what the #!@$?: managing customer complaints

What the #!@$?...

Managing Customer Complaints

and Creating Positive Customer

Experiences

Imagine If you could…

…identify competitors’

strengths and

weaknesses?

…detect and

address regulatory

risks before they

result in costly

fines?

…identify key

customer pain

points to improve

the customer

experience and

drive retention?

Analysis of the Consumer Financial Protection Bureau

(CFPB) complaint database can help you identify key

issues early on and uncover emerging trends to reduce

your risk and costs.

Research is clear: increase in revenues for

card issuers driven by improved experience

revenue

potential

reduced

Add’l

purchases

Word of

Temkin $246M $91.8M $82.3M $72M

Forrester $307M $83M $213M $12M

• Incremental purchases from existing customers in the same year.

• Revenue saved by lower churn.

• New sales driven by word of mouth.

Many companies have voiced their concern

about the CFPB and the complaint database

Concerns about the database:

• Complaints are not verified for accuracy

• Not representative of the population as whole

• Cannot determine if complaints are related to dissatisfaction or misunderstanding terms of service

• However, analysis of issues in the CFPB can help you determine where the customer experience is falling short

January February March April May June July August September October November December

Social Media and CFPB comparison (percent of total)

Social media CFPBSources: Nilson report 2012, CFPB, Beyond the Arc

Social media comments about Citibank APR

show sharp spike in May

January 2012 – December 2012

• How's this for cynical capitalism. Rang up Citibank to pay-off and close my credit card. The lovely lady in the Philippines asked me why and I said: your interest rate is far too High (21%) and she said Well I'm now willing to lower your rate because you are such a valuable customer .....Well if that's the case, why didn't you drop it earlier?‘

• Now that I am close to paying off almost all of my credit card debt, it feels so good to tell these credit card companies they have to drop my interest rate to something competitive… Citibank can kiss my a$$ with their terrible outsourced customer service.

Citibank APR sample comments

Companies are responding more quickly

Regions had double the % of untimely

responses as the #2 bank First Niagara

Regions (68) First NiagaraBank (9)

USAASavings (11)

People'sUnited Bank

Bank ofAmerica

PNC Bank(34)

Navy FCU(3)

Comerica (3) M&T Bank(4)

BMO Harris(1)

Untimely responses as a percent of issuer's total*

Sources: CFPB, Beyond the Arc*Minimum 30 complaints

Note: Number in parenthesis is number of untimely responses

Untimely Response = 60 days or more for company to respond to complaint

Consumers are disputing fewer responses

Referrals were the top method of submission

to the CFPB with over half of the complaints

Sources: CFPB, Beyond the Arc

Referral Web Phone Postal mail Fax Email

Submission method - number of complaints

How do customer problems become complaints?

Customer experiences a

problem

Customer provides feedback

Bank addresses problem

Resolution

Files complaint with CFPB

Closes account(s)

and / or Customers often try

multiple time to resolve their problems

Bank does not address problem

How can we identify and address these

issues so they don’t escalate?

problem

Resolution

Closes account(s)

and /or Customers often try

We need to focus on collecting, analyzing,

and tracking customer feedback

problem

Resolution

Closes account(s)

and /or Customers often try

Voice of the Customer analysis is the key to

preventing feedback from escalating

• Voice of the Customer (VOC) analysis allows you to:

– Identify customer pain points to improve the customer

experience and drive retention

– Detect regulatory risks and

address them before the CFPB

takes punitive action

Include external measurements to create an

integrated view of the customer

InternalData from across the enterprise

o Customer feedback

o Frontline notes

o Transactional data

o Behavioral data

SocialSocial media about you and your competitors

o Twitter

o Facebook

o Blogs

RegulatoryCustomer complaints

o Federal

o State

o CFPB

The CFPB database is a meaningful data

source to incorporate into your VOC

program

• Determine key metrics

– # of CFPB credit card complaints

– # of untimely responses

– Volume of credit card related customer feedback

– Call volume to credit card customer service

• Translate metrics into ROI– i.e. Savings = (Reduction in call volume) * (average call time) * (employee hourly wage)

