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#2253671 - 05/07/21 08:25 PM Tracking Complaints
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
Business units who interact with consumers are required to track and report complaints to Compliance and Legal. It was suggested to us (By one of our regulators) that all customer facing BUs track and report complaints. Naturally there is some push back as areas that don't open accounts for consumers don't want to comply with this.

I get that an individual who has authority of an entity account could conceivably make a complaint but are we required to track and monitor complaints that originate from business clients?
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#2253721 - 05/10/21 05:02 PM Re: Tracking Complaints ACBbank
alisonb Offline
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Joined: Jul 2014
Posts: 1
"Required" is a strong word. You should have a complaint management program that defines what a complaint is and how it is reported and tracked. The FDIC consumer compliance examination manual is specific to "consumers". However today they issued a settlement announcement with a Bank related to practices that were "unfair and deceptive" pertaining to collection efforts on commercial equipment financing. If the Bank had included third party complaints and commercial customers in their complaint management program, (and maybe they did, I don't know...) they may have been alerted to the issue before it had raised to such a level as causing a CMP..... which is the overall purpose of having a complaint management program.

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#2253730 - 05/10/21 06:26 PM Re: Tracking Complaints ACBbank
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 542
USA
Are you absolutely certain none of your commercial business units have consumer customers? There are a lot of commercial lenders that issue accommodation loans to consumers. For example, Company A is a great customer. Its CEO wants a personal line of credit, so Mr. Commercial Lender originates an unsecured line. The commercial lender now has consumer business.

Another example: Commercial Treasury and Payments team has a relationship with several colleges. The team sells prepaid debit cards to those universities, which use them to disburse financial aid to students. The Treasury and Payments team now has thousands of consumer customers.

Beyond that, if you exclude BUs that are not consumer-facing, you will miss opportunities to identify customer pain points that affect business customers.
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#2253800 - 05/12/21 02:24 PM Re: Tracking Complaints ACBbank
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,286
Cape Cod
Welcome, "alisonb," to our discussion forums, and congratulations on your first post.

Your point is very well taken. A bank that is serious about maintaining a well-managed complaint monitoring program should not exempt any of its business units. As you've pointed out, the Umpqua Bank civil money penalty levied by the FDIC clearly sends a message that commercial transactions aren't exempt from regulatory scrutiny, and, as InFairness observed, complaint monitoring programs can reap self-improvement benefits even for business-facing business units.
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#2253803 - 05/12/21 03:03 PM Re: Tracking Complaints ACBbank
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
Thank you for the feedback everyone.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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