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#1332 - 04/13/01 03:49 PM Consumer Complaints
JoAnne Offline
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Joined: Feb 2001
Posts: 795
Michigan
Is a complaint received directly from a consumer by a bank employee (and not sent to/from a regulatory agency) considered a Consumer Complaint under Regulation AA. Currently I do not believe that we are treating those complaints as Reg AA consumer complaints and the bank employee receiving the complaint is typically handling it rather than sending it to a centralized area.

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JoAnne

Opinions posted are not necessarily those of my employer.

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General Discussion
#1333 - 04/14/01 04:59 AM Re: Consumer Complaints
Andy_Z Online
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Andy_Z
Joined: Oct 2000
Posts: 27,348
On the Net
The definition of "complaint" isn't specific to an employmer or even whether or not the complaint comes through your regulator. Your policy need not differentiate between a consumers letter and one from a regulator.

Some regulations place time frames and requirements upon you no matter where the complaint originates. Regs E, Z, FCRA and RESPA in particular.

I recommend your policy look at the problem and resolution, that is what is important. Take a broad view.


"(b) Consumer complaint means an allegation by or on behalf of an individual, group of individuals, or other entity that a particular act or practice of a state member bank is unfair or deceptive, or in violation of a regulation issued by the Board pursuant to a federal statute, or in violation of any other act or regulation under which the bank must operate."

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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#1334 - 04/16/01 02:27 PM Re: Consumer Complaints
Lucy Griffin Offline

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Lucy Griffin
Joined: Nov 2000
Posts: 1,544
Andy has it right. On top of what Andy has already said, the signals we are getting from the bank regulatory agencies are that consumer complaints are getting more and more attention. In particular, the agencies are concerned about how the bank responds to complaints.

The key distinction that you should allow branch staff to make is whether the complaint is really service related (such as the teller made faces at me) or may in any way be related to regulatory requirements. Any complaint that could have substance should go to a centralized point for evaluation.

Banks should also have complaint policies that state how the bank will respond to the complaint and indicate the bank's level of commitment to resolving complaints.

I like to see complaints managed by the compliance department because that is the surest way to identify regulatory issues.


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#1335 - 04/16/01 09:08 PM Re: Consumer Complaints
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 9,995
Toano, VA
Although complaints should never be taken lightly and I don't disagree with the merits of Andy's & Lucy's suggestions, Subpart A of the regulation is an internal standard for the Fed. It does not require specific action by a state memeber bank. During the course of a complaint investigation, the Fed will explain its authority to investigate alleged problems. Suspected violations of law may trigger an onsite review in addition to a letter-writing campaign. If the bank is found to be violating the law, it will be directed to discontinue the illegal practice.
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