Attorneys amp Collectors Overview 2 Confidential Overview of Training 3 This training will cover Citibanks policy and process for handling complaints received on the phone After this training you will be able to ID: 735305
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Slide1
2017 Citi Complaint Training
Attorneys & CollectorsSlide2
Overview2
ConfidentialSlide3
Overview of Training3
This training will cover Citibank’s policy and process for handling complaints received on the phone.
After this training you will be able to:
Identify complaint trigger language
Identify what is a complaint
Identify what is not a complaint
How to escalate a complaint
How to properly
document the complaint
ConfidentialSlide4
Citibank Complaints4
ConfidentialSlide5
How To Identify a Complaint5
The term Consumer includes any individual who is:
A current or former customer of a Citi product or service; or
Impacted by a Citi financial product, service or asset, including an individual who does not have a Citi financial product or service; or
Applying for a product or service (i.e. "Potential Consumer
")
ConfidentialSlide6
How To Identify a Complaint (Cont.)6
In addition to the verbatim and example phrases
provided on the next few slides, you
should also consider the demeanor as potential signs of dissatisfaction such
as:
Tone or an increase in
volume
Voice inflection or an increase in pace of
speechCommunication
style
Continued repetition of key words by the consumer
ConfidentialSlide7
Complaint Types & Triggers7
Over the next few slides specific complaint types & verbiage will be covered.
ConfidentialSlide8
Complaint Types & Triggers (Cont.)8
Confidential
A
Complaint Has
:
Example
Verbatim
Example Triggering
Phrases
Expressions
of
Dissatisfaction
Wrongdoing
Consumer
displeasure
Request for escalation / speak to
supervisor
Threat to file regulatory
complaint
Dissatisfaction as it relates to
Point of sale (POS) card declines
"
I want to file a
Complaint"
“I am unhappy
about…”
"I had a terrible experience with..."
"Citi screwed this
up“
"
This was not what I
requested“
"
I'm really annoyed
by
this"
"You are going to lose a customer"
"I'm going to notify the
CFPB"
"This is
crazy"
"I'm extremely frustrated
with this"
"You are
harming
me"
"Very disappointed in
Citi"
"I want to speak to a
supervisor
/
manager / Executive Office / Executive / Member of your
Operating
Committee“
"Your manager needs to call me back“
"You embarrassed me when you declined my card"
dissatisfied
ridiculous
sick of
this
disappointed
frustrated
getting
no
where
want a
manager
how can that
be
unacceptable
annoyed
that is
crazy
unbelievable
unhappy
upset
harm meSlide9
Complaint Types & Triggers (Cont.)9
Confidential
A
Complaint
Concern
Has:
Example
Verbatim
Example Triggering
Phrases
An
allegation of unacceptable employee
behavior
Language related
Activity of the employee
Treatment of customer
"
Agent was rude and offensive"
"Used derogatory language"
"Treated me second class"
"They didn't believe me"
"Employee (name) just ignored me"
"The agent hung up on me"
"Lied to me"
ignored
inappropriate treatment
offensive
impolite
didn't listen
harass
liedSlide10
Complaint Types & Triggers (Cont.)10
Confidential
A
Complaint Has
:
Example
Verbatim
Example Triggering
Phrases
Product issue including product design or performance
The customer's issue could indicate a systemic/pervasive issue
Inherent flaw not previously identified
Barriers to termination
Consumer access to information
"I've called four months in a row to get my benefit"
"I got this product/service because it was supposed to..."
"I'm being prevented from cancelling"
"I never got my reward points as promised"
"Your website doesn't work and now I got charged a fee"
"Your system did not process my payment on time"
"This product hasn't helped me at all“
"My card keeps getting declined over and over and I'm sick of it"
multiple times
tried to cancel
doesn’t/won't work
I keep calling
I have tried multiple times
no benefitSlide11
Complaint Types & Triggers (Cont.)11
Confidential
A
Complaint
Concern
Has:
Example
Verbatim
Example Triggering
Phrases
Sales, service or marketing practice
Aggressive sales or tactics
Lack of follow up
System issue
Bait and switch
Misinformation / Misrepresentation
Disclosure of information
Terms/features/teasers
Telemarketing
Cancellations (Dissatisfaction causing cancellation or with Citi cancelling)
Sales:
"I never signed up for (Product or Service)"
"I thought I was signing up for X but instead they gave me Y"
Marketing:
"That advertisement was confusing and didn't understand what I was signing up for"
"I was led to believe something different"
"They said this is the best interest rate anywhere but...."
