The advent of the Consumer Financial Protection Bureau (CFPB) has turned the consumer complaint process into a compliance event.
It’s no longer enough to take consumer complaint calls and strive for good service, says Jared Ihrig, CUNA’s chief compliance officer.
“The CFPB wants to see how you’re managing those calls and how you’re tracking them,” he says. “They want spreadsheets and pie charts that show when the calls came in and how long it took to resolve the issue, and if the error was extrapolated across the membership and remediated with all the members who had the same issue.
“They want to know if you changed your policies, procedures, and product offerings so the same complaint does not happen again.”
CFPB is closely scrutinizing regulators to ensure they’re documenting these issues.
Credit unions must establish a channel through which complaints can be tracked whether it’s a phone number, e-mail address, or a web address.
“You’ve also got to delineate between complaints and inquiries,” Ihrig says.
A complaint that comes in repeatedly may indicate a weakness in the credit union’s compliance management system.
“That’s what the regulators look for,” Ihrig says. “If they see 50 overdraft complaints, they are going to see a deficiency and ask how you plan to address that deficiency.”
Ihrig addressed the CUNA Governance, Risk Management, and Compliance Leadership Institute, produced in collaboration with Rochdale Paragon Group, a CUNA partner.