Staying off the CFPB radar

Aligning Consumer Expectations, CFPB Expectations, and Your Business

Scott Cornell, CEO

Consumers and the CFPB

Source: Beyond the Arc, Inc. 2013

Social MediaComments Complaints

Filed at CFPB

$214M Fine

You want this!

Different perspectivesTo a Credit Union:A consumer is a person in need of a loan

To the CFPB:A consumer is a victim in need of help

First to the Credit Union… then social media….

o 51% of those who got a response to their complaint had a positive reactiono 22% then posted a positive comment

But even this is changing…..

Where do consumers go to complain?

Poor Service

26% Complain on Social MediaDo Nothing

Ignored Complaints79% felt complaint was ignored21% had their complaint answered

At the CFPB it’s all about complaints!

“Complaints provide indications of potential regulatory violations, including unfair, deceptive, or abusive acts or practices”

“How the entity handles complaints is also a key element in evaluating its compliance”

- The CFPB

“Consumers just don’t think about going to the government for help” – Internal CFPB survey

Have you looked at this process?

It’s a CFPB complaint menu!

Business is good!

300,000 complaints filed so far.

Nov-11

Jan-12

Mar-12

May-12Jul-1

2

Sep-12

Nov-12

Jan-13

Mar-13

May-13Jul-1

3

Sep-13

Nov-13

Jan-14

Mar-14

May-140

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

Complaints Filed Per Month at the CFPB

If that weren’t enough…here’s more places to complain!

1. CFPB http://www.consumerfinance.gov/

2. OCC  http://www.helpwithmybank.gov/index.html

3. FDIC http://www.fdic.gov/consumers/questions/consumer/complaint.html

4. NCUA http://www.mycreditunion.gov/help/Pages/Submit-Your-Complaint.aspx

5. FED http://federalreserveconsumerhelp.gov/?District=1 

6. SEC  https://tts.sec.gov/oiea/Complaint.html

7. FTC http://www.ftc.gov/about-ftc/bureaus-offices/bureau-consumer-protection

8. State of NH http://www.nh.gov/banking/consumer-assistance/complaint.htm

9. State of MAhttp://www.mass.gov/ocabr/government/oca-agencies/file-a-complaint.html

10. State of VThttp://www.dfr.vermont.gov/banking/consumer-resources/file-complaint

A consumer’s view of you

I need info!

Bank Staff• Call Center• Front Line • Management

Bank E-Channels• Website• Online Banking• Mobile

Bank Venders / Partners / Brokers / Processors• Call Center• Website

Social Media

Gov’t Agency• Call Center• Website & Complaints

I need to communicate!

What consumers the CFPB wants…

Comparing expectations…

What consumers want…1. Be professional2. Be clear3. Be fast4. Be everywhere

Expectation #1: Be professional

Consumers are expecting:• For you to know us• For timely responses• To be treated fairly

The CFPB is expecting:• For you to centralize consumer complaint and response management• For you to develop consumer analytics and trend analysis

Expectation #1: Be professional

Consumers say…

Top 2 reasons we stick with you

1. Friendly employees 2. Ease of finding information

But 78% of us will abandon you due to poor member service

And we are 2X as likely to talk about bad member service

Expectation #1: Be professional

The CFPB says…Your consumer complaint management program should include:

Channels to receive consumer complaints and inquiries Proper and timely resolution of all complaints Recording, categorization, and analysis of complaints and inquiries

– CFPB Supervisory Highlights, Summer 2013

Reiterated in:

• CFPB Supervisory Highlights, Spring 2014

• CFPB Bulletin, Responsible Business Conduct

• CFPB Supervision and Examination Manual

• CFPB Dodd-Frank Mortgage Rules Readiness Guide

Expectation #2: Be Clear

Consumers are expecting:• To easily find and understand information on product and policy• Consistent answers from employees and all other electronic

channels

The CFPB is expecting:• Non-deceptive, clear, easy-to-read collateral• Well trained employees with consistent information• You to demonstrate effort in member education• Consistency of service and information

Expectation #2: Be Clear

Consumers say…• 52% make it easy for us to ask questions and access info

• 36% improve your search and online experience

The CFPB says…

Don’t put out deceptive ads… And be clear (even in Spanish)

$40M – AMEX was fined, in part for “not providing Spanish language scripts to CSR’s … and all written material provided to consumers…”

$225M – GE Capital was fined for “not extending [offers] to customers who indicated that they preferred to communicate in Spanish”

¡Ayuda!

Expectation #3: Be fast

Consumers are expecting:• We want it yesterday

The CFPB is expecting:• You to deliver responses promptly• You to automate as much as possible

Expectation #3: Be fast

25% will abandon your website if we cannot easily find what we are looking for.

56% said you were too slow to resolve our issues.

75% say valuing our time is the most important thing you can do.

