Tracking customer disputes and complaints has become an incredibly important process in the collections industry since the Consumer Financial Protection Bureau came into existence five years ago. And the CFPB thinks that collection agencies and other companies in the industry are not listening or are giving complaints “short shrift,” according to an industry lawyer who spoke during a webinar last week on the importance of analytics in tracking and addressing complaints and disputes. The webinar was hosted by Callminer.
“As [CFPB] Director [Richard] Cordray has said, it would be compliance malpractice not to read closely what [the CFPB] has done to other companies,” said Tomio Narita, with the law firm of Simmonds & Narita. The CFPB thinks that companies are “not analyzing what complaints mean to their business.”
A major issue when tracking complaints is the complaint itself. It can be hard to delineate when an individual is complaining and when it does happen, it usually comes in the form of “unstructured data,” said David Cherner, the chief compliance officer at Northland Group, a collection agency. Analytics can help detect complaints and disputes and make sure that they are dealt with promptly and properly. Analytics can also be used to identify complaints or disputes that were not flagged as such by the agent involved in the interaction, Cherner said, allowing for those incidents to be categorized and used as possible future training opportunities.
If the CFPB ever knocks on an agency’s door, it is going to want to know how that agency is managing complaints. Does it know how many complaints it has received? What is the process for handling complaints? “There is an opportunity ti use analytics that will allow you to get concrete information about your business,” Cherner said.
Northland has developed a specific process for handling complaints, Cherner said. Agents are trained to flag a complaint as it comes in, which triggers an automated report to the company’s compliance department to review those calls. The compliance department then determines if a report to the client is required. Complaints are also categorized in an internal database and analytics are used to help build criteria that would identify calls as being unsatisfied or if there is a suspicion of wrongful conduct.
What makes the situation difficult, Narita said, is that there really is not a standard definition of what constitutes a complaint. And calls that may start out with a dispute may get worked out on the same call. How should those be categorized?
Cherner admitted that there is an expense to this process and that it is not cheap. But that does not mean it is not important.
Narita provided a set of guidelines for agencies for how complaints should be handled during his presentation. Those are:
- Agencies need specific criteria for identifying disputed accounts in order to give them special handling
- Agencies need to be comfortable with their definition of dispute
- Agencies need a process to identify verbal disputes
- Agencies need trained staff to correctly handle and promptly report disputed accounts
- Agencies should conduct additional review or verification of disputed accounts and track dispute resolution results