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#1771579 - 01/02/13 05:27 PM Definition of an "Complaint?"
dconsigli Offline
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Joined: Dec 2012
Posts: 25
I know there are many definitions but for a regulator do you have a good definition of what a complaint really is? Thanks

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#1771652 - 01/02/13 07:47 PM Re: Definition of an "Complaint?" dconsigli
edAudit Offline
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edAudit
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You are here
you may wish to post in which regulation the "complaint" is in reference to.
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#1771703 - 01/02/13 08:48 PM Re: Definition of an "Complaint?" dconsigli
rlcarey Offline
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Outside of the regulatory defined complaints (some are not really complaints), but you have Reg E errors, complaints forwarded by the regulators, qualified written requests under RESPA, comments under CRA, etc., you are pretty much able to define it any way you want. Unless governed by a specific regulation, you are under no real obligation to track or respond to anything else, although most banks do.
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#1771708 - 01/02/13 08:54 PM Re: Definition of an "Complaint?" dconsigli
John Burnett Offline
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One of the major reasons that complaint handling is getting so much attention of late is that complaints often suggest areas in which consumers are confused or misinformed about a bank policy or the terms of an account or service, etc. When complaints help a bank identify opportunities to improve customer disclosure and contract documents or marketing materials to enhance customer knowledge, they reduce the risk of getting bushwhacked by a UDAAP complaint.
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#1773372 - 01/07/13 10:34 PM Complaint policy for "Commercial" customers? edAudit
dconsigli Offline
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Joined: Dec 2012
Posts: 25
We have a "consumer" complaint policy but do we need to track commercial and/or small business customer complaints or even create a separate complaint policy for "commercial"?

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#1773388 - 01/07/13 10:53 PM Re: Complaint policy for "Commercial" customers? dconsigli
rlcarey Offline
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Galveston, TX
I would think so, why would you not? I don't think you need a separate policy. In fact, what do you need a policy for in the first place. Are these not just procedures?
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#1774294 - 01/09/13 07:04 PM Re: Complaint policy for "Commercial" customers? dconsigli
Sugarbaker Offline
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Joined: Nov 2005
Posts: 265
Does a complaint policy need to be board approved? How about a DAAP policy? Just wondering how others are handling these "policies".

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#1774306 - 01/09/13 07:23 PM Re: Complaint policy for "Commercial" customers? Sugarbaker
Elwood P. Dowd Offline
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Elwood P. Dowd
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As neither policy is required, neither has to be approved by anyone in particular, particularly not the board.

Examiners often suggest that banks have "policies" on a variety of things primarily as a way of putting the board on notice that such issues exist. That "policy" then becomes the prybar they use to hold the board accountable. It's perverse, but it's worked for decades.

As noted, many issues can be addressed in procedures which are developed by and for the people who actually do the work.
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