Learn what it takes to align consumer expectations, CFPB expectations and your business. SilverCloud, Inc. will take you through the evolving consumer behaviors, the current regulatory landscape and where you want to be to stay off the radar. Learn what your financial institution needs to be doing to have happier consumers, drive more revenue, lower costs, and stay compliant.

1. Staying off the CFPB radar
Aligning Consumer Expectations,
CFPB Expectations,
and Your Business
Scott Cornell, CEO

2. Consumers and the CFPB
Source: Beyond the Arc, Inc. 2013
Social Media
Comments
Complaints
Filed at CFPB
$214M Fine
You want this!

3. Different perspectives
To a Credit Union:
A consumer is a person in need of a loan
To the CFPB:
A consumer is a victim in need of help

4. First to the Credit Union… then social media….
o 51% of those who got a response to their complaint had a positive reaction
o 22% then posted a positive comment
But even this is changing…..
Where do consumers go to complain?
Poor Service
26%
Complain
on Social
Media
Ignored Complaints
79% felt
complaint
was ignored

5. At the CFPB it’s all about complaints!
“Complaints provide indications of potential
regulatory violations, including unfair,
deceptive, or abusive acts or practices”
“How the entity handles complaints is also a
key element in evaluating its compliance”
- The CFPB
“Consumers just don’t think about going to the government for help”
– Internal CFPB survey

7. Have you looked at this process?
It’s a CFPB complaint menu!

8. Business is good!
300,000 complaints filed so far.
0
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
Nov-11
Jan-12
Mar-12
May-12
Jul-12
Sep-12
Nov-12
Jan-13
Mar-13
May-13
Jul-13
Sep-13
Nov-13
Jan-14
Mar-14
May-14
Complaints Filed Per Month at the CFPB

9. If that weren’t enough…
here’s more places to complain!
1. CFPB http://www.consumerfinance.gov/
2. OCC http://www.helpwithmybank.gov/index.html
3. FDIC http://www.fdic.gov/consumers/questions/consumer/complaint.html
4. NCUA http://www.mycreditunion.gov/help/Pages/Submit-Your-Complaint.aspx
5. FED http://federalreserveconsumerhelp.gov/?District=1
6. SEC https://tts.sec.gov/oiea/Complaint.html
7. FTC http://www.ftc.gov/about-ftc/bureaus-offices/bureau-consumer-protection
8. State of NH http://www.nh.gov/banking/consumer-assistance/complaint.htm
9. State of MA http://www.mass.gov/ocabr/government/oca-agencies/file-a-complaint.html
10. State of VT http://www.dfr.vermont.gov/banking/consumer-resources/file-complaint

10. A consumer’s view of you
I need
info!
Bank Staff
• Call Center
• Front Line
• Management
Bank E-Channels
• Website
• Online Banking
• Mobile
Bank Venders / Partners /
Brokers / Processors
• Call Center
• Website
Social Media
Gov’t Agency
• Call Center
• Website & Complaints
I need to
communicate!

11. What consumers the CFPB wants…
Comparing expectations…
What consumers want…
1. Be professional
2. Be clear
3. Be fast
4. Be everywhere

12. Expectation #1: Be professional
Consumers are expecting:
• For you to know us
• For timely responses
• To be treated fairly
The CFPB is expecting:
• For you to centralize consumer complaint and response management
• For you to develop consumer analytics and trend analysis

13. Expectation #1: Be professional
Consumers say…
Top 2 reasons we stick with you
1. Friendly employees 2. Ease of finding information
But 78% of us will abandon you due to poor member service
And we are 2X as likely to talk about bad member service

14. Expectation #1: Be professional
The CFPB says…
Your consumer complaint management program should include:
 Channels to receive consumer complaints and inquiries
 Proper and timely resolution of all complaints
 Recording, categorization, and analysis of complaints and inquiries
– CFPB Supervisory Highlights, Summer 2013
Reiterated in:
• CFPB Supervisory Highlights, Spring 2014
• CFPB Bulletin, Responsible Business Conduct
• CFPB Supervision and Examination Manual
• CFPB Dodd-Frank Mortgage Rules Readiness Guide

15. Expectation #2: Be Clear
Consumers are expecting:
• To easily find and understand information on product and policy
• Consistent answers from employees and all other electronic
channels
The CFPB is expecting:
• Non-deceptive, clear, easy-to-read collateral
• Well trained employees with consistent information
• You to demonstrate effort in member education
• Consistency of service and information

16. Expectation #2: Be Clear
Consumers say…
• 52%make it easy for us to ask questions and access info
• 36% improve your search and online experience
The CFPB says…
Don’t put out deceptive ads… And be clear (even in Spanish)
$40M – AMEX was fined, in part for “not providing Spanish language scripts to
CSR’s … and all written material provided to consumers…”
$225M – GE Capital was fined for “not extending [offers] to customers who
indicated that they preferred to communicate in Spanish”
¡Ayuda!