Servicing:
"You promised you would notify me when...."
"You never did what I requested"
"The employee told me I could do this"
"It doesn't say I need to do that anywhere"
"I have attempted to get this resolved multiple times/four months in a row"
Cancellation:
"I want to cancel because this never works like I thought"
"You should not have cancelled my account"
"I'm cancelling because I don't want to deal with Citi anymore"
they
told me
I wasn’t told
wouldn’t /won’t stop
you didn’t do
I didn’t sign
I didn’t approve
I was never given
I don’t see where it says that
no help
it seemed like
confused (beyond clarification)
you never told meSlide12
Complaint Types & Triggers (Cont.)12
Confidential
A
Complaint Concern
Has:
Example
Verbatim
Example Triggering
Phrases
Problem with handling and resolution (e.g., multiple hand-offs, excessive time lag)
Problem handling
Timeliness
Consumer dissatisfaction with prior handling or resolution
'Problem handling & timeliness of resolution
:
"I have been transferred to four different agents and I'm not getting what I need"
"This is taking longer than what you promised me"
"I spoke to Employee (name) who assured me this was resolved and it is not"
"No one has returned my phone call" or "I was never contacted as promised"
multiple transfers
longer than promised
didn't take care of
was supposed to be resolved
disagree with credit bureau resolution
won't call me backSlide13
Complaint Types & Triggers (Cont.)13
Confidential
A
Complaint Concern
Has:
Example
Verbatim
Example Triggering
Phrases
Disagreement with industry dispute/resolution practices and inappropriate Collection & Recovery activities
Disagreement with result of industry dispute/resolution practices
Failure to comply with collection activity requests or inaccuracies
Disagreement with result of industry dispute/resolution practices:
*Any subsequent contact by the consumer expressing dissatisfaction over the resolution or response to the dispute above will result in a
Complaint such as:
"Its taking you way too long to resolve this billing dispute"
"I disagree with the outcome of my dispute"
Collections & Recovery examples:
Dissatisfaction with the failure to comply with collection activity requests or inaccuracies identified during collection & recovery interactions shall be identified as Complaints.
"I am not your customer and if I don't owe this debt, you are collecting on the wrong person"
"I've told you to stop calling me at work"
"I have already paid my debt, stop calling me"
disagree with dispute outcome
I’m not
the right person
I don’t owe anythingSlide14
Complaint Types & Triggers (Cont.)14
Confidential
A
Complaint Concern
Has:
Example
Verbatim
Example Triggering
Phrases
Dissatisfaction related to the Fraud
process or experience
Dissatisfaction with decline if customer proactively contacted Citi for travel and
or large purchase plans
Authenticated customer expresses dissatisfaction with authentication method or experience
(prior or current)
Dissatisfaction related
to compromise communications or the auto-reissue process/experience
Security
closure process or experience
Method
of communication
Delay
in contact to the customer
Communication
is inaccurate or confusing
Inability for
customer to self-service
“My card was declined and I told you I was traveling to Mexico /making a large dollar charge.”
"I have been declined several times in the last few
months/weeks"
“I am upset that I was required
to call back from my home
phone number when I needed
to use my card earlier.”
“I was never told about my card
being closed for compromise
until I received the new cards.”
“I’m upset that you closed my
account before even sending me a new card.”
“I did not receive a text message upon being declined as
I
was supposed to be.”
“My card was declined and you
didn’t call me until two days
later.”
“I’m upset that I did not receive
an immediate notification upon
being declined.”
