Compliance Blog

Written by Michael Coleman, Regulatory Compliance Counsel

Yesterday we blogged about the CFPB's new Consumer Complaint Database. We mentioned that unfounded complaints can present a reputation risk to credit unions. Today we want to focus on NCUA's procedures and guidance for complaints made to NCUA, and some steps that credit unions can take to manage their reputation risk.

NCUA's Office of Consumer Protection (OCP) is NCUA's newest office and is responsible for member complaints. OCP maintains a Consumer Assistance Center which contains the page "Help With My Credit Union" designed to help members with the complaint process. NCUA states the following regarding when to file a complaint with NCUA:

"First, Attempt to Resolve the Complaint Directly with Your Credit Union 

Before you contact NCUA, please contact the credit union directly to attempt to correct the problem. You can do this over the phone, in person or in writing. If you believe the credit union's staff is unresponsive to your inquiry or complaint, address your concerns in writing to the president or chief executive officer of the credit union or the credit union’s supervisory committee."(emphasis added).

As you can see, NCUA stresses the importance of trying to resolve the complaint directly with the credit union before submitting a complaint to NCUA. This is a great opportunity for your credit union to manage your reputation risk. As we have talked about in the past, there are bound to be some complaints received at your credit union, but poor handling of member complaints can negatively affect your credit union's reputation. Here are some steps that your credit union can take to mitigate these reputation risks arising from complaints:  

• Establish a process for handling member complaints and train your staff to implement it. Prompt responses to member complaints will hopefully resolve the issue and prevent a complaint from being submitted to NCUA.
• Create written policies and procedures for member complaints.
• Monitor the complaints that you receive. This will help you identify patterns in complaints and help you take corrective action where necessary.

Even with effective reputation risk management and an effective complaint response program at your credit union, some complaints may still be submitted to NCUA.  We'll talk more about the actual complaint process in a future blog post.

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CUSO Rule Pulled.  Yesterday, NCUA heeded NAFCU's advice and removed their CUSO rule from their June Board Meeting.  And, since the CUSO rule was the only agenda item - canceled the open meeting.  NAFCU Today has more information.