Complaint Management in Today s Banking and Regulatory Environment Utah Bankers Association 2015 Fall Compliance Conference- The Magic of Compliance

Transcription

1 Complaint Management in Today s Banking and Regulatory Environment Utah Bankers Association 2015 Fall Compliance Conference- The Magic of Compliance Presenter: Lourdes Johnson, CRCM, CAMS SVP, Corporate Compliance Governance Manager Zions Bancorporation October 28, 2015

2 How does our bank view our customers voices (aka complaints )? Do we view them as a benefit or as a detriment? Consumer Financial Protection Bureau By adding their voice, consumers help improve the financial marketplace. 2

3 Discuss: using complaint management as a business tool; the definition of complaints; the attributes of effective complaint management programs; benchmarking against industry best practices; the benefits and challenges faced by complaint management programs; and two sample complaint scenarios. Today s Objectives 3

4 Bank s can use complaints to better understand their customers needs and frustrations. One of the keys is understanding all source areas where complaints can be received, such as: social media channels the bank s complaint repository customer correspondence employees (regardless of department or physical location) third party vendors and service providers regulatory agencies and other agencies Using Complaint Management as a Business Tool 4

5 Customer Service Issues Management Use complaints as an opportunity to improve products, services and delivery channels. Use complaints as employee coaching opportunities. Use complaints to identify issues and track trends. Use complaints (especially those received via social media channels) to stay ahead of potential regulatory issues or concerns. How Do We Effectively Use Complaints As a Business Tool? 5

6 Does the bank s definition of complaints agree with regulatory expectations? Does the definition of complaints include all types of complaints regardless of source channel? Does the bank s definition of complaints differentiate between complaints, disputes and inquiries? Does the bank define consumer complaints? How Do We Define Complaints? 6

7 At a minimum, an effective Complaint Management Program should: Have a governing policy and procedures; Identify complaint channels; Require complaints to be managed in an effective and timely manner; Analyze complaints for potential unfair and deceptive acts and practices (UDAP); Analyze complaints for potential unfair, deceptive and abusive acts and practices (UDAAP); Analyze and track complaint trends and require root cause analysis; and Establish reporting and escalation requirements. Complaint Management Programs 7

8 Look for trends that have potential UDAAP implications, such as complaints alleging: False statements Missing information Excessive fees Undisclosed charges Non-timely posting of payments Unfair practices in advertising, account delivery, account maintenance, and special handling Benchmarking Against Industry Best Practices 8

9 Conduct periodic key word searches of bank complaint databases. Stay abreast of regulatory trends and enforcement actions. Include complaint management as part of the Company s UDAAP Program, and/or Responsible Banking Program. Track third-party vendor/service provider complaints. Benchmarking Against Industry Best Practices 9

10 Benefits Challenges Complaints (even one complaint) can serve as a warning sign of potential problems with products, services, or business practices. Often times, one of the key metrics used to determine the significance of complaints is the volume of complaints received on a particular topic for a particular period of time. Complaint Management- Easier Said Than Done Right??? 10

11 Benefits Social media can provide an unfiltered forum for a bank to better understand what their customers and prospective customers are saying. Challenges Without a social media strategy that allows a bank to monitor, analyze and address what is being conveyed online, the bank misses opportunities to identify and address issues, manage negative perceptions, and project a positive presence online. Complaint Management- Easier Said Than Done Right??? 11

12 Scenario 1 Scenario 2 Your bank uses social media on a broad basis. You are in Compliance and have been asked to review and approve the new Social Media Policy. What specific items will you be looking for in the policy from a complaint management perspective? You manage your organization s corporate complaint management department and have received one complaint regarding the Rewards Program linked to your Platinum credit card. The complaint discusses confusing disclosures and the customer s inability to fully understand the Rewards Program. How Would You Handle This? 12

13 Effective complaint management is a top priority and is viewed by regulators as a key element of a strong Compliance Management Program. Complaints allow us opportunities to learn more about our customers and to gain their perspective about our organization, our employees and the products and services we offer. Complaints should be viewed as a positive, rather than a negative. They are a gift... Conclusion 13

14 Thank you for your participation in today s session. Q and A 14