Measuring your results is the key to a successful VOC

program

Flagstar Bank leads all other banks in the number

of mortgage complaints per $ billion in mortgages

Flagstar Bank Bank ofAmerica

EverBank JPMorganChase

HSBC Wells Fargo SunTrustBank

M&T Bank PNC Bank Citibank

Company complaints per billion dollars in mortgages

Sources: Beyond the Arc, CFPB, www.ffiec.gov/

Flagstar also leads all banks in mortgage

complaints per $ billion on a monthly basis

Apr2012

May2012

Jun2012

Jul2012

Aug2012

Sep2012

Oct2012

Nov2012

Dec2012

Jan2013

Feb2013

Mar2013

Apr2013

May2013

Monthly trend - number of complaints per billion dollars

Flagstar Bank

Bank of America

EverBank

JPMorgan Chase

Customer reviews of Flagstar Bank on social

media reflect a negative mortgage experience

• Flagstar Bank received only 2 out of 5 stars on mybanktracker.com

• Many negative customer comments referenced mortgages:

– What a horrible experience it has been to buy my first house thank you Flag Star for that. They will do anything to benefit themselves and make your life miserable. So many things that I find hard to believe are even legal.

– We have had nothing but problems from this our Flagstar mortgage. I don't have the characters to explain all of our complaints, but I can't even imagine half of what they've done is even legal.

– If anyone suggests to use Flagstar as your mortgage company - run as fast as you can. They are a nightmare!

A poor customer experience causes attrition, hurts

the brand, and can lead to financial penalties

• Flagstar Bank has paid over $200 million due to the quality mortgage and home equity backed securities:

– $105 million to Assured Guaranty to “settle allegations it misrepresented the quality of loans backing securities”

– $110 million to MBIA Insurance Corporation for “lying about the quality of loans backing $1.1 billion in securities”

• By monitoring social media, the CFPB database, and other publicly available data, Flagstar Bank can address gaps in the customer experience and prevent:– Damage to the brand and the ability to attract new

customers

– Further potential legal penalties20

Citibank leads all other banks in the number

of student loan complaints per $ billion

Citibank AES/PHEAA KeyBank NA Discover JPMorganChase

Wells Fargo Sallie Mae U.S. Bancorp Bank ofAmerica

SunTrustBank

Company complaints per billion dollars in student loans

Sources: Beyond the Arc, CFPB, www.citigroup.com

Citibank’s student loan issues are reflected

in social media as well• Customers expressed difficulties with the transferal of their

loans from Citibank to Discover *:

– Unbeknownst to me, a portion of this additional payment was going towards interest! So basically, I am paying the minimum payment and 10% of the additional I am adding to principal was going into Discover's pocket as interest!!! It's ridiculous!

– I got a notice yesterday that Citibank somehow made a mistake and forgot to add the appropriate amount of interest to my principal loan balance to the tune of almost $4,300. Really? I have a huge problem with this

• Citibank can monitor the CFPB database and social media to identify customer experience issues and take action before they escalate into negative brand sentiment

* Comments taken from Citibank student loan page on Consumer Affairs.com

Complaint volume shifts in September, when

Citibank notified its customers of the transfer

Mar2012

Apr2012

May2012

Jun2012

Jul2012

Aug2012

Sep2012

Oct2012

Nov2012

Dec2012

Jan2013

Feb2013

Mar2013

Apr2013

May2013

Number of complaints per month

Citibank

Discover

September 2012, Citibank

sends notice out to its

customers informing them

about their student loan

transfers to Discover

Sources: Beyond the Arc, CFPB

The 5 bank account and servicing issues

trended form March 2012 to March 2013

Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13 Mar 13

The 5 issues as a percent of total complaints

Account management Deposits and withdrawals Insufficient funds Transfers/Payments ATM card

1195 1259 1662 1401 1302 1267 1096 1219 962 942 1253 1086 811

Note: Bar graph represents total number of complaints each month

PNC’s issue trend from March 2012 to

March 2013

PNC Bank - 5 issues (number of complaints)

