Consumer Complaints Flashcards
Which of the following would be MOST concerning to a compliance officer when evaluating the information stored in the bank’s complaint monitoring system?
A. It is unclear whether the bank identified several complaints as escalated or not
B. The bank’s vendor is not responsive to issues concerning the storage media of the system
C. It is ambiguous as to which employee was assigned responsibility to respond to some complaints
D. The system itself is several years old and it is likely that newer technology is available
A. It is unclear whether the bank identified several complaints as escalated or not
It is a requirement that complaints be escalated in certain circumstances, so if this is not happening, it is a pressing concern. The storage media of complaints, as well as the age of the system itself, is not as concerning, as the system may still be functioning properly. The assignment of the proper employee is concerning, but not as concerning as not escalating complaints as required.
A good customer complaint management program should include all of the following EXCEPT:
A. Evaluation of length of response times
B. Evaluation of the customer racial and ethnic characteristics
C. Evaluation of root causes
D. Evaluation of recordkeeping
B. Evaluation of the customer racial and ethnic characteristics
According to regulatory guidance from the Agencies, an effective complaint management program should include evaluations of response times of complaints, root cause analysis, and recordkeeping. The guidance does not require analysis of racial and ethnic characteristics of the consumers making the complaints. If complaints are lending-related, it might seem like a good idea to evaluate demographic characteristics, but this may also present a risk to the bank, and is not required by the complaint guidance.
Which of the following would be the MOST important information within a report that the compliance officer coordinates for the bank’s auditors regarding complaints received by the bank?
A. How many complaints the bank received on funds availability issues over the past year
B. The contact information for the consumer logging the complaint
C. How a complaint was received: by phone, email, face-to-face conversation, etc.
D. Listing of dates of resolution for escalated complaints and details of resolution plans
D. Listing of dates of resolution for escalated complaints and details of resolution plans
Resolution of escalated complaints is a requirement of an effective complaint management system, and listing the date of resolution is a principal component of this requirement. How many complaints were received on any particular issue and the medium of receipt, while useful to the bank, is not as critical as resolution detail. Contact information for the consumer lodging the complaint is not necessary at all unless the bank wishes to contact the consumer. It is not required by rule.
Which component should be included in effective complaint resolution processes?
A. Analytical practices to identify trends, patterns, and root causes of significant trends
B. Decentralized tracking of complaint volumes for a particular business unit or product
C. Sole responsibility for the compliance function to identify and report on complaint volumes
D. Reporting to the board and management that is limited to complaint volumes and timeliness of resolution
A. Analytical practices to identify trends, patterns, and root causes of significant trends
How long does a bank have to respond to a consumer complaint filed with the CFPB?
15 days, or up to 60 if the bank tells the complainant they’re working on it
The bank has received numerous complaints from customers about negative credit report information submitted by the bank due to customers’ excessive use of its overdraft program. What is the BEST response to these complaints?
A. The bank must cease reporting negative information to the credit bureaus for customers’ use of overdraft programs promoted by the bank, but need not send the corrected information to remove previously-reported information about overdraft use
B. The bank must immediately discontinue its overdraft program and its promotion, as it has violated regulatory guidelines and committed unfair practices under UDAAP principles
C. The bank must cease reporting negative information to the credit bureaus for customers’ use of overdraft programs promoted by the bank, and should send corrected information to remove previously-reported information about overdraft use
D. The bank may continue reporting negative information to the credit bureaus around excessive use of the overdraft program, as it demonstrates customers’ misuse of their deposit account funds
C. The bank must cease reporting negative information to the credit bureaus for customers’ use of overdraft programs promoted by the bank, and should send corrected information to remove previously-reported information about overdraft use
Use of overdraft programs by customers should not result in negative information being reported to consumer reporting agencies. If this is being done, amended information should be provided to the bureaus to correct the previous reporting. Even if this has been done, there is no need to discontinue the program itself, but previous errors must be corrected.
