Topic: Compliance Management Systems
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We allow customers to leave their utility bills with us, and we drop the bills at city hall for processing. We accidentally forgot one, and it went a few days past due. Our customer requested reimbursement from the city for the $2 late fee, without mentioning our institution’s name. We paid the late fee for our customer and apologized. Do we need to write this up as a complaint? This is just a service we provide our customers unconnected to any bank product.
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We believe that your bank’s internal policies and procedures would determine whether your institution should log this situation as a complaint. We are not aware of a regulation or law that defines “consumer complaint,” although the federal banking regulators all expect financial institutions to track and respond to consumer complaints. Your primary federal regulator, the…
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Has the FDIC recently changed their procedures for handling consumer complaints? After providing a written response to a consumer complaint received via FDICconnect and verbally communicating with our customer, we received a letter from the FDIC requiring us to “provide a copy of the bank’s response sent directly to the complainant, in accordance with new FDIC procedures which began on November 16, 2020.” We have to respond within five days.
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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…
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We are aware of a service called “CU Policy Pro” that allows credit unions to access model polices for compliance and operational matters. Does a similar program exist for banks?
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We are aware of two companies that provide similar services — Compliance Alliance and Continuity. Links to their websites are included in the resources below. In addition, the IBA offers a Forms Library on GoToIBA.com that has over 300 sample policies, procedures, checklists, worksheets and more, most of which were provided by IBA member banks. A…
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Is there a standard template or flowchart regarding interdepartmental risk management? Our current process generally involves analyzing risk in separate departments, but we are looking to create a more efficient and comprehensive system to analyze risk and convey key risk items to our board.
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We have two different documents regarding risk management in our GoToIBA.com forms database. Our Compliance Risk Assessment is a checklist that addresses the various components involved in risk management, including board involvement, documentation, staffing, regulatory exposure and more. Our Compliance Risk Assessment Matrix is a comprehensive score card that can help you identify, analyze, and…
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What must be included in a bank’s customer complaint policy?
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We recommend reviewing the FDIC’s discussion of consumer complaint policies in its compliance examination manual, which you can find in our resources below. In addition, the FDIC presented a webinar in 2013 on consumer complaints with a discussion of how a bank’s consumer complaint policy should fit into its overall compliance management system. We also…