2016 marked a CFPB milestone of one million complaints! Based on the CFPB’s Consumer Response Annual Report for that year, the majority had to do with loans but other products and services weren’t totally neglected either. Almost half of the complaints geared towards other bank products and services had to do with account opening, closing, and management. One example, a consumer applies for an offer only to find out they weren’t eligible to begin with. That got us to thinking, are you clearly presenting your products and services and/or offers?
Other notable complaints included when funds are made available (including for mobile deposits); overdrafts (amount and transaction ordering); and error resolution procedures. Good for the CFPB, though, in clarifying that some complaints stemmed from a consumer’s dissatisfaction with a product or service, which doesn’t mean the transaction is unauthorized under Regulation E.
Interestingly enough, there were also a number of deposit-related complaints related to getting information and access to accounts of someone who has died. On the loan side, complaints in this area have led to more regulation for “successors in interest”. Understandably, this is a tough spot for bankers because we’re so tuned in to privacy and non-disclosure. We recommend getting together with legal counsel to determine what a person needs to provide to you in order to demonstrate they should have access to an account when a death occurs. Not knowing what you need or asking for more than you need will likely cause you some headaches.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!