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.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8