Consumers say…

9am10am

11am12pm

1pm2pm

3pm4pm

5pm6pm

7pm8pm

9pm10pm

11pm12am 1am 2am 3am 4am 5am 6am 7am 8am

0

2000

4000

6000

8000

10000

12000

14000

16000

18000

20000

Time of Day: Consumer Inquires54%

After Hours46%

Business Hours

Source: SilverCloud Inc.

Expectation #3: Be fast

Expectation #4: Be everywhere

Consumers are expecting:• To get full service online• To be Mobile • For you to be in social media• To communicate with employees when we need them• To be talking to you, not your vendors

The CFPB is expecting:• Provide consistent service and information across all channels• Enable compliant and error submission across all channels• Integrate information and complaint process with your vendors

Expectation #4: Be everywhere

Consumers say…

72% of us go online first to resolve a problem – Forbes

48% of us with smart phones use mobile banking - The Federal Reserve

26% of us will post negatively on Facebook if we get poor service

Expectation #4: Be everywhere

The CFPB says…

3rd PARTIES: “The fact that a [FI] enters into a business relationship with a service provider does not absolve the [FI] of responsibility for complying … and it may be held legally responsible for violations by the third party.”

– CFPB Supervisory Highlights, Spring 2014

FACEBOOK: “...a [FI] may establish one or more specified channels that customers can use for submitting communications directly to the institution.”

– FFIEC Final Guidance Notice, Social Media

MOBILE: “[With mobile] consumers may find it harder to access customer service when there is an error or something goes wrong. The Bureau is seeking information on what types of customer service or technical assistance are available to consumers when they use mobile products.”

- CFPB Inquiry Into Mobile Financial Services

Expectation #4: Be everywhere

A little more from the CFPB Supervision and Examination Manual

Channels for Consumers to Contact the Entity. • Identify all channels the entity makes available for consumers to

submit inquiries, complaints, and disputes… • Assess the effectiveness of each of these channels

Offense is the best defense with the CFPBStay off the radar!

1. Reduce complaints in the first place2. Capture as many as you can yourself – don’t let your

customers go elsewhere with them!3. Centralize all complaint channels

• For complaint, inquiry and feedback management • For analysis and for auditing

4. Technology is your ally with the CFPB.

What is that Technology?

Technology that enables consumer Information Accuracy and Consistency

– All info, all places Engagement

– Consistent experience across all channels Complaint and Response Management

– Capture, track, respond Analytics

– Trends in products, issues and desires

Specifically, technology that:1. Facilitates outbound knowledge

• Automated information access• On every channel• Make it comprehensive, engaging and useful

2. Facilitates inbound communication and responses• Inquires, feedback and problems• On every channel• Manage and track all responses

3. Does analysis! • Find trends for compliance improvement• Find trends for revenue improvement!

Big benefits of aligning expectations1. Increased Compliance - Stay off the radar!

• Better meet CFPB conduct and service expectations

2. Increased revenue• Better consumer loyalty, education, service. Higher product and

self-service adoption. Higher loan growth

2008 2009 2010 2011 2012 2013

SilverCloud ClientsNon-clients

Average Loan

Growth

1.08

1.06

1.04

1.02

1.00

0.98

Big benefits of aligning expectations1. Increased Compliance - Stay off the radar!

• Better meet CFPB conduct and service expectations

2. Increased revenue• Better consumer loyalty, education, service. Higher product and self-

service adoption. Higher loan growth

3. Increased competitiveness• Better meet consumer expectations• 95% auto answer, lower abandonment, omni-channel experience

4. Decreased costs• In call center (20%)• In reporting and auditing time• In enforcement actions

5. Greater Business Analytics

So what would a solution look like?

Getting info to consumers

Bank Staff Bank E-Channels Social Media

consumers

Employee Knowledgebase

ConsumerKnowledgebase

Answers Product info Calls to action Customer Service

Bank Staff Bank E-Channels Social Media

consumers

Response Management

Inquiries Problems Feedback

Enabling Complaints and Inquires

With consumer self service• 24/7 service and engagement• Always deliver instant, consistent, accurate answers

Across every channel

Thousands of answers with thousands of CALLS TO ACTION Promote and advertise product and drive more business.

And driving engagement

While reducing and managing complaints

Capture all consumer inquires• From any channel (Website, Mobile, Facebook, Call center)• From 3rd Parties

Manage• Categorize and manage complaints • Escalate & respond to complaints

Track• Record submitted complaints• Record notes, escalations and all service rep responses

Report & Analyze• Audit and report responses and turnaround times• Analyze for trends

And generating consumer analytics

So stay off the CFPB radar!

1. Reduce Complaints first …then manage any complaints that come in properly!

2. Keep that Consumer Perspective“Expectations: Be professional, clear, fast, everywhere.”

• Provide easy access to information on every channel• Improve complaint and inquiry submission on every channel

3. Technology is your friend with the CFPB• Always have analytics and reporting on complaints• Centralize content and complaint processing

Let’s Connect…

Scott Cornell 978-590-1703 scott@silvercloudinc.com www.silvercloudinc.com