Is an inquiry considered a consumer complaint? How severe does the complaint have to be to log it in your complaint tracking system? The short answer: Everything should be considered a complaint, better safe that sorry!
This week, the “A” in our Q&A comes to us courtesy of Michael Benoit and Wendy MIller.
Michael Benoit, Partner
Michael Benoit, the man with his finger on the regulatory pulse, will provide an overview of the CFPB’s audit requirements. As an attorney with Hudson Cook, Michael provides legal advice on wide range of consumer financial services law topics, and represents clients in investigation and enforcement matters involving the Federal Trade Commission and the Consumer Financial Protection Bureau.
Wendy Miller, VP of Customer Success
With 20 years of experience in the technology realm, Wendy is a knowledgeable leader focused on exceeding client expectations through technical solutions. Her career spans managing Customer Success for GTS Services, an ERP Software solution for the Glass Industry along with Product Management, Client Services and Strategic Development positions for both start-ups and established companies such as Direct Revenue, About.com, and Hachette Filipacchi.
Q. Does the CFPB have a standard definition of a complaint?
Michael: I don’t think that there’s a standard definition. I think there’s some guidance in the CFPB exam manual. But I think the CFPB is more inclined to see inquiries as complaints than the rest of the world is. We certainly have had clients who only log their escalated complaints. That, I think, is a little too thin in today’s environment. And again, it depends on how your intake systems work, your loan origination systems work, how your servicing systems work.
If it were me and it were a perfect world, I would just log everything and deal with the severity of the complaint through a categorization process. Categorizing things as simple inquiries that you answered on the phone or you’re done with as opposed to other issues that require a little bit more attention.
Wendy: That’s what we’ve seen with existing customers who are utilizing our system. They’re managing it through the escalation process. Again, via their legal counsel’s recommendations, they are logging everything.
They have Compligo in place to manage it. So when they log it, it can be identified how it was handled regardless, and there’s an escalation process defined and in place and automated to deal with the things that need to escalate.
We’re seeing on our end that people are definitely erring on the side of caution.