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Complaint Management:
Identifying, Addressing, Reporting
Jason Spelliscy, CRCM, CAMSManaging Principal
Capco
2Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
OBJECTIVESIDENTIFYINGADDRESSINGREPORTINGRECAPQUESTIONSTHANK YOU!
01.02.03.04.05.06.07.
CONTENTS/AGENDA
3Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
IDENTIFYING
4Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
DEFININGWhat is a complaint?
SOURCEHow can/do we receive?
CAPTURINGMaintain a log
CATEGORIZINGMeaningful and Useful characteristics to aid in measuring level and trend
IDENTIFYING
5Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
IDENTIFYING
DEFINING
6Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
IDENTIFYING
DEFINING
WHAT IS A COMPLAINT?Regulators• FDIC• CFPB• California DBO
HOW DO YOU DEFINE?
WHAT IS NOT A COMPLAINT?• What are your deposit rates?• Asking questions or inquiring on
services?
7Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
IDENTIFYING
SOURCES OF COMPLAINTS
REGULATOR• FDIC via FDIConnect
INTERNAL• From Staff/Employees• From Customerso Directlyo Indirectly – Facebook, Twitter, other social
media
EXTERNAL• Credit Reporting Agencies• Better Business Bureau
THIRD PARTY VENDORS• Types of Vendors: Credit Card, Insurance,
Investments• Contract provisions require?• How have they defined?
CONGRESSIONAL INQUIRY• Your customer submits a complaint/concern
with his/her representative in DC
8Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
IDENTIFYING
Source: fdic.gov
9Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
IDENTIFYING
Source: consumerfinance.gov
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IDENTIFYING
LOGGING METHODS• Excel Spreadsheet• SharePoint• Ticketing System• Software Provider
DATA CAPTURE• Line of Business• Key Characteristics (of the complaint)• Response Management
LOGGING
11Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
IDENTIFYING
KEY CHARACTERISTICS TO CAPTURE• Date Received• Customer Name• Customer Account Number• Source of Complaint/How was complaint
received?o In PersonoRegulatoroCustomer Service Line• Type of Complaint• Date Response Due• Product(s) and Service(s) Affected. Standard
fields vs Customizable Entries• Did they ask for a refund? • UDAAP Determination/impact• Team Responsible• Date Response Completed
CATEGORIZATION
12Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
ADDRESSING
13Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
OWNERSHIP AND ACCOUNTABILITY
REASONABLE INVESTIGATION
ROOT CAUSE ANALYSIS
TIMELINESS
RELATION TO “DISPUTES”
• Electronic Funds Transfers (Reg E)
oDebit Card unauthorized use, fraud
• Truth in Lending Act (Reg Z)
oOpen-end (i.e., Credit Cards)
• Credit Bureau Reporting
ADDRESSING
14Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
ADDRESSING
OWNERSHIP AND ACCOUNTABILITY
• Delegate to LOB• Validate/confirm log entries
Compliance
• Investigate• Determine Cause• Resolve• Draft Response
Line of Business (LOB)
• Review and Finalize Response
• Complete Log
Compliance
15Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
ADDRESSING
REASONABLE INVESTIGATION
REASONABLE INVESTIGATION• Risk Based
ROOT CAUSE ANALYSIS• Isolated – one-off • Systemic – part of a potential bigger issue
16Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
ADDRESSING
RELATION TO DISPUTES
RELATION TO “DISPUTES”• Electronic Funds Transfers (Reg E)oDebit Card unauthorized use, fraud• Truth in Lending Act (Reg Z)oOpen-end (i.e., Credit Cards)• Credit Bureau Reporting
17Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
REPORTING
18Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
REPORTING
AUDIENCE• Line of Business Ownership/Accountability• Senior/Executive Management• Board of Directors or Committee
WHAT TO REPORT? • Actual Data• Absence of Complaints• Volume, Level and Trend• Charts, Graphs, Visual Aids• Aggregated Data from Regulators
FREQUENCY?• Annually• Quarterly• Monthly
INTERNALLY
19Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
REPORTINGEXTERNALLY• Community Reinvestment Act (CRA)
Considerations• When to inform regulators? oSystemic IssueoConsumer Harm (i.e., monetary, credit
bureau reporting)
EXTERNALLY
20Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
RECAP
21Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
COMPLAINT MANAGEMENT
IDENTIFYING• Defining: what is a complaint? • Creating a log to capture, track,
use for reporting• Key characteristics
ADDRESSING• Workflow management• Investigation• Timely response
REPORTING• Board of directors visibility• Level and trends• Compare and contrast to periodic
publications by regulators
IDENTIFYING, ADDRESSING,
REPORTING
22Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
QUESTIONS
23Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
THANK YOU
JASON SPELLISCY, CRCM, CAMSMANAGING PRINCIPAL
MOBILE: 208.258.1930EMAIL: JASON.SPELLISCY@CAPCO.COM
24Capco Confidential. © 2019 The Capital Markets Company. All rights reserved.
FAST FACTS
1998 20FOUN
DED I
N
EXCPERIENCEINDUSTRYYEARS
27 WORLDWIDE OFFICESACROSS 4 CONTINENTS
5000 + EMPLOYEES
90 +GLOBAL CLIENTS
INDUSTRIESBANKING & PAYMENTS �CAPITAL MARKETSWEALTH & ASSET MANAGEMENT�INSURANCEENERGY MARKETS
24
ABOUT CAPCOCapco is a global business and technology consultancy focused on financial services.
INNOVATORS: We are innovators who combine a disruptive, design-thinking approach with unrivalled, first-hand industry knowledge and technology acumen.
FACILITATORS: We facilitate the handshake between the business and technology organizations to deliver end-to-end consulting services and solutions.
TRANSFORMATION SPECIALISTS: We help our clients transform and advance their businesses, increase revenue, manage risk and regulatory change.
We consistently deliver these core tenets as part of our brand:
DIGITALTRANSFORMATION
INNOVATIONAND THOUGHTLEADERSHIP
EXECUTIONEXCELLENCE
UNIQUECULTURE
INDUSTRYEXPERIENCE
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