BOA’s issue trend from March 2012 to

March 2013

Bank of America - 5 issues (number of complaints)

Capitol One’s issue trend from March 2012

to March 2013

Capitol One - 5 issues (number of complaints)

Citibank’s issue trend from March 2012 to

March 2013

Citibank - 5 issues (number of complaints)

TD Bank’s issue trend from March 2012 to

March 2013

TD Bank - 5 issues (number of complaints)

RBS Citizens’ issue trend from March 2012

to March 2013

RBS Citizens - 5 issues (number of complaints)

Chase’s issue trend from March 2012 to

March 2013

Chase - 5 issues (number of complaints)

US Bancorp’s issue trend from March 2012

to March 2013

US Bancorp - 5 issues (number of complaints)

SunTrust Banks’s issue trend from March

2012 to March 2013

SunTrust Bank - 5 issues (number of complaints)

Wells Fargo’s issue trend from March 2012

to March 2013

Wells Fargo - 5 issues (number of complaints)

U.S. Bancorp (NYSE: USB), with $355 billion in assets as of March 31,

2013, is the parent company of U.S. Bank, the 5th largest commercial

bank in the United States. Celebrating its 150th anniversary this year,

the company operates 3,080 banking offices in 25 states and 5,056

ATMs and provides a comprehensive line of banking, brokerage,

insurance, investment, mortgage, trust and payment services products

to consumers, businesses and institutions. Visit U.S. Bancorp on the

web at www.usbank.com.

Customer Experience

Office

Measurement

Customer Experience Managers

Strategic

Initiatives

Branch Engagement

VoC/ECU

Reporting

ECU -Executive Complaints

Speech Analytics/

Other Initiatives

Social

ject M

anagem

Our Customers, Team Member & Shareholders

Voice of the Customer Team

nceLending

Retail

Support

Payment

Mortgag

BusinessOnline ATM

Executive Sponsorship

Creative Team Production Team

• Product and

Development• Front Line & Support

• Provide Insights

• Connect the dots

• Ad Hoc Reports

Work Together

Interchangeable

Voice of the Customer Team - Putting it together

PMO, TOS,

Compliance

Action

Communicatio

nCelebration

Retail

Payment

Solution

24BHFS

Retail

Banking

Implemen

Sources & Data

Various places

Analysis & Reporting Sharing

• Enhancements and Edits – Categorization and Models

– Reports based on likes and use

• Consistency– Trend & Extract Reports

– Collaboration meetings & follow up

• Deep Dives– Hot topics

– Root Cause

– Complex stories

Commitment Is Key

In the wonderful musical 1776, there is line inspired by words John Adams

once addressed to his wife Abigail –

"Commitment, Abby – commitment! There are only two creatures of value on

the face of this earth – those with a commitment, and those who require the

commitment of others."

Dashboards

Executive Recaps

Ad Hoc with purpose

• Know/Don’t Know/Need to Know More– Discover/Deep Dive

– Use theme detection, Relationship Reports

• Special Events or Situations– Review volume/scale

– May be very specific phrasing or words

• Use Attributes– Can be telling for root cause

– Collaborate telling the story

Beware: Don’t Fall Into

the Pit Not efficient or effective

Can be hard to find your way

Our Customers, Team Member & Shareholders

Reprise, Celebrate Everything, &

SHARE THE WINS!

Often, Regularly & All Ways

Intranet ArticlesInternal Social Media

Newsletters/

Emails

Division Calls

Internal CXO site

Performance Reviews/Lessons Learned

• Regular meetings with

whole team (2x month)

• Top Categories easy to

identify

• Effort across enterprise

• Educate, (ABC’s of

analytics & reports)

• Plan on refinements

• Set Expectation with

data imperfections

• Take the time for “unique” opportunities

– Employee Survey’s

– Special Situation Surveys

Change in

Conversation

Preview of Upcoming Events

• Clarabridge Collaborate

– Currently Piloting

– Use to Distribute reports automatically

• Explore – Auto load sources

• Expanding sources and VoC Team

Thank you & Questions

Consumer Complaint ProcessElizabeth Clarkson

Umpqua Bank

Agenda

• Why you need an effective complaint

management program

• Key considerations for an effective complaint

management process and program

• Walk through complaint analysis and report

example

• Regulatory Requirement

• Increase Customer Satisfaction (customer

retention)

