THE CFPB ARE COMING

What are the CFPB out for? Some think it’s legislative or political. Some think they’re after setting an example by calling out a particular bank and announcing a huge enforcement action. Some think they’re just a regulator simply looking for respect. Or are they just out to protect the consumer?

I believe they truly are looking to protect the consumer, but regardless of what you believe their intentions to be, it’s evident that they’re lurking among banks and other financial services providers. Now it’s simply a matter of what are you doing to prepare? What it comes down to is proving you are doing the right thing, even if you’ve been doing that all along.

So how can we show this? Well ultimately they want to see that banks are taking the policies and practices that inform how they operate, and build those into a strategy and executional mode that can be verified. Meaning, there’s a dashboard of results. There’s a way to handle exceptions. There’s a way to escalate results. There’s a method to track and manage any remediation efforts and use those efforts to create a feedback loop that will inform future policies. And, of course, provide an audit trail showing that we’ve done all of the above.

Something else they are looking for is control and explainability. From managing contacts, offers, disclosures, to off system (typically manual) processes such as bankruptcies, disputes, and complaints, they’re examining these and pushing to get more systematic. At the end of the day it seems they want banks to not only prove a level of control, our level of transparency for all touch points, interactions, and outcomes as it relates to the customer experience, but also to possess explainability. Despite how great a model might be, if we fail to explain how it works and how it works consistently, then we might fail to explain all together.

CMC's platform was built to make it easier to manage both the frequency and execution of contacts across all of the channels of communication (digital, letter, agent) and to provide, through a business rule driven decisioning and workflow engine, the transparency and control that lets you know exactly what the customer experience is. What touch point, what content (document or disclosure), and if that content is compliant by state and municipal level segmentation. The same is true with payment program offers. We’re using a rules based approach to ensure that the offers are both consistently and fairly applied with no out of bounds bias. We also capture express consent at channel and individual address level.

Complaints, is a big buzz word in CFPB related conversations. They want to know not only that you are tracking complaints but that you are proactively remediating the complaints and trying to figure out how to avoid their occurrence in the future. With the ability to build out workflows for escalation and escalation handling you have a record of tracking root causes so that you can find ways to proactively avoid them in the future. When it comes to client exception reviews we can set up workflows within FlexCollect that will automate the steps and data capture so you not only have the reporting capacity but also ability to proactively build queues for exception handling. Another way to use the FlexCollect system is to do some sampling and monitoring on a targeted basis. With our decision tree approach you can segment out testing control populations or small audit sample populations that can be set up in a separate queue to have a full review. 

Full and complete management of third party agencies is another hot button. We just deployed a document capture and review process so that you can have a single repository for all docs you require from your agencies in an automated fashion. This allows you to establish escalation and exception handling queues and automated alerting that would tell an agency for example that their certificate for a particular state is about to expire. 

Also enabling agencies to do their work off of our FlexCollect system, you could control the terms of contacts and give them as much freedom over their own strategies that you are comfortable with, ultimately centralizing your customer experience management. You might also want to standardize the digital channel interfacing that their agencies use – for consistency purposes. Finally, using the decisioning engine as an after the fact monitoring capability where the agencies put their results back into FlexCollect – we run the strategies to show you what exceptions and escalations queues would result as a result of the things that are already done.

The CFPB are coming, and we can help you be ready.