Pressure-Test Your Complaints Management Program

April 30, 2020

Time to Pressure Test Your Complaints Management Program

Credit bureau and collections complaints once again lead all other consumer complaint types in the recently released CFPB 2020 Consumer Response Annual Report. These trends are likely to remain unchanged with consumers’ concerns about the impact of missed payments and increased collections efforts during—and following—the pandemic. Additionally credit bureaus are providing customers with access to credit reports on a weekly basis. So it stands to reason that complaints will continue to increase. With that in mind, here are key components to develop and maintain a strong, effective complaints management program.


4 Pillars of a Complaints Management Program that Works

Complaints Management

1. GOVERNANCE to ensure a sustainable program and employee engagement

Determine what is expected and memorialize through documentation. These requirements are reinforced through training and tie to expected performance.

Required Elements

  • Clear Compliance Expectations and Definitions
  • Roles & Responsibilities
  • Policies & Procedures
  • Training

2. DETECTION, CAPTURE & ESCALATION guarantee that what is expected is being done and communicated properly

Implement methods to effectively communicate expectations and identify and document instances requiring attention.  Confirm exceptions are communicated promptly to the right people for appropriate next steps.

Required Elements

  • Identification & Capture
  • Prioritization & Communication

3. ANALYSIS & RESOLUTION aids in decision-making and drives change

Analyze to identify the root cause and formalize remediation needs. This should not be limited to the “highest volume” complaint types, as we have seen a small number of complaints be signs of significant underlying issues.

Required Elements

  • Root Cause analysis
  • Remediation
  • Restitution
  • Validation

4. REPORTING & MONITORING ensures widespread awareness and accountability from the top down

Appropriately record and categorize complaints and use the data to drive business decisions and to inform policies, procedures, monitoring and training.

Required Elements

  • Trends
  • Issues
  • Risks
  • Effectiveness

Success Factors to Support the Pillars

Top-to-Bottom Enterprise Buy-in

Everything relating to risk and control must have board and senior leadership agreement on its importance and expectations.

Effective Case & Workflow Management Tools

You need proper case management to be able to process documents and hand-off to the right resources.  Complaints should be reviewed centrally and segmented for escalation due to legal issues involving potential consumer harm from unfair or discriminatory treatment, or other regulatory risks.

End-to-End Consumer Focus

Regardless of where the consumer is in the complaints journey, you must keep that person’s perspective in mind to ensure regulatory compliance and consumer loyalty. The way you respond to COVID-19 inquiries or complaints can differentiate and drive consumer confidence in your organization.

Reliable Data & Advanced Analytics

Inadequate data and broken reporting mechanisms are inefficient and hinder your ability to identify trends. Analysis should be system-driven to include detailed tracking of important data. Your data should include the number of complaints, severity, classification, response timeliness and the relevant functional business area(s) to determine root cause and corrective action. Then, the data pieces need to be joined to examine enterprise-wide complaint activity.

Strong Governance & Oversight

Leadership must create and maintain an authentic “culture of complaints as gifts” to clearly define accountability and expectations for behavior, communication, and actions.

Success of governance and oversight should translate into improved first contact resolution, a reduction of repeat consumer complaints and reduced complaint volumes in relation to your consumer base.

In view of all that’s going on in the world, take time to pressure test your complaints management program.

Bridgeforce can evaluate your program. We’ve worked with financial institutions of all sizes to assess their credit bureau complaints management programs as a part of our proven, proprietary Credit Reporting and Disputes Management methodology.

Contact us today to talk through your needs.