• Identify Opportunities to Improve Products and

Services

Regulatory Expectations

• Develop an enterprise-wide program for

overseeing the customer complaint process

• Compile, analyze, and summarize customer

complaints across the enterprise

• Use data to improve customer experience

• Robust Governance

Barriers to Successful Complaint

Management Program

• Lack of Standards (definitions, categories, etc.)

• Lack of, or different processes to receive, track, report

• Lack of responsibility and accountability at business unit

• Program separate from the Bank’s customer service

standards/culture

• Program’s scope too narrow or too broad

Elements of a Successful

Complaint Management Program

Start with Defining a Complaint

• Any expression of dissatisfaction with a product, service or

business practice that a customer or non customer has

experienced at your organization

• Includes verbal (person/phone) and written

(paper/electronic)

• Received through various channels

– Regulatory Agencies

– Consumer Protection Agencies (BBB)

– Frontline, Call Center, Online

Define When it is Not a Complaint

• Issue resolved in normal course of business

• Routine service request/issue: account balances,

transaction questions (missing or unauthorized)

• Disputes with a separate resolution process (Reg E, billing

disputes)

• Legal issues with separate resolution process (lawsuit,

contract dispute)

• Negative customer feedback in Bank sponsored surveys

• Negative customer feedback on non-Bank sponsored sites

(Blogs, Twitter)

Refining the Complaint Definition:

Regulatory Complaints

• Must be in writing

• All complaints submitted to a regulatory or consumer

protection agency

• All complaints submitted to Bank claiming a regulatory

issue or violation:– Services performed by third-party vendor/service provider

– Privacy or disclosure of NPPI

– Allegation products, services, or promotion misleading, abusive, or

deceptive

– Accuracy of deposit or loan disclosures

– Allegation of discrimination or unfair treatment in regard to application or

servicing of loan

– Community Reinvestment Act concerns

• Keep definition broad

Non-Regulatory Complaints

• Verbal complaints

– Responded directly by the receiving Business Unit associate and

escalated as necessary

• Written complaints

– Doesn’t fit regulatory definition

– May be related to Bank’s policies or procedures, and/or non-

regulatory service issues

– Train associates if not sure, then ask

• Each business area responsible for procedures on

– Investigating & Responding

– Documenting, Retention, Tracking, and Monitoring

Complaint Management Standards apply to

Social Media

• Negative posts on bank-sponsored sites (Bank’s

Facebook and Twitter) = Written

• A Rapid Response Team

– Facebook and Twitter monitored and responded to daily

– Complaints meeting regulatory definition are escalated per

standard process

• Monitor negative comments on other Social Media (Blogs,

Twitter, Facebook)

– Categorize by sentiment (positive, neutral, negative)

– Negative posts reviewed for trends

Complaint Management Process Standards

• Link to Customer Service Standards

• Roles and Responsibilities

• System to receive complaints from across Bank

• Strict submission and response timelines

– Applies to all complaints

• Record retention standards

• Training, Tools, and Resources

• Centralized tracking and trend analysis

• Reporting

• Ongoing Monitoring

Reference Tools & Resources

Complaint Decision Tree

Written

(By letter, email, or website)

Determine if Non-Regulatory

Follow Business Unit Complaint Procedures

Resolve and retain documentation per

Business Unit Complaint Procedures

Determine if Regulatory

Log and indicate which regulation(s) apply, if

Compliance will facilitate a response within 15

calendar days of receipt of complaint

Verbal

(In person or over the phone)

Handled on the Spot/ Escalate as Necessary

Resolve per Business Unit procedures on verbal

complaints

1) Determine which type of complaint you received

(Written or Verbal)

