Simple Fix: Vendor Management
One thing regulators have been picking up on lately ...
We all know complaints are hot right now. To satisfy our Compliance Management responsibilities, we need to collect, record, and respond to them. Regulators search the internet for non-reported complaints pre-examination, and the CFPB maintains a public database where it has published almost 700,000 complaints so far. For them pre- examination, scouring the internet on social media, the Better Business Bureau, etc. (very interesting reading).
But financial institutions are getting pretty good at complaint management. Many institutions, for example, have adopted policies to define complaints as including both written and verbal complaints - a common weakness cited by regulators for a period of time.
But there's one thing you might be missing - complaints received by 3rd party vendors. Yes - we are expected to monitor any complaints sent to our vendors when it's regarding our products or services, or a product or service the 3rd party is providing on our behalf.
The good news is that there's one easy way to protect yourself from regulatory scrutiny - include a clause in every vendor contract that requires the vendor to report any/all complaints to your organization. There's no magic language, but it might go something like this:
[Vendor name] agrees to report any and all consumer complaints to [financial institution] in a timely matter, not to exceed 48 hours. [Vendor] will retain all records related to this complaint. For these purposes, complaints include those related, in any way, to products or services provided by [financial institution] or by [Vendor] on our behalf.
You might clarify the procedure more, or maybe include a better definition of a complaint. But this is the general idea.
Now, you might get some pushback from vendors on this. But stand strong. Vendors providing a service to your customers are providing a service for you. This isn't only good for you ... federal regulators don't normally go in to audit a vendor, but they have a full right to if the vendor refuses to cough up consumer complaints. No vendor wants the FDIC spending too much time with them - that's not going to be good for business!
Bringing this to real life ... if you close 2,000 mortgage loans a year with 225 closing attorneys, how many complaints are forwarded to you by closing attorneys each year? If your answer is zero, just keep in mind that won't get you a slap on the back from your regulator, that will translate to "I'm not doing a good job collecting complaints."
So it's pretty much that simple. Ideally you're monitoring for any funny business, e.g., you have a large vendor that's reporting never having received any consumer complaints. Are they really collecting/reporting?
In Other News
So it's the end of an eara ... the "Spelling Bee Bandit" has been arested for bank robberies in Burlington, Arlingtun, Peebody, and Reding. This Chelsea man got the nickname after passing a note to the bank teller in his first robbery that said "Robery" (sic).
Hey anybody working with/as a mortgage broker in Massachusetts, remember the Loan Originator Compensation Agreement previously required for mortgage brokers has been repealed in the past year and should no longer be in your loan files.
Fannie Mae sued for fair lending violations?
The quote below is interesting. First of all, because of it's origin. Some attribute this as an "African proverb," some to Richard Branson, some to Al Gore. Al Gore gave this quote in an interview, but then years later on the show 30 Rock quipped that "You know, there's an old African proverb that I made up ..."
It's also interesting because it's easy to read this as an indictment of someone who wants to do something alone. I don't read it that way, necessarily. When something's gotta get done quickly, you might just have to do it yourself. But obviously for many issues, you'll progress further working as a team. One example - borrower needs an answer on a rate lock by today. You could just do it yourself in half an hour. Or you could work with the new guy on the lock desk - maybe it takes you an hour, but long- term that might be better for the department.
"If you want to go quickly, go alone. If you want to go far, go together."
- Anon.
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