Yes, the FDIC has recently changed their procedures related to handling consumer complaints.
The FDIC notified FDIC-supervised institutions of its new consumer complaint process in an October 28, 2020, email with the subject line “Notification of Changes to FDIC’s CRC Complaint Investigations.” The new process became effective November 16, 2020, and requires banks to respond directly to the complaining consumer in writing and to furnish the FDIC’s Consumer Response Center with a copy of the dated response and any requested supporting documentation.
In an informal conversation with an individual at the FDIC Consumer Response Center, we confirmed that this new procedure will not be made publicly available. Additionally, the FDIC noted that the relevant timeframes for responding to complaints has not changed. Institutions are still required to provide their initial response within twenty days of receiving a Case Notification and Request Letter from the FDIC, and if the FDIC requests additional information thereafter, it will usually require responses within five days. However, the individual we spoke with at the FDIC noted that the five-day timeframe is a flexible one, and institutions may reach out to the relevant FDIC specialist noted in the request for more time if needed.
For resources related to our guidance, please see:
- FDICconnect email, October 28, 2020 (“The FDIC’s Consumer Response Center (CRC) is transitioning to a new process for responding to consumer complaints. As part of these changes, banks will be required to respond directly to the consumer in writing and furnish the CRC with a copy of the dated response along with any requested supporting documentation. In the event there is additional information related to the complaint that cannot be shared with the complainant, a separate response should also be provided to the CRC. Banks should follow existing Customer Identification Procedures when responding to consumers.
The CRC will continue to conduct its standard review of the complaint and provide a response to the consumer. Accompanying this notice below is a sample request letter that will be provided to you via FDICConnect CRCFE upon receiving a complaint involving your institution.
These changes are scheduled to go into effect November 16, 2020, and will apply to any new complaints received on this date and thereafter. If you have any questions regarding this change, you may contact CRC Chief Stefano LeGrande at 816-234-8539. . . .
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Please provide your written response through FDICconnect within 20 calendar days of receipt of this letter. . . .”)