2) If the complaint is Written and Regulatory

complete the Written Complaint Log, otherwise

consult Business Unit Complaint Procedures

For more information about complaints see the

Complaint Procedures or contact Compliance at

compliancedept@

Training Elements

• Communicates Bank’s attitude toward customer

complaints

• Provides real life examples of what is and what isn’t a

complaint

• Defines the types of complaints

• Provides examples of regulatory complaints

• Shows how to submit a regulatory complaint

• Tests knowledge

• Consider customizing for each business area

Annual Review of Program

• Review all elements of the Program

• Review the non-regulatory complaint process

– Ensures Business areas are executing program appropriately

• Test Associate knowledge of policies and procedures

• Use results to enhance and expand the Program

Analysis & Reporting

Trend Analysis

• Type, Regulation, Volume…

• Potential Regulatory Issues

– Investigation not admission

– UDAAP

• Applies to non-regulatory complaints

– Business unit/area analysis

– Customer contact points

• Looking for red flags/opportunities

– Couple with Compliance Monitoring Activity

– Third Party Risk Management

Reporting Elements

• Compliance reporting is focused on regulatory complaints

– Include Social Media and/or Service trends

• Summarize recent complaint activity and impact, so audience gets a

little detail behind the numbers

• Categorize complaints for better trend analysis

• Year over year trending

• Distribution

– Internal Compliance Committee

– Executive Management

– Board

Analysis & Sample Report

Executive Summary:

•# of new complaints received since last report.

•Details on at fault complaints, service versus regulatory.

•Trends in complaints with regulatory issues “UDAAP risk has broadest applicability and remains the most common regulatory category investigated, but no UDAAP issues identified year to date.”

•Industry or environment highlights: “CFPB began accepting all types of consumer complaints with quarterly reports issued publicly”

•Analysis of social media sentiment (Facebook, Twitter, Blogs) provides additional tool to identify potential negative trends in consumer sentiment.

Assets Complaints

Projected Actual (YTD) Identified Bank Fault (YTD)

Direct to Bank

Regulatory Agency

Complaints by Referral Source

Customer Complaint Type

& Totals

Complaint by Type 20XX YTD

Deposit Process or Service X X

Account Authority/Suspected Fraud X X

Credit Reporting Dispute X X

Fees X X

Item Processing/Funds Availability X X

Loan Modification/Resolution X X

Loan Origination/Decline X X

Loan Servicing X X

Physical Environment/Safety X X

Privacy/Info Sec X X

Vendor Management X X

Affiliate X X

Customer Complaints by

Potential Regulation

Complaints by Reg YTD

Non-Regulatory

Fair Lending - Equal Credit Opportunity,

FHA, etc.

CRA - Community Reinvestment Act

Reg E - Electronic Funds Transfers

GLBA Sec 305 - Insurance Customer

Protections

Reg CC - Availability of Funds

FCBA - Fair Credit Billing Act (Billing and

Collections)

FCRA - Fair Credit Reporting Act (Using and

Sharing Credit Report Information)

