Complaint Management:

Identifying, Addressing, Reporting

Jason Spelliscy, CRCM, CAMSManaging Principal

Capco

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OBJECTIVESIDENTIFYINGADDRESSINGREPORTINGRECAPQUESTIONSTHANK YOU!

01.02.03.04.05.06.07.

CONTENTS/AGENDA

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IDENTIFYING

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DEFININGWhat is a complaint?

SOURCEHow can/do we receive?

CAPTURINGMaintain a log

CATEGORIZINGMeaningful and Useful characteristics to aid in measuring level and trend

IDENTIFYING

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IDENTIFYING

DEFINING

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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?

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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

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IDENTIFYING

Source: fdic.gov

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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

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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

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ADDRESSING

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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

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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

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ADDRESSING

REASONABLE INVESTIGATION

REASONABLE INVESTIGATION• Risk Based

ROOT CAUSE ANALYSIS• Isolated – one-off • Systemic – part of a potential bigger issue

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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

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REPORTING

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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

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REPORTINGEXTERNALLY• Community Reinvestment Act (CRA)

Considerations• When to inform regulators? oSystemic IssueoConsumer Harm (i.e., monetary, credit

bureau reporting)

EXTERNALLY

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RECAP

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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

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QUESTIONS

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THANK YOU

JASON SPELLISCY, CRCM, CAMSMANAGING PRINCIPAL

MOBILE: 208.258.1930EMAIL: JASON.SPELLISCY@CAPCO.COM

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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

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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