Complaint Resolution Policy and Procedure
The targeting of audit subjects through the use of the CFPB Complaint Portal means you need a proactive complaint resolution process.
Since the Consumer Financial Protection Bureau began accepting complaints related to mortgage transactions in 2011, the industry's fears that this would simply act as a targeting mechanism have been realized. Multiple complaints, more than a single complaint, act as a red flag attracting the worst kind of scrutiny. Recent presentations by CFPB Senior Analyst Ann Thompson confirmed this. As a preventative tool, our first recommendation involves adding a daily or weekly check of state and national complaint portals by the company's compliance manager.
But it goes beyond dealing with complaints. You must take a proactive attitude. Make it easy for your customers to file a complaint with you and company management directly, before the customer elevates it to the regulator to resolve it. This means:
More importantly, though, all employees need to understand they must participate in communicating to troubleshoot, document and resolve complaints.
Since the Consumer Financial Protection Bureau began accepting complaints related to mortgage transactions in 2011, the industry's fears that this would simply act as a targeting mechanism have been realized. Multiple complaints, more than a single complaint, act as a red flag attracting the worst kind of scrutiny. Recent presentations by CFPB Senior Analyst Ann Thompson confirmed this. As a preventative tool, our first recommendation involves adding a daily or weekly check of state and national complaint portals by the company's compliance manager.
But it goes beyond dealing with complaints. You must take a proactive attitude. Make it easy for your customers to file a complaint with you and company management directly, before the customer elevates it to the regulator to resolve it. This means:
- Adding prominent "complaint" button on web pages
- Proactively sourcing "compliments and complaints" via promotional materials
- Asking customers "have I addressed all of your concerns today?" question in the footer of all electronic communications
- In addition, have an effective process for resolving complaints once they arise. This is called a "Complaint Resolution Process"
More importantly, though, all employees need to understand they must participate in communicating to troubleshoot, document and resolve complaints.
