beyond the Arc
0
5
10
15
20
25
30
35
40
45
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
The 5 issues as a percent of total complaints
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
1195 1259 1662 1401 1302 1267 1096 1219 962 942 1253 1086 811
Note: Bar graph represents total number of complaints each month
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PNC’s issue trend from March 2012 to
March 2013
25
Sources: CFPB, Beyond the Arc
0
10
20
30
40
50
60
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
PNC Bank - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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BOA’s issue trend from March 2012 to
March 2013
26
Sources: CFPB, Beyond the Arc
0
20
40
60
80
100
120
140
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
Bank of America - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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Capitol One’s issue trend from March 2012
to March 2013
27
Sources: CFPB, Beyond the Arc
0
5
10
15
20
25
30
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
Capitol One - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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Citibank’s issue trend from March 2012 to
March 2013
28
Sources: CFPB, Beyond the Arc
0
5
10
15
20
25
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
Citibank - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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TD Bank’s issue trend from March 2012 to
March 2013
29
Sources: CFPB, Beyond the Arc
0
5
10
15
20
25
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
TD Bank - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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RBS Citizens’ issue trend from March 2012
to March 2013
30
Sources: CFPB, Beyond the Arc
0
5
10
15
20
25
30
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
RBS Citizens - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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Chase’s issue trend from March 2012 to
March 2013
31
Sources: CFPB, Beyond the Arc
0
10
20
30
40
50
60
70
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
Chase - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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US Bancorp’s issue trend from March 2012
to March 2013
32
Sources: CFPB, Beyond the Arc
0
5
10
15
20
25
30
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
US Bancorp - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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SunTrust Banks’s issue trend from March
2012 to March 2013
33
Sources: CFPB, Beyond the Arc
0
2
4
6
8
10
12
14
16
18
20
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
SunTrust Bank - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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Wells Fargo’s issue trend from March 2012
to March 2013
34
Sources: CFPB, Beyond the Arc
0
20
40
60
80
100
120
140
160
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13
Wells Fargo - 5 issues (number of complaints)
Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card
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U.S. Bancorp (NYSE: USB), with $355 billion in assets as of March 31,
2013, is the parent company of U.S. Bank, the 5th largest commercial
bank in the United States. Celebrating its 150th anniversary this year,
the company operates 3,080 banking offices in 25 states and 5,056
ATMs and provides a comprehensive line of banking, brokerage,
insurance, investment, mortgage, trust and payment services products
to consumers, businesses and institutions. Visit U.S. Bancorp on the
web at www.usbank.com.
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Customer Experience
Office
Measurement
Customer Experience Managers
Strategic
Initiatives
Branch Engagement
VoC/ECU
Reporting
ECU -Executive Complaints
Speech Analytics/
Other Initiatives
2009
2011
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Social
Media
Team
CXO
Pro
ject M
anagem
ent O
ffice
Our Customers, Team Member & Shareholders
Voice of the Customer Team
Com
plia
nceLending
Retail
24HB
Support
Teams
Payment
s
Mortgag
e
Small
BusinessOnline ATM
Executive Sponsorship
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Creative Team Production Team
• Product and
Development• Front Line & Support
CXO
• Provide Insights
• Connect the dots
• Ad Hoc Reports
Work Together
Interchangeable
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Voice of the Customer Team - Putting it together
A
N
A
L
Y
S
I
S
Surve
y
Feed
back
PRT
Othe
r
PMO, TOS,
Compliance
Action
Plan
Communicatio
nCelebration
Retail
Payment
Solution
24BHFS
Retail
Banking
CXO
Implemen
t
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Sources & Data
Various places
Analysis & Reporting Sharing
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• Enhancements and Edits – Categorization and Models
– Reports based on likes and use
• Consistency– Trend & Extract Reports
– Collaboration meetings & follow up
• Deep Dives– Hot topics
– Root Cause
– Complex stories
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Commitment Is Key
In the wonderful musical 1776, there is line inspired by words John Adams
once addressed to his wife Abigail –
"Commitment, Abby – commitment! There are only two creatures of value on
the face of this earth – those with a commitment, and those who require the
commitment of others."
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Dashboards
Executive Recaps
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Ad Hoc with purpose
• Know/Don’t Know/Need to Know More– Discover/Deep Dive
– Use theme detection, Relationship Reports
• Special Events or Situations– Review volume/scale
– May be very specific phrasing or words
• Use Attributes– Can be telling for root cause
– Collaborate telling the story
Beware: Don’t Fall Into
the Pit Not efficient or effective
Can be hard to find your way
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Our Customers, Team Member & Shareholders
Reprise, Celebrate Everything, &
SHARE THE WINS!
