Thread Options
|
Tools
|
#50084 - 12/20/02 04:14 PM
Complaint
|
Anonymous
Unregistered
|
Banks are required to included all written comments received from the public and the response to those comments in the CRA Public File. Could someone please ellaborate on the types of comments? Is it talking about complaints that we receive such as Sam was upset because he did not receive an AAN within 30 days so he reported it to the OCC. The OCC notifies the bank and we respond. How do I determine what to place in this file?
|
Return to Top
|
|
|
|
#50085 - 12/20/02 04:20 PM
Re: Complaint
|
10K Club
Joined: Oct 2000
Posts: 27,754
On the Net
|
No, it is not the ones about a service or minor gripe such as that. It addresses credit needs. Claims of discrimination, poor lending practices, and such would be there.
§228.43 Content and availability of public file. (1) All written comments received from the public for the current year and each of the prior two calendar years that specifically relate to the bank’s performance in helping to meet community credit needs, and any response to the comments by the bank, if neither the comments nor the responses contain statements that reflect adversely on the good name or reputation of any persons other than the bank or publication of which would violate specific provisions of law;
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
|
Return to Top
|
|
|
|
#50086 - 12/28/02 09:56 PM
Re: Complaint
|
New Poster
Joined: Dec 2002
Posts: 20
|
Doesn't it cause a privacy violation if I put "Sam's letter" in the CRA file and other people can see that Sam is a customer?
_________________________
The opinions expressed here are my own and may not represent the views of my employer.
|
Return to Top
|
|
|
|
#50087 - 12/28/02 11:15 PM
Re: Complaint
|
10K Club
Joined: Oct 2000
Posts: 27,754
On the Net
|
It depends on what Sam says in his/her comments, but there need not be any inference that he/she is a customer. Anyone can add comments to your public file, customer or not.
Letters that attack employees, by name, need not be added, however. You may be able to block out some of the text or just not include it altogether. Save the original for regulatory review though.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
|
Return to Top
|
|
|
|
#50088 - 12/30/02 03:32 AM
Re: Complaint
|
Anonymous
Unregistered
|
In reference to
No, it is not the ones about a service or minor gripe such as that.
Sould there be a seperate file for those or can they be destroyed?
|
Return to Top
|
|
|
|
#50089 - 12/30/02 03:42 AM
Re: Complaint
|
10K Club
Joined: Oct 2000
Posts: 27,754
On the Net
|
There is no retention requirement that I am aware of. I would retain it in a central file if it went through your regulator, the BBB or some similar entity. I would also consider keeping it for some period to determine if you see a trend.
The time frames are up to you with the caveat that those through my regulator, I would hold exam to exam. They have a list of complaints filed through them and may ask about the disposition.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
|
Return to Top
|
|
|
|
#50090 - 12/30/02 04:45 PM
Re: Complaint
|
Diamond Poster
Joined: Jun 2002
Posts: 1,210
California
|
During a recent exam the OTS suggested that I add a heading for "Complaints" to my quarterly Audit Committee report. I maintain a file and track resolution of general customer complaints.
_________________________
My opinions are not legal advice and are worth what you paid for them.
|
Return to Top
|
|
|
|
#50091 - 12/30/02 06:47 PM
Re: Complaint
|
10K Club
Joined: Oct 2000
Posts: 27,754
On the Net
|
Absolutely. Nancy Derr Castiglione wrote an article some years back on reporting to the audit committee/board. That article changed my reports.
Complaints are certainly added into it, some very specifically and some may be reported as a group if there is a common issue.
This is a bit off of the retention topic, but reporting these can be very important as it could be a first step in litigation and is certainly a measure of customer satisfaction.
A difficult part of this is what is reported? Written complaints are pretty easy. But those originating by telephone, through a CSR or call center are more difficult. Without creating a very cumbersome process (depending on your infrastructure) we catch the written and the telephonic/in-person complaints that rise to a certain level and demand managements time. Otherwise they seem to be resolved and would be discussed in manager's meetings.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
|
Return to Top
|
|
|
|
#50092 - 02/18/03 07:23 PM
Re: Complaint
|
Gold Star
Joined: Feb 2002
Posts: 461
Mississippi River Valley
|
I am searching for a regulation(s) that requires us to have a Customer Feedback or Complaint policy. I understand the requirements under CRA §228.43 Content and Availability of public file, but is there any other regulation that requires such a policy? Thanks for your input......
_________________________
How long a minute is depends on what side of the bathroom door you're on.
|
Return to Top
|
|
|
|
#50094 - 02/18/03 08:23 PM
Re: Complaint
|
Platinum Poster
Joined: Nov 2002
Posts: 598
Flushing, NY
|
Regulation AA -- Unfair and Deceptive Practices has a section dealing with consumer-complaint procedures (Subpart A)
_________________________
It really doesn't matter, no one listens to me anyway.
|
Return to Top
|
|
|
|
#50095 - 02/18/03 08:35 PM
Re: Complaint
|
10K Club
Joined: Jul 2001
Posts: 83,393
Galveston, TX
|
But even Reg AA does not specifically require an institution to maintain a file. It governs what the Fed will do when it receives a complaint from a consumer.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#50097 - 02/19/03 01:23 PM
Re: Complaint
|
10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
|
I grew up on a farm and the rule I was given in FFA was, "You have 100 rats for every one rat that you see." Apply the same concept to complaint logs.
A couple weeks ago I heard a speaker who was formerly employed by a bank with nationally publicized "financial privacy" problems say that, in retrospect, they should have known their customers objected to their practices. There had been complaints regarding their procedures, but they were not overwhelming in number and no one paid any attention to them.
If one or two people complain about something, you can attribute it to indigestion or just having a bad day. However, there is some point where a conscientious review of a complaint log can tell you something you need to know.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
|
Return to Top
|
|
|
|
#50098 - 02/19/03 05:35 PM
Re: Complaint
|
Gold Star
Joined: Feb 2002
Posts: 461
Mississippi River Valley
|
Thanks everyone for your feedback. I appreciate it.
_________________________
How long a minute is depends on what side of the bathroom door you're on.
|
Return to Top
|
|
|
|
|
|