Service and Compliance: What Matters?
How important is customer service? For that matter, how important is compliance? And what is the difference? For an example, here's a situation that really happened - to a compliance expert! The customer, our compliance expert, called customer service to inquire about an increase to the line of credit on the bank's visa card. It's a request that should be routine. It's a request that staff manning the phones should know how to handle.
But, instead of the help this compliance expert expected, the so-called customer service rep manning the phones blocked the request at every turn, saying things like "you can't just call the bank and ask for money." The next resist was "all the underwriters are at lunch." The time was shortly after 11:00 EST. What time zone were these folks in, and why did they all leave together? By the way, this was not a small bank - nowhere close. In fact it was a huge institution. Not many restaurants could accommodate that many underwriters at the same time.
If those excuses weren't enough, there was the Patriot Act. It seems that customers cannot call and ask for increases to their lines of credit because of the Patriot Act. Interesting news to a compliance expert.
The bottom line: the customer's request, made in accordance with the bank's procedures, was denied. But we figure it will be a really cold day somewhere very warm before the bank sends this customer an adverse action letter!
What was wrong? For starters, this was pretty awful service. In fact, we wouldn't call it service at all. More like anti-service. And on top of that, there were some pretty serious compliance violations. There may also be a customer lost. In short, whether looking at customer service or at compliance as a priority, this bad service may cost the institution customer losses or even lawsuits.
What does this mean to compliance, customer service and the training program? First, this so-called customer service rep either had not been trained or was not being monitored for quality of service. The rep made no effort at all to help the customer and clearly didn't care how the customer reacted. So, we see a serious lack of quality service training. There is also a lack of quality service monitoring. Quality service may come naturally to some people, but that clearly was not the case with our particular rep. And no-one else in the bank seemed to notice.
Second, in the process of providing abysmal service, the customer service rep committed a number of compliance violations. Not only did this customer service rep mangle things such as the USA PATRIOT Act and what it actually requires, this rep took adverse action by refusing to grant the customer's request. However, it is highly unlikely that this action was noted anywhere and it is even less likely that the compliance expert will receive an adverse action notice.
The situation illustrates a significant lack of compliance training in addition to the lack of service training. It also illustrates that compliance and excellent customer service are very close to being the same thing. Not only was it a violation of Regulation B to refuse to consider the request for a credit line increase that was made in accordance with the bank's procedures, it was awful service. Whether you count regulatory violations or the level of customer service, this particular service rep was a loser - for himself and for the bank.
Good customer service training would not only have given the customer good service, it would also have prevented the adverse action violation. The adverse action violation occurred simply because the customer service rep wouldn't respond to the customer's request. Similarly, good compliance training would have made certain that each customer service rep knew not to simply stonewall a customer.
Better yet, combine customer service with compliance training. The combination of messages lets staff know that compliance serves an important purpose, and that good service is a key element of compliance.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 14, 12/05
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