Often, Regularly & All Ways
Intranet ArticlesInternal Social Media
Newsletters/
Emails
Division Calls
Internal CXO site
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Performance Reviews/Lessons Learned
• Regular meetings with
whole team (2x month)
• Top Categories easy to
identify
• Effort across enterprise
• Educate, (ABC’s of
analytics & reports)
• Plan on refinements
• Set Expectation with
data imperfections
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• Take the time for “unique” opportunities
– Employee Survey’s
– Special Situation Surveys
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Change in
Conversation
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Preview of Upcoming Events
• Clarabridge Collaborate
– Currently Piloting
– Use to Distribute reports automatically
• Explore – Auto load sources
• Expanding sources and VoC Team
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Thank you & Questions
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Consumer Complaint ProcessElizabeth Clarkson
Umpqua Bank
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Agenda
• Why you need an effective complaint
management program
• Key considerations for an effective complaint
management process and program
• Walk through complaint analysis and report
example
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Why?
• Regulatory Requirement
• Increase Customer Satisfaction (customer
retention)
• Identify Opportunities to Improve Products and
Services
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Regulatory Expectations
• Develop an enterprise-wide program for
overseeing the customer complaint process
• Compile, analyze, and summarize customer
complaints across the enterprise
• Use data to improve customer experience
• Robust Governance
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Barriers to Successful Complaint
Management Program
• Lack of Standards (definitions, categories, etc.)
• Lack of, or different processes to receive, track, report
• Lack of responsibility and accountability at business unit
level
• Program separate from the Bank’s customer service
standards/culture
• Program’s scope too narrow or too broad
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Elements of a Successful
Complaint Management Program
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Start with Defining a Complaint
• Any expression of dissatisfaction with a product, service or
business practice that a customer or non customer has
experienced at your organization
• Includes verbal (person/phone) and written
(paper/electronic)
• Received through various channels
– Regulatory Agencies
– Consumer Protection Agencies (BBB)
– Frontline, Call Center, Online
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Define When it is Not a Complaint
• Issue resolved in normal course of business
• Routine service request/issue: account balances,
transaction questions (missing or unauthorized)
• Disputes with a separate resolution process (Reg E, billing
disputes)
• Legal issues with separate resolution process (lawsuit,
contract dispute)
• Negative customer feedback in Bank sponsored surveys
• Negative customer feedback on non-Bank sponsored sites
(Blogs, Twitter)
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Refining the Complaint Definition:
Regulatory Complaints
• Must be in writing
• All complaints submitted to a regulatory or consumer
protection agency
• All complaints submitted to Bank claiming a regulatory
issue or violation:– Services performed by third-party vendor/service provider
– Privacy or disclosure of NPPI
– Allegation products, services, or promotion misleading, abusive, or
deceptive
– Accuracy of deposit or loan disclosures
– Allegation of discrimination or unfair treatment in regard to application or
servicing of loan
– Community Reinvestment Act concerns
• Keep definition broad
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Non-Regulatory Complaints
• Verbal complaints
– Responded directly by the receiving Business Unit associate and
escalated as necessary
• Written complaints
– Doesn’t fit regulatory definition
– May be related to Bank’s policies or procedures, and/or non-
regulatory service issues
– Train associates if not sure, then ask
• Each business area responsible for procedures on
– Investigating & Responding
– Documenting, Retention, Tracking, and Monitoring
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Complaint Management Standards apply to
Social Media
• Negative posts on bank-sponsored sites (Bank’s
Facebook and Twitter) = Written
• A Rapid Response Team
– Facebook and Twitter monitored and responded to daily
– Complaints meeting regulatory definition are escalated per
