Complaint Management
Introduction
The effective management of End User complaints is a core part of Unit’s Compliance Management System and is critical to ensuring that Unit’s clients are meeting compliance obligations on behalf of its Partners and Clients. End User complaints are also an important source of information that allows you and Unit to identify and mitigate compliance risks, better design your products and services, and prevent consumer harm and/or violations of laws and regulations. If an End User is dissatisfied with a service that you offer, this information should be shared with Unit as part of our Complaint Management Program.
A complaint is expressed dissatisfaction from an End User in connection with a financial product enabled by Unit. Complaints can be oral or written and can be received from End Users, regulatory agencies, bank partners, etc. A complaint is an expression of dissatisfaction with a financial product, service, policy, fee, etc. Specifically we are looking for sentiments that relate to fintech offerings related to banking services such as ACH, debit card, broader money movement or technology related errors. A complaint does not include communications from End Users alleging transaction errors or unauthorized activity related to financial products. Complaints do not include routine inquiries or requests for information or documents.
Complaints Intake
In most cases, complaint intake can be facilitated through an existing End User support system. An adequate system includes the ability to track, respond, and resolve complaints within established timeframes. Please note, Client’s with at least 1,000 End Users on the platform, must maintain a telephone number for End Users to call and leave messages. This does not need to include 24 hour support; however, it must, at a minimum, include a voicemail that is actively monitored and allows the Client to return all calls.
Complaints from End Users are received in two ways:
- Directly from the End User or on behalf of the End User to the Client. This can be received via email, chat, phone call, social media comments, etc.
- Directed to the Bank Partner from or on behalf of the End User. Unit shares these complaints with Clients who are responsible for researching and responding through established channels and within required timeframes.
Complaints received directly from End User to the Client should be investigated and resolved, including notification to the End User, within 30 calendar days of the complaint receipt. For complaints directed to the Bank Partner from the End User, the Bank Partner will establish timelines for response. In many cases these complaints are sent to the bank by the Attorney’s General, Better Business Bureau, CFPB, FDIC, OCC, etc. and are subject to stricter timelines (typically less than 10 days). Prompt attention to complaint research and resolution is strongly encouraged. Failure to adhere to deadlines, provide complete information, adequately address complaint(s), etc. may result in bank imposed service disruptions.
Unit will cooperate with its respective banking partners in the resolution of all material Client, End User, and non-End User complaints related to the Program. Clients should retain any communications (emails, letters, phone call recordings, chats, etc.) with the End User for at least 5 years.
How to Track Complaints
Please note Clients working with Piermont Bank have a different tracking and submission process. Please reach out to your Customer Success Manager with any questions.
Complaints are to be tracked using the Unit Complaint Tracking Template. Complaints received directly from an End User or on behalf of the End User to the Client must be investigated and resolved, including response back to the End User, within 30 calendar days of the complaint receipt. Complaints received by the Bank Partner from or on behalf of the End User will be forwarded to the Client via Unit. Clients are responsible for investigating all claims and providing a written response (including supporting documentation) by date indicated by the bank partner (typically less than 10 days). Prompt attention to complaints is critical to ensure a thorough investigation can be completed before the due date. Both direct complaints and bank received complaints are to be tracked using the Unit Complaint Tracking Template.
Tips for Researching and Responding to Complaints:
Start researching complaints promptly upon notification.
Identify the account(s) impacted. Ensure the Complainant is a signatory to the account giving them rights to the information.
Be sure to research and address each point the Complainant identifies in their communication.
Document events in chronological order. Collect supporting evidence of the events that occurred with the Complainant and any other involved party (i.e. letters, chat text, emails, call recordings, bank statements, etc.).
- If an account closure check was issued or a refund of any kind awarded, document the date, amount, check number, etc. as evidence.
Outline the investigation that took place in the response narrative.
Address the Complainants’ requested remediation. Explain how the sought after remediation was provided. If it wasn’t, explain and evidence why the requested remediation is not possible.
Complaint Reporting to Unit
Please note Clients working with Piermont Bank have a different tracking and submission process. Please reach out to your Customer Success Manager with any questions.
Complaints are to be tracked using the Unit Complaint Tracking Template. Clients must submit their completed complaint log monthly to complaints@unit.co on the 1st of the month; reporting on the previous month's complaints.
If, within a particular month, you did not receive any End User complaints, the bank requires that you fill out and sign an attestation that states that you have no complaints to report. The company employee that signs the attestation is up to your discretion, as long as they are well suited to confirm that you've received zero complaints during this time period. Clients must submit their Zero Complaint Attestation to complaints@unit.co on the 1st of the month; attesting to receiving zero complaints in the previous month.
If the 1st of the month falls on a weekend (Saturday or Sunday) or a US federal holiday, complaint data is due on the following business day.
Incomplete or Late Submissions
Complaints can provide valuable information about the products and services Clients offer but also can identify areas of improvement for Unit and Bank Partners. Prompt review, investigation, communication and reporting are critical for an effective complaint management process. Bank Partners rely on this information as a critical part of their Compliance Management System and as a result require timely and complete submission of complaint information.
Bank Partners and/or Unit may impose limitations on access or requests if complaint data submitted does not adhere to this guidance and accompanying documentation and instructions. Incomplete, inaccurate or late data can result in a warning, pause on feature build requests, pause on new applications, etc.