I had told you
Unable to use a product
You were supposed to know
Continually declinedSlide15
Complaint Types & Triggers (Cont.)15
Confidential
A
Complaint Concern
Has:
Example
Verbatim
Example Triggering
Phrases
An allegation related specifically to Fair Lending/Fair Banking principles or discrimination
Fairness/Deceptive (UDAAP-Unfair, Deceptive, or Abusive Acts or
Practices
)
Discrimination
Protected classes/adverse treatment
Fair Lending/Discrimination:
"You are discriminating against me"
"This is because I am black / white / Asian / old / young / disabled / minority / income / religion, etc."
"You are treating me this way because I am (protected class)“
Fair Banking (UDAAP/TCF-Treating
Customers Fairly
):
"This is unfair, these fees are too high"
"I was misled to believe"
"What you're doing to me is completely unfair"
"Why am I being treated this way"
"I was told one thing but you did another"
"I was never told"
"You are exploiting your capabilities"
"There's no way I could have avoided this"
"I paid for this benefit, and you're not letting me use it"
"Taking advantage of me"
Examples of Fair Lending/Discrimination:
discriminated against
treated differently
predatory
not treated equally
Examples of Fair Banking (UDAAP/TCF):
unfair
abusive
deceptive
confusing / don't understand (beyond clarification)
mislead
frustrated
mistreated
making it impossible
deceiving
this is so difficultSlide16
Complaint Types & Triggers (Cont.)16
Confidential
A
Complaint Concern
Has:
Example
Verbatim
Example Triggering
Phrases
An allegation of a violation of law or regulatory requirement
Specific law/regulatory citation
Complaints that require escalation to Level 3:
"You overcharged me according to RESPA"
"You violated my right to privacy"
"According to FDCPA, you can't call me after 9pm"
"Your branch does not accommodate people with disabilities"
"I am in the military and have not been receiving the correct interest rate on my loan as previously promised"
"I have asked you to stop contacting me with solicitations or marketing information but you keep calling/mailing/emailing me"
Complaints/Concerns which do not require escalation to Level 3:
"that's against the law" (without mention of an unlawful act)
"you are in violation of my rights" (without mention of the violation)
"I received collection calls on Sunday"
any specific regulation or law
person affected by a specific regulation (disabled, military, etc.)
violated (and indicating the law)
against the law (and indicating the unlawful act)Slide17
What is a complaint (cont.)17
Customer Complaints
Customer “Complaints” are written or verbal submissions by a customer that express dissatisfaction with, or communicate suspicion of wrongful conduct by a practice or act of the Service Provider or Citi regarding the customer’s personal experience with the financial product or service.
The collector should be versed in listening to the customer/consumer in order to pick up key words, phrases, and language to assist in identifying dissatisfaction, and to ensure satisfaction in the resolution
. Slide18
Complaint Types & Triggers (Cont.)18
Confidential
Debt Management
Complaints
Citi must be notified of all complaints received by the Service Provider from a customer, attorney, third party, or any other party regarding debt management companies. Whether the communication is verbal or written, Citi wants to be made aware of any allegations that allege violations of federal, state, and/or local laws. This is to control and identify debt management companies in the industry that are not adhering to debt management legislation
.Slide19
What is NOT a Complaint19
Service Requests, Inquiries
&
Feedback
Not all consumer interactions where there is a request for action from the consumer are considered
Complaints.
Specifically, the following categories of interaction are not
Complaints.
The following slides will contain examples of non-complaint items.
ConfidentialSlide20
Inquiries20
Inquiries
are requests for information from the consumer that do not contain an expression of dissatisfaction.
Consumer
inquiries may include questions regarding existing accounts, and general requests for information
.
The request does not have an expression of dissatisfaction
.
ConfidentialSlide21
Service Requests21
Service
Requests
are requests to perform account maintenance, execute a transaction, or perform other routine servicing requests of a similar nature, provided that the request does not have an expression of dissatisfaction. An initial contact or notification regarding a dispute that follows industry practices and resolution processes prescribed by consumer protection laws is defined as a Service
Request.
Credit
Bureau reporting requests or disputes
Initial
allegations of fraud, account takeover or identity theft
Merchant
billing disputes
Validation
of
Debt
if it is an initial request
Collections
– An expression of dissatisfaction because a consumer is appropriately in Collections is not considered a
Complaint
Subsequent
contact by the consumer expressing dissatisfaction over the handling, resolution, or response to the disputes will be treated as a
Complaint.