standard process
• Monitor negative comments on other Social Media (Blogs,
Twitter, Facebook)
– Categorize by sentiment (positive, neutral, negative)
– Negative posts reviewed for trends
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Complaint Management Process Standards
• Link to Customer Service Standards
• Roles and Responsibilities
• System to receive complaints from across Bank
• Strict submission and response timelines
– Applies to all complaints
• Record retention standards
• Training, Tools, and Resources
• Centralized tracking and trend analysis
• Reporting
• Ongoing Monitoring
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Reference Tools & Resources
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Complaint Decision Tree
Written
(By letter, email, or website)
Determine if Non-Regulatory
Follow Business Unit Complaint Procedures
Resolve and retain documentation per
Business Unit Complaint Procedures
Determine if Regulatory
Log and indicate which regulation(s) apply, if
known
Compliance will facilitate a response within 15
calendar days of receipt of complaint
Verbal
(In person or over the phone)
Handled on the Spot/ Escalate as Necessary
Resolve per Business Unit procedures on verbal
complaints
1) Determine which type of complaint you received
(Written or Verbal)
2) If the complaint is Written and Regulatory
complete the Written Complaint Log, otherwise
consult Business Unit Complaint Procedures
For more information about complaints see the
Complaint Procedures or contact Compliance at
compliancedept@
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Training Elements
• Communicates Bank’s attitude toward customer
complaints
• Provides real life examples of what is and what isn’t a
complaint
• Defines the types of complaints
• Provides examples of regulatory complaints
• Shows how to submit a regulatory complaint
• Tests knowledge
• Consider customizing for each business area
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Annual Review of Program
• Review all elements of the Program
• Review the non-regulatory complaint process
– Ensures Business areas are executing program appropriately
• Test Associate knowledge of policies and procedures
• Use results to enhance and expand the Program
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Analysis & Reporting
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Trend Analysis
• Type, Regulation, Volume…
• Potential Regulatory Issues
– Investigation not admission
– UDAAP
• Applies to non-regulatory complaints
– Business unit/area analysis
– Customer contact points
• Looking for red flags/opportunities
– Couple with Compliance Monitoring Activity
– Third Party Risk Management
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Reporting Elements
• Compliance reporting is focused on regulatory complaints
– Include Social Media and/or Service trends
• Summarize recent complaint activity and impact, so audience gets a
little detail behind the numbers
• Categorize complaints for better trend analysis
• Year over year trending
• Distribution
– Internal Compliance Committee
– Executive Management
– Board
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Analysis & Sample Report
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Executive Summary:
•# of new complaints received since last report.
•Details on at fault complaints, service versus regulatory.
•Trends in complaints with regulatory issues “UDAAP risk has broadest applicability and remains the most common regulatory category investigated, but no UDAAP issues identified year to date.”
•Industry or environment highlights: “CFPB began accepting all types of consumer complaints with quarterly reports issued publicly”
•Analysis of social media sentiment (Facebook, Twitter, Blogs) provides additional tool to identify potential negative trends in consumer sentiment.
Assets Complaints
Projected Actual (YTD) Identified Bank Fault (YTD)
Direct to Bank
%
Regulatory Agency
%
Complaints by Referral Source
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Customer Complaint Type
& Totals
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Complaint by Type 20XX YTD
Deposit Process or Service X X
Account Authority/Suspected Fraud X X
Credit Reporting Dispute X X
Fees X X
Item Processing/Funds Availability X X
Loan Modification/Resolution X X
Loan Origination/Decline X X
Loan Servicing X X
Physical Environment/Safety X X
Privacy/Info Sec X X
Vendor Management X X
Affiliate X X
X X
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Customer Complaints by
Potential Regulation
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Complaints by Reg YTD
Non-Regulatory
Fair Lending - Equal Credit Opportunity,
FHA, etc.
