We are not aware of any state or federal law requiring a financial institution to disclose a telephone number or mailing address for purposes of receiving complaints. Nor are we aware of any law or rule that requires financial institutions to disclose their regulator’s contact information for purposes of making or receiving complaints. Regulation B requires that contact information be provided in the adverse action notice for the federal agency that supervises the financial institution (see 12 CFR 1002.9(b)(1)), but other than the adverse action notice, we are not aware of any law or rule that requires such information be provided.

We do note that guidance from the FDIC requires financial institutions to develop consumer complaint policies and procedures. The FDIC’s Compliance Manual includes a short discussion of a consumer complaint response program in its Compliance Management System section, which recommends establishing procedures to handle complaints and to monitor them, as they “may be indicative of a compliance weakness in a particular function or department.”

Also, the Fair Lending section’s Appendix includes a “complaint file” as part of the checklist for an institution’s compliance program. More guidance from the FDIC is available from its December 2013 Teleconference on Consumer Complaints, which recommends keeping “proper documentation” of complaints. The FDIC also identified “three essential issues” for handling complaints: (1) establishing a centralized process for complaints, (2) identifying risks regarding automated or manual systems on complaints received, and (3) identifying risks associated with product or service offerings.

Additionally, the Consumer Financial Protection Bureau (CFPB) has issued guidance on consumer complaints. While the CFPB’s guidance does not directly apply to your institution, it may be helpful to look at its expectations as best practices for your institution. The CFPB Supervision and Examination Manual states that its examiners check that a supervised company records and categorizes all consumer complaints, “regardless of where submitted.” The CFPB expects the institutions it supervises to be “responsive and responsible in handling consumer complaints and inquiries. Intelligence gathered from consumer contacts should be organized, retained, and used as part of an institution’s compliance management system.” See CFPB Supervision and Examination Manual (page 43).