NMP - July 2018 - 39

By Jonathan Foxx, Ph.D., MBA

Steps for Responding to Consumer Complaints

I

1. Consumer submits a
complaint about a consumer
financial product or service by
Web, telephone, mail, fax, email or another agency refers
the complaint to the CFPB.
Consumers who submit
complaints directly to the
CFPB's Web site can opt to
have their complaint narrative
published in the Consumer
Complaint Database.
2. Consumer Response screens
the complaint for

3.

4.

5.

6.

7.

completeness and sends it to
the company identified by the
consumer via the secure
portal for a response or refers
it to the appropriate regulator.
Company reviews the
complaint, communicates with
the consumer as appropriate,
and determines what action to
take in response.
Company responds to the
consumer and the CFPB via
the portal.
Optional: Company selects
from a structured list of public
company response categories.
CFPB invites the consumer to
review the company's
response by logging into the
secure Consumer Portal or
calling the CFPB's toll-free
number.
Consumers are given the
opportunity to provide
feedback to the CFPB about
the complaint process.

8. Complaints are published in
the Consumer Complaint
Database when the company
responds to the complaint
confirming a commercial
relationship with the
consumer, or after the
company has had the
complaint for 15 days,
whichever comes first. With
consumers' consent, scrubbed
complaint narratives will be
published when the company
selects an optional public
response or after the company
has had the complaint for 60
calendar days, whichever
comes first. Complaints can be
removed if they do not meet all
of the publication criteria.
9. Complaint data and
information is shared with
other offices within the CFPB,
including, but not limited to,
enforcement and supervision,
as necessary.

Jonathan Foxx, Ph.D., MBA, is the Managing Director of
Lenders Compliance Group, the first and only full-service,
mortgage risk management firm in the United States,
specializing exclusively in outsourced mortgage compliance
and offering a suite of services in residential mortgage
banking for banks and non-banks. Information contained in
this article is not intended to be and is not a source of legal
advice. If you would like to contribute a question, please
submit it to Compliance@LendersComplianceGroup.com.

n National Mortgage Professional Magazine n JULY 2018

Answer
In the readiness reviews that we
do in anticipation of examinations
conducted by the Consumer
Financial Protection Bureau
(CFPB), one of the important
policies to always review is the
one relating to consumer
complaints. Keep in mind that the
CFPB considers the appropriate
handling of consumer complaints
a foundational pillar of a
Compliance Management System.
Response time and process
flow are critical aspects of the

compliance requirements vis-àvis consumer complaints. The
CFPB answers consumers'
questions and sends consumers'
complaints directly to financial
companies. It expects to work
with companies in such a way as
to get the consumer a response,
generally within 15 days. The
CFPB considers responses to be
past due for complaints that have
exceeded the 15-day limit by
which a company must provide
an "in progress" status or the 60day time limit by which a
company must provide a final
response to a consumer
complaint.
The Consumer Response
process requires the following
nine steps:

NationalMortgageProfessional.com

Question
n our recent CFPB exam,
the examiners noted that we
did not have a policy and
procedure in place for
consumer complaints that
took the CFPB's Company
Portal into consideration. I know
the policy is supposed to provide
the procedures, step by step, for
handling consumer complaints
that originate through the portal.
Our Compliance Attorney asked
us to contact you, as she said you
provide such policy documents for
consumer complaints. So, what
are the steps that we should be
following when we receive a
complaint through the CFPB's
complaint portal?

39



Table of Contents for the Digital Edition of NMP - July 2018

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