CRA - Community Reinvestment Act
Reg E - Electronic Funds Transfers
GLBA Sec 305 - Insurance Customer
Protections
Reg CC - Availability of Funds
FCBA - Fair Credit Billing Act (Billing and
Collections)
FCRA - Fair Credit Reporting Act (Using and
Sharing Credit Report Information)
Flood - Flood Insurance requirements
GLBA - Privacy and Information Security
RFPA - Handling government requests for
Financial Information
TIL - Truth in Lending
RESPA - Real Estate Settlement Procedures
Act
TIS - Rates - Truth in Savings Rate issues
TIS - Fees - Truth in Savings Fee issues
UDAAP - Unfair, Deceptive or Abusive Acts
or Practices
ADA - Americans with Disabilities Act
State Reg - State-specific Regulations
Affiliate
Non-Reg% Fair Lending
%Reg E
%
GLBA%
TIL%
TIS - Rates%TIS - Fees
%
UDAAP%
Vendor%
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Summary of Complaints
with Bank Fault Identified
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• Bank Fault – Service– Summary
• Bank Fault – Regulatory– Summary
Service%
Fault Not Yet Determined
%
No Bank Fault
%
Complaints - Bank Fault Identified YTD
No Bank Fault%
Fault Not Yet Determined
%
Deposit Process or Service
%
Loan Origination/
Decline%
Loan Modification/ Resolution
%
Bank Fault - Complaints by Type YTD
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Social Media Monitoring Results
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Sentiment Social Media Posts
Negative #
Neutral #
Somewhat Positive #
Positive #
Negative Sentiment
Breakdown of Negative Social
Media Posts
Incidental Mention - Post
mentions Bank, but negative
comment(s) not directed at Bank #
NASDAQ - Post addresses
Company Stock #
Corporate Concern - Post
addresses Bank corporate
practices (not consumer related) #
Non-Specific Consumer Concern - Unspecified consumer
dissatisfaction #
Non-Regulatory Consumer Concern - Specific non-regulatory
concern (e.g., service related) #
Regulatory Consumer
Concern - Specific regulatory
concern #
Negative%Somewhat
Positive%
Positive%
Social Media Sentiment – YTD 2012
Incidental Mention
%NASDAQ%
Corporate Concern
%
Non-Specific Consumer Concern
%
Breakdown of Negative Social Media Sentiment – YTD 2012
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Successful Costumer Complaint Program
• Link with Bank’s customer service standards
• Broad definition of Complaint
– Broad Regulatory Complaint Definition
• Communicate expectations/standards
– Formal, documented, communicated, tested
• Procedures, Tools, and Training
• A system to receive complaints from across Bank
• Robust and meaningful analysis and reporting
• Ongoing monitoring & continual enhancements
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Lessons Learned
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CFPB Top 10 Lessons Learned
1. It’s a whole new ball game
– It’s nothing like a Fed/OCC exam
– New relationships to build
– Need to build credibility
– They have political agendas
– They get to make the rules as they go
– Emphasis on enforcement
2. They view everything from the customer’s perspective
– It’s all about the customer
– Heavy focus on UDAAP
– They start with complaints and then work their way backwards
– Compliance management is kind of the last stop – versus with the Fed/OCC it’s the first stop
– When putting together your materials for them, focus on the customer experience
– Good idea to involve 1WF
– Therefore, it is important to emphasize programs, processes, and policies that focus on
customer advocacy, complaint management, call monitoring, voice of the customer, etc.
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CFPB Top 10 Lessons Learned (Cont.)
3. It’s all about the data, data, data……
• Initial request
• Many follow up questions
• Oftentimes it feels like they don’t even look at the data – feels like they’re stockpiling it for later…
• Need to establish process for managing data requests
• Request letters are very comprehensive and responses require a tremendous amount of data
• Recommendation: Establish a process so that all requests are funneled through one person in
order to manage expectations and ensure some level of control.
4. Documentation is key
• Policies, procedures, notes in files, exceptions, etc.
• EVERYTHING must be documented
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CFPB Top 10 Lessons Learned (Cont.)
5. They think “surprise” is a good thing
• They appear to have a set of “rules” that they are using to exam us against – unfortunately, we
don’t have the rule book
• Ex. Limit of 1 rebuttal
• They are communicating their expectations through enforcement actions
6. Exam process is much more complicated
• Legal review required of all documents
• Legal review is required of ALL materials provided to the CFPB. This includes not only LOB
legal, but “CFPB-focused” lawyers as well
• Legal needs to be represented during all meetings with the CFPB
• Recommendation: Schedule regular checkpoint meetings once the examination starts. It will
provide an opportunity to ensure examiners have what they need, address any questions, build
the relationship, and, most importantly, discuss any potential issues as soon as possible.
• More corporate involvement – lots of interested parties
• Need to keep everyone apprised of exam progress
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CFPB Top 10 Lessons Learned (Cont.)
7. Logistics is important to CFPB
• Travel arrangements, lodging, restaurants – make it easy for them
• If allowing them to work remotely, make sure you have someone there to oversee them.
8. Call monitoring
• They will listen to many calls
• Presumptive sales
• Pace of speech
• “risk free for 90 days”
• “Only 69 cents”
• Need to have calls recorded – the full call
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CFPB Top 10 Lessons Learned (Cont.)
9. The exam will last longer than they anticipate and you want
• Need to plan accordingly
• It is a full time job and then some
• You won’t have time for anything else
10 . This is new to the examiners too – and WF is a complicated place to understand
• Kick off meetings helpful
• Need to teach them about our businesses and our company
• During discussions with examiners as well as in presentations, remember to integrate the roles of
OR and Audit – it’s important they understand their roles as well.
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