17. Expectation #3: Be fast
Consumers are expecting:
• We want it yesterday
The CFPB is expecting:
• You to deliver responses promptly
• You to automate as much as possible

18. Expectation #3: Be fast
25% will abandon your website if we cannot easily find
what we are looking for.
56% said you were too slow to resolve our issues.
75% say valuing our time is the most important thing you
can do.
Consumers say…

19. 0
2000
4000
6000
8000
10000
12000
14000
16000
18000
20000
Time of Day: Consumer Inquires
54%46%
Source: SilverCloud Inc.
Expectation #3: Be fast

20. Expectation #4: Be everywhere
Consumers are expecting:
• To get full service online
• To be Mobile
• For you to be in social media
• To communicate with employees when we need them
• To be talking to you, not your vendors
The CFPB is expecting:
• Provide consistent service and information across all channels
• Enable compliant and error submission across all channels
• Integrate information and complaint process with your vendors

21. Expectation #4: Be everywhere
Consumers say…
72% of us go online first to resolve a problem – Forbes
48% of us with smart phones use mobile banking - The Federal Reserve
26% of us will post negatively on Facebook if we get poor service

22. Expectation #4: Be everywhere
The CFPB says…
3rd PARTIES: “The fact that a [FI] enters into a business relationship with a service provider
does not absolve the [FI] of responsibility for complying … and it may be held legally
responsible for violations by the third party.”
– CFPB Supervisory Highlights, Spring 2014
FACEBOOK: “...a [FI] may establish one or more specified channels that customers can use for
submitting communications directly to the institution.”
– FFIEC Final Guidance Notice, Social Media
MOBILE: “[With mobile] consumers may find it harder to access customer service when
there is an error or something goes wrong. The Bureau is seeking information on what types
of customer service or technical assistance are available to consumers when they use mobile
products.”
- CFPB Inquiry Into Mobile Financial Services

23. Expectation #4: Be everywhere
A little more from the CFPB Supervision and Examination Manual
Channels for Consumers to Contact the Entity.
• Identify all channels the entity makes available for consumers to
submit inquiries, complaints, and disputes…
• Assess the effectiveness of each of these channels

24. Offense is the best defense with the CFPB
Stay off the radar!
1. Reduce complaints in the first place
2. Capture as many as you can yourself – don’t let your
customers go elsewhere with them!
3. Centralize all complaint channels
• For complaint, inquiry and feedback management
• For analysis and for auditing
4. Technology is your ally with the CFPB.

25. What is that Technology?
Technology that enables consumer
 Information Accuracy and Consistency
– All info, all places
 Engagement
– Consistent experience across all channels
 Complaint and Response Management
– Capture, track, respond
 Analytics
– Trends in products, issues and desires

26. Specifically, technology that:
1. Facilitates outbound knowledge
• Automated information access
• On every channel
• Make it comprehensive, engaging and useful
2. Facilitates inbound communication and responses
• Inquires, feedback and problems
• On every channel
• Manage and track all responses
3. Does analysis!
• Find trends for compliance improvement
• Find trends for revenue improvement!

27. Big benefits of aligning expectations
1. Increased Compliance - Stay off the radar!
• Better meet CFPB conduct and service expectations
2. Increased revenue
• Better consumer loyalty, education, service. Higher product and
self-service adoption. Higher loan growth
2008 2009 2010 2011 2012 2013
SilverCloud Clients
Non-clients
Average
Loan
Growth
1.08
1.06
1.04
1.02
1.00
0.98

28. Big benefits of aligning expectations
1. Increased Compliance - Stay off the radar!
• Better meet CFPB conduct and service expectations
2. Increased revenue
• Better consumer loyalty, education, service. Higher product and
self-service adoption. Higher loan growth
3. Increased competitiveness
• Better meet consumer expectations
• 95% auto answer, lower abandonment, omni-channel experience
4. Decreased costs
• In call center (20%)
• In reporting and auditing time
• In enforcement actions
5. Greater Business Analytics

29. So what would a solution look like?

30. Getting info to consumers
Bank Staff Bank E-Channels Social Media
consumers
Employee
Knowledgebase
Consumer
Knowledgebase
 Answers
 Product info
 Calls to action
 Customer Service

31. Bank Staff Bank E-Channels Social Media
consumers
Response Management
 Inquiries
 Problems
 Feedback
Enabling Complaints and Inquires

32. With consumer self service
• 24/7 service and engagement
• Always deliver instant, consistent, accurate answers

33. Across every channel

34. Thousands of answers with thousands
of CALLS TO ACTION
Promote and advertise product and
drive more business.
And driving engagement

35. While reducing and managing complaints
 Capture all consumer inquires
• From any channel (Website, Mobile, Facebook, Call center)
• From 3rd Parties
 Manage
• Categorize and manage complaints
• Escalate & respond to complaints
 Track
• Record submitted complaints
• Record notes, escalations and all service rep responses
 Report & Analyze
• Audit and report responses and turnaround times
• Analyze for trends

36. And generating consumer analytics

37. So stay off the CFPB radar!
1. Reduce Complaints first
…then manage any complaints that come in properly!
2. Keep that Consumer Perspective
“Expectations: Be professional, clear, fast, everywhere.”
• Provide easy access to information on every channel
• Improve complaint and inquiry submission on every channel
3. Technology is your friend with the CFPB
• Always have analytics and reporting on complaints
• Centralize content and complaint processing

38. Let’s Connect…
Scott Cornell
 978-590-1703
 scott@silvercloudinc.com
 www.silvercloudinc.com