ConfidentialSlide22
Feedback22
Feedback
is information about a product or service provided by or on behalf of a consumer used as a basis for improvement. The customer/consumer presents the information for improvement or in the form of a suggestion to change existing activities without an expression of dissatisfaction
.
ConfidentialSlide23
A Complaint is not:23
Confidential
A Complaint is not:
Example
Verbatim
Routine service requests
Account maintenance
Transaction processing
Consumer assistance
Card declines
"I want to open a new account"
"I'd like to execute a transaction"
"I want to make/stop payment"
"I want a replacement card"
"Can you resend my statement?"
"Please update my contact information?"
"Can you lower my interest rate?"
"This interest rate is higher than my friend's"
"These fees should be refunded because I have been a good customer"
"My card doesn't work or was declined"Slide24
A Complaint is not: (Cont.)24
Confidential
A Complaint
is not:
Example
Verbatim
Question (inquiry) or asking for clarity
Comprehension
Seeking clarity
"Can you explain to me…"
"When are you open?"
"Why didn’t …. happen?"
“Can you help me?"
"Why were these fees charged?"
"I thought I was supposed to have zero percent interest rate"
"Can you lower my interest rate?"
"Why was my credit line reduced?"
"Will you notify me when that occurs?"
"What day is my payment due?"
"What is my balance?"
"Why has my loan not closed yet?"Slide25
A Complaint is not: (Cont.)25
Confidential
A Complaint is not:
Example
Verbatim
Feedback
Suggestions
Opportunities
Consumer opinions
Commentary regarding our value proposition or lack of competitive terms
"Can I suggest…"
"I wish you had…"
"These fees are not competitive"
"I would like the branch to be open later"
"The call center should be open on Saturday"
"This offer to sign up is not good enough“
"It would be nice if your product did…."Slide26
A Complaint is not: (Cont.)26
Confidential
A Complaint is not:
Example
Verbatim
Cancellations
Not caused by dissatisfaction (i.e. life events, personal credit decisions)
"I just don't use the card anymore"
"I have too many credit cards"
"I've never used this product"
"I can't afford this anymore"
"I want to eliminate this payment"Slide27
A Complaint is not: (Cont.)27
Confidential
A Complaint is not:
Example
Verbatim
Current Events
Natural disaster
Industry wide event
National advertisement
"We were affected by Hurricane Katrina and want to defer our payment"
"I saw the ad on TV and want my rate lowered"
"My card was compromised in the Home Depot breach and I need to block the account"Slide28
A Complaint is not: (Cont.)28
Confidential
A Complaint is not:
Example
Verbatim
Request/inquiry that follows industry dispute/resolution practices and Collection & Recovery activities
Credit Bureau Reporting related (i.e. Request to amend or dispute)
Billing or Transaction disputes
Request to open fraud investigation
Unauthorized or Incorrect Electronic Funds Transfers
QWR, NOE, and RFI typically related to mortgage servicing
Collection/recovery activity
Industry dispute/resolution practices:
"My credit bureau report is inaccurate"
"My account is not delinquent"
"I've been current on paying my account but my CBR shows it as delinquent"
"I did not make these transactions"
"Costco charged me twice"
"My card was stolen"
"I think someone has my account information"
"I'd like to file a claim"
"I don't want any more calls (Cease & Desist)" – can include collections related calls
Collections & Recovery Examples:
'If a Consumer expresses dissatisfaction because they are appropriately in collection or recovery, it should not be considered a complaint.
"I don't want to pay this debt"Slide29
A Complaint is not: (Cont.)29
Confidential
A Complaint is not:
Example
Verbatim
Fraud Communications that follows industry practices and activities
General dissatisfaction associated with POS interruption
Dissatisfaction with need to complete additional verification (per policy)
Inability to pass verification
Need to close account due to high risk
Multiple compromise reissues
Inability to release merchant name associated with breach
Required to close account
Allowing Fraud to occur
No Contact prior to decline
"My card was declined:
"I shouldn’t have to verify with any more information.”
"I do not want to close my account; I have too many auto billers tied to this account.”
