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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 any customer communication (verbal and/or written) made to the fintech client or an agency that expresses dissatisfaction with a service or system, alleges an error, or alleges a violation by the fintech client of state or federal regulations and/or law. Specific complaints we are looking for are any that relate to fintech offerings such as ACH, debit card, broader money movement or technology related errors.

Complaints Intake#

Complaints intake can be handled based on your existing End Customer support system, as long as it allows you to track, respond, and resolve complaints in a timely manner. Additionally, by the time clients have at least 1,000 End Users on the platform, clients 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 allowing the client return all calls.

As the End User-facing and ultimate providers of financial products to End Users, Clients are required to effectively respond to complaints of End Users and utilize complaint data to identify and mitigate compliance risks. Given Unit’s role in enabling the offering of financial products for its Clients, it is Unit’s policy to assist its Clients in meeting their obligations and reducing risk by implementing a robust complaint management program. Unit manages such complaints by centrally collecting them from Clients, routing them to the appropriate stakeholder(s) for resolution if they were not resolved by the Client, and monitoring their handling to help ensure that applicable laws, regulations and Partner Requirements are met.

All complaints should be investigated and resolved within 30 calendar days and communicated to the End User within this timeline. 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 with the End User for at least 5 years. If you had a particular issue that was brought up by multiple customers, you can aggregate them to one report and let us know that the issue was escalated by X customers.

Reporting to Unit#

All complaints should be reported to Unit via the Unit Dashboard, by using the Support widget and choosing “Complaints Reporting → “Report a Complaint.” As part of this form, you will need to provide the following information:

  1. Customer ID (Customer ID can be found in the customer page in the Unit Dashboard)
  2. Customer Name
  3. Partner Bank - the bank through which the account is offered to the customer
  4. Complaint Category - the type of complaint that the customer submitted (see categories information below)
  5. Complaint Resolved? - indicate if the complaint has been resolved by you or requires Unit’s assistance
  6. Description of Complaint - provide more information on the customer’s claims

If, within a particular month, you did not receive any End Customer complaints, the bank requires that you fill out and sign an attestation that states that you have no complaints to report, and submit it via the Support widget in the Dashboard (choose “Complaint Reporting” → “Submit 0 complaints attestation”). 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 0 complaints during this time period.

Unit requires that all complaints will be categorized. The categories to which complaints are assigned determine how the complaint will be routed and tracked, and whether any applicable regulatory notice, investigation and timing requirements are met. Proper complaint categorization also allows Unit to better analyze complaint data, identify complaint trends, and perform root cause analyses.

Important Note: You might notice that some of the categories cover issues that your Support team occasionally escalates to Unit’s Support. As part of this process, you won’t need to submit a Support request in addition to the Complaint reporting. The Complaint will be automatically directed to Unit’s Support if you’ve indicated that the Complaint was not resolved.

Complaint categories#

We recommend that you think about the complaint concept as a spectrum. Not every customer inquiry under the categories below would be considered a complaint. If you receive a letter from an attorney, or a letter from the Better Business Bureau, this is clearly a complaint. However, sometimes you will receive operational questions that won’t be considered a complaint. much of it is up to your judgment based on the communication with the client: The level of dissatisfaction, and the ‘tone’ of the customer.

Example - Card Inquiries Category:

Not a complaint: A client is reaching out regarding a card decline. you explain that the customer exceeded their limits. The customer responds: “Thank you, I haven’t noticed. Have a good day”. This would not be considered a complaint.

Complaint: A client is reaching out regarding a card decline. you explain that the customer exceeded their limits. The customer responds: “I didn’t realize that those are the limits that you are imposing! It makes no sense, what kind of service is this?” - this should be considered a complaint.

once you’ve identified a customer question / issue as a complaint, here are the categories you should report the complaints under:

  1. Missing deposits - Deposit that should have landed at the customer’s account on your platform or a payment that was sent from the customer’s account on your platform
  2. Payment rejection reason - clarification on a payment that was initiated from the customer’s account on your platform and was rejected
  3. Card inquiries - card declines, card blocked, authorization holds, missing card orders
  4. Unauthorized activity - Card disputes or ACH disputes
  5. Remaining balance check - missing a remaining balance check for closed accounts
  6. Identity theft - users that reach out to you and report that their identity has been wrongfully used for account creation
  7. Errors on periodic statements - customers are identifying an error on their monthly statement
  8. Fee complaints - misrepresentation of product or service fee features or dissatisfaction with fees on a product or service
  9. Legal or regulatory violations - Customer claims around regulatory or legal violations that your business performed
  10. Complaints received from attorneys - On behalf of an End-User
  11. Product or service complaints - Dissatisfaction with product or service features or benefits, Misrepresentation of product or service, Change in product or service without proper notification
  12. State or federal government agencies and regulators complaints

We recommend that you think about the complaint concept as a spectrum. Not every customer inquiry under the categories below would be considered a complaint. If you receive a letter from an attorney, or a letter from the Better Business Bureau, this is clearly a complaint. However, sometimes you will receive operational questions that won’t be considered a complaint. much of it is up to your judgment based on the communication with the client: The level of dissatisfaction, and the ‘tone’ of the customer.

Example:

A client is reaching out regarding a card decline. you explain that the customer exceeded their limits. The customer responds: “Thank you, I haven’t noticed. Have a good day”. This would not be considered a complaint.

A client is reaching out regarding a card decline. you explain that the customer exceeded their limits. The customer responds: “I didn’t realize that those are the limits that you are imposing! It makes no sense, what kind of service is this?” - this should be considered a complaint.

Unit's Complaint Management#

Once Unit receives a complaint from you, if the complaint is marked as not resolved, Unit will handle the complaint and support you with resolving the issue for the End User. Once the complaint is resolved, or if you reported it as resolved when you submitted it, it will be routed to our complaint reporting system. Unit will provide partner banks with complaints reporting on behalf of you, according to the bank requirements.