Flood - Flood Insurance requirements

GLBA - Privacy and Information Security

RFPA - Handling government requests for

Financial Information

TIL - Truth in Lending

RESPA - Real Estate Settlement Procedures

TIS - Rates - Truth in Savings Rate issues

TIS - Fees - Truth in Savings Fee issues

UDAAP - Unfair, Deceptive or Abusive Acts

or Practices

ADA - Americans with Disabilities Act

State Reg - State-specific Regulations

Affiliate

Non-Reg% Fair Lending

%Reg E

TIS - Rates%TIS - Fees

UDAAP%

Vendor%

Summary of Complaints

with Bank Fault Identified

• Bank Fault – Service– Summary

• Bank Fault – Regulatory– Summary

Service%

Fault Not Yet Determined

No Bank Fault

Complaints - Bank Fault Identified YTD

No Bank Fault%

Fault Not Yet Determined

Deposit Process or Service

Loan Origination/

Decline%

Loan Modification/ Resolution

Bank Fault - Complaints by Type YTD

Social Media Monitoring Results

Sentiment Social Media Posts

Negative #

Neutral #

Somewhat Positive #

Positive #

Negative Sentiment

Breakdown of Negative Social

Media Posts

Incidental Mention - Post

mentions Bank, but negative

comment(s) not directed at Bank #

NASDAQ - Post addresses

Company Stock #

Corporate Concern - Post

addresses Bank corporate

practices (not consumer related) #

Non-Specific Consumer Concern - Unspecified consumer

dissatisfaction #

Non-Regulatory Consumer Concern - Specific non-regulatory

concern (e.g., service related) #

Regulatory Consumer

Concern - Specific regulatory

concern #

Negative%Somewhat

Positive%

Social Media Sentiment – YTD 2012

Incidental Mention

%NASDAQ%

Corporate Concern

Non-Specific Consumer Concern

Breakdown of Negative Social Media Sentiment – YTD 2012

Successful Costumer Complaint Program

• Link with Bank’s customer service standards

• Broad definition of Complaint

– Broad Regulatory Complaint Definition

• Communicate expectations/standards

– Formal, documented, communicated, tested

• Procedures, Tools, and Training

• A system to receive complaints from across Bank

• Robust and meaningful analysis and reporting

• Ongoing monitoring & continual enhancements

Lessons Learned

CFPB Top 10 Lessons Learned

1. It’s a whole new ball game

– It’s nothing like a Fed/OCC exam

– New relationships to build

– Need to build credibility

– They have political agendas

– They get to make the rules as they go

– Emphasis on enforcement

2. They view everything from the customer’s perspective

– It’s all about the customer

– Heavy focus on UDAAP

– They start with complaints and then work their way backwards

– Compliance management is kind of the last stop – versus with the Fed/OCC it’s the first stop

– When putting together your materials for them, focus on the customer experience

– Good idea to involve 1WF

– Therefore, it is important to emphasize programs, processes, and policies that focus on

customer advocacy, complaint management, call monitoring, voice of the customer, etc.

CFPB Top 10 Lessons Learned (Cont.)

3. It’s all about the data, data, data……

• Initial request

• Many follow up questions

• Oftentimes it feels like they don’t even look at the data – feels like they’re stockpiling it for later…

• Need to establish process for managing data requests

• Request letters are very comprehensive and responses require a tremendous amount of data

• Recommendation: Establish a process so that all requests are funneled through one person in

order to manage expectations and ensure some level of control.

4. Documentation is key

• Policies, procedures, notes in files, exceptions, etc.

• EVERYTHING must be documented

5. They think “surprise” is a good thing

• They appear to have a set of “rules” that they are using to exam us against – unfortunately, we

don’t have the rule book

• Ex. Limit of 1 rebuttal

• They are communicating their expectations through enforcement actions

6. Exam process is much more complicated

• Legal review required of all documents

• Legal review is required of ALL materials provided to the CFPB. This includes not only LOB

legal, but “CFPB-focused” lawyers as well

• Legal needs to be represented during all meetings with the CFPB

• Recommendation: Schedule regular checkpoint meetings once the examination starts. It will

provide an opportunity to ensure examiners have what they need, address any questions, build

the relationship, and, most importantly, discuss any potential issues as soon as possible.

• More corporate involvement – lots of interested parties

• Need to keep everyone apprised of exam progress

7. Logistics is important to CFPB

• Travel arrangements, lodging, restaurants – make it easy for them

• If allowing them to work remotely, make sure you have someone there to oversee them.

8. Call monitoring

• They will listen to many calls

• Presumptive sales

• Pace of speech

• “risk free for 90 days”

• “Only 69 cents”

• Need to have calls recorded – the full call

9. The exam will last longer than they anticipate and you want

• Need to plan accordingly

• It is a full time job and then some

• You won’t have time for anything else

10 . This is new to the examiners too – and WF is a complicated place to understand

• Kick off meetings helpful

• Need to teach them about our businesses and our company

• During discussions with examiners as well as in presentations, remember to integrate the roles of

OR and Audit – it’s important they understand their roles as well.

what the #!@$?: managing customer complaints

customer complaints

customer problems

customer attrition

valuable customer

cfpb database

key customer pain points

credit card companies

credit card data8consumers

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