"This is the second security close I have had to take this year due to compromise; this is very inconvenient.”
"I am upset that you cannot tell me which merchant my card was compromised.”
" I don’t want you to close my account even though
it was compromised"
"You should have caught these fraud transactions sooner.”
"You should have contacted me first before declining me.”Slide30
Escalation and Documentation30
ConfidentialSlide31
Escalation Levels 1-2-331
Citi organizes all Complaints into one of three Escalation levelsLevel 1 = Agent/Collector ResolutionLevel 2 = Manager ResolutionLevel 3 = Upper management or Compliance Attorney or VBCS Resolution Slide32
Level 132
Level 1 Complaint - Collector is able to resolve the complaint with customer while the customer is still on the phone with the collector. If Collector
is unable to resolve it must be escalated to Level
2
The Collector is required to Escalate the following complaints after one opportunity to de-escalate.
If
the customer/consumer requests to speak to a manager and after one attempt to
de-escalate (the Collector asks once more if the collector can solve the issue) still wants to speak to a manager or supervisor If the customer/consumer requests to be escalated directly to an Attorney or Level 3 function, with one opportunity to de-escalate by offering to personally assist or transfer to Level 2.Slide33
Level 133The collector may attempt to resolve a Complaint/Concern before escalation if:
The customer/consumer is amenable to the employee attempting to research and resolve; if not, the collector will escalate as requiredAfter resolution is provided, the collector confirms with the customer/consumer that s/he has effectively addressed the customer’s/consumer’s Complaint/Concern and the customer/consumer no longer requests escalation
.
Ask “Have I Resolved your Concern or Complaint ?”
This should be titled as a Level 1 Resolution in JST.
Examples: CM states never gets ahold of anyone when they called but finally got through and collector helped them. CM states why wont you settle for x
bcs
other creditors will but at end of call the CM settles account. Slide34
Level 2-334
If the Collector could not resolve the complaint it is then escalated and should be noted on JST as Escalated to level 2 or 3. Level 2- Manager Resolution (collection manager or lead)TMLG must send an Acknowledgment letter for all complaint not resolved at the initial point of contact
All
Level 2 Escalations MUST be resolved within 3
days.
Level 3- Attorney or Citi Resolution.
Include Direct Escalations, Regulatory channels, Filed litigation or those that could not be Resolved in level 2.
All level 3 Escalations must be resolved within 15 days.Slide35
Direct Escalation35
All Collectors are required to escalate the complaint/Concern directly to level 3 with no De-escalation attempts allowed if:The Contact relates to or already is in Complaint or dispute status .
Communications is from regulators, or is from a Local, State, or Federal Agencies, Attorney General, State Bar, or Direct Suit against TMLG.
Commination was directed at or to an executive, board, president, operating committee, level 3 attorney, or specifically acts to speak to Harry Moore
Communication is from the Better Business Bureau
Communication From a Special interest or Consumer advocacy group as CFPB.
Complaints/Concerns that directly allege a violation of Specific Law, Regulation threat of suit Regulatory Complaint, violation of FDCPA.
All Direct Escalations should be Noted on JST as “Direct Escalation to Level 3”.
All Non-Direct Escalations should be attempted to be Resolved at the level 1 Escalation Stage. Slide36
Complaint Documentation36Identify
Escalation Level 1 or Note as Escalated to level 2 or Note as Direct Escalation to level 3If Escalation to level 2 or 3 is Required
Collector notes must contain sufficient information regarding the complaint and attempts to resolve or specific request of consumer. This information is needed for the Acknowledgment letter which must include
Contact Details-Brief description of the complaint and Concern
Estimated timeframe for follow-up or resolution
Way to contact Service provider regarding the complaint/ConcernSlide37
Complaint Documentation37
Document
all details of the complaint including specific statements made by the consumer in JST by using
TMLG Intranet
.
Reference the work instructions on
TMLG Intranet
on how document and escalate a complaint—see next slide.
ConfidentialSlide38
Complaint Documentation (Cont.)38
All of this information is located in the
Support
section of the Intranet under the
Complaints
—see below.
ConfidentialSlide39
Questions?39
Confidential