I just came across offered training titled "Complaint Management" How to Ensure Your Institution is Actively Monitoring Complaints and Preparing for the Next Reg Exam. The training lists items from the CFPB manual as of January 2016. I searched BOL but only two threads came up both from 2015 and not really what I was looking for. Does anyone have any insight to this complaint management requirements? Thanks!

Each bank must have a policy/procedure detailing their complaint management program. You should keep a compliant log of when the complaint came in, what it was, how it was resolved, and when it was finally resolved. Training your staff on the program is important as well as recognizing a complaint under your program. You should then be able to pull trends from the complaint log - if they exist to determine if you may have UDAAP or other systemic issues within your bank.

Is this what you were looking for?

Yes, but of course I have questions. Do you have a designated person and if so, at what level, teller versus loan officer or an operations person. Do you send reports anywhere like the board? Who determines if it is a complaint or just whining? I think you know what I mean, I can't be overdrawn, I still have checks! I always feel less is more and I don't want to put so much in that isn't necessary. Thanks again!

You need someone with authority to resolve the complaints. A teller may have authority over some complaints but they still need to be logged. There should be an officer who is in charge of the process/program. The bank can define complaint however it pleases but it must stand up to regulators scrutiny. Complaints such as, "I can't use your internet banking -it never works!" from different customers may not be whining - it may be a system issue that you need to resolve.

The Compliance officer would normally oversee the process unless there is a dedicated officer. I don't know what size your bank is. the board should receive periodic reports on the number and type of complaints as well as any complaints received from regulatory agencies.

Walden has made great points here and is spot on.

What I will add to this is that the program should be tailored to your institution. Our complaint policy/program involves training staff, continuing email reminders, and a 2-3 page policy document. Don't get hung up if you don't see complaints come rolling in. The goal of the program is to get you in front of the problem and to be proactive, not reactive. We do things pretty well around here and I archive a handful of complaints each year.

From your profile, your FI is about 1.7MMM and has 49 branches. You are going to have a bit more robust program than we, but it shouldn't be scoped like a BOA or Wells.

Good luck.

You could always run your program like the CFPB and only take complaints that are against other institutions and not accept any related to yourself.

But I am guessing that would be frowned upon.

Thank you for all responses, but I'm still confused. I took this to our compliance committee and we all agreed we did not know about this. When was this implemented?
Norman Paperman, I'm guessing your research was on Waldensouth as my bank is just over 110M and has 3 branches. Thanks though!

Oops.

Grannie, you won't find anything set in stone saying the program is required, so it hasn't been "implemented", per say.

However, be it that the CFPB has gone through great efforts to collect and data-mine consumer complaint, regulators generally like to see a proactive, rather than reactive, approach coming from institutions.

https://consumercomplianceoutlook.org/2012/second-quarter/enhancing-compliance-mgmnt-program/

Thanks again!