Complaint Management Policy
Intake, tracking, investigation, and resolution of complaints from customers, consumers, and the sponsor bank.
| Field | Value |
|---|---|
| Document | Complaint Management Policy |
| Version | 1.0 |
| Owner | Compliance Officer |
| Review | Annual, or on material program change |
Authorities
This policy implements, within the sponsor bank's program:
- CFPB Supervision and Examination Manual, Compliance Management Review, which treats consumer complaint response as one of the four components of a compliance management system.
- Dodd-Frank Act sections 1031 and 1036, the prohibition on unfair, deceptive, or abusive acts or practices, which complaint trends are used to detect.
- Regulation E, 12 CFR 1005.11, error resolution for electronic fund transfers, where a complaint alleges a transfer error.
- The sponsor bank's program agreement, which sets the notice and reporting obligations to the bank.
1. Purpose and Scope
This policy describes how the Company intakes, tracks, investigates, resolves, and reports complaints related to its program. Complaint handling is one of the four components of the Company's Compliance Management System, alongside policies, training, and monitoring and testing. A working complaints program is the mechanism that catches problems the other three components miss: it surfaces real customer experience, identifies emerging risks, and creates accountability for resolution.
This policy applies to all employees, contractors, and service providers who may receive a complaint or whose work could generate one. It covers complaints from any source: direct customers, consumers who transact through a customer's platform, the sponsor bank, regulators, and internal sources.
2. Definitions and Complaint Categories
2.1 General Definitions
| Term | Definition |
|---|---|
| Complaint | An expression of dissatisfaction, oral or written, about a product, service, decision, or experience attributable in whole or in part to the Company or the sponsor bank program. |
| Inquiry | A request for information, clarification, or routine assistance that does not allege a problem. |
| Feedback | A suggestion or general observation provided voluntarily that does not allege a problem. |
| Escalated complaint | A complaint that meets one or more escalation triggers under the program agreement and this policy. |
| Complainant | The party submitting the complaint. |
2.2 Program-Agreement Complaint Categories
The Company tracks the following categories as defined in its program agreement with the sponsor bank:
- Regulatory criticism. An adverse regulatory communication relating to the program, including critical findings, enforcement actions, consent orders, or adverse notices. The Company notifies the sponsor bank in writing within 5 business days of receipt, sooner if the matter is material, and shares the relevant written documentation or a detailed written summary of any oral communication. The sponsor bank has final approval over any response to a regulator.
- Customer complaint. A complaint from a direct customer relating to the program, written or otherwise. Immaterial complaints and complaints related solely to technical difficulties are excluded from tracking. The Company addresses all other customer complaints and uses commercially reasonable efforts to resolve them.
- Executive complaint. Material criticism received by senior management that threatens litigation, regulatory action, or material reputational damage. The Company notifies the sponsor bank in writing within 2 business days of receipt, including details of the matter and the status of the investigation, and proposes a response subject to sponsor bank review and approval.
- Consumer-side complaint. A complaint from a consumer using a customer's platform, passed through or escalated by that customer. It is acknowledged and coordinated with the customer; primary resolution responsibility rests with the customer under its own consumer program. The Company investigates any operational or data-integrity role of its own.
3. Complaint Sources and Pathways
Complaint pathways differ by source and require different intake and routing treatment.
| Source | Typical subject matter | Intake treatment |
|---|---|---|
| Direct customer | Account access, transaction holds, billing or fee disputes, settlement timing, vendor performance | Direct intake by Customer Success or the Compliance Officer; logged as a customer complaint; assigned for investigation |
| Consumer via customer | Consumer disputes escalated by a customer for coordination or data in context | Logged with the customer identifier; investigated in coordination with the customer; primary resolution sits with the customer |
| Regulator | Regulatory inquiry or finding related to the program | Logged as regulatory criticism; sponsor bank notified within 5 business days; sponsor bank approves the response |
| Executive | Material threat of litigation, regulatory action, or reputational harm received by senior management | Logged as an executive complaint; sponsor bank notified within 2 business days; proposed response subject to sponsor bank approval |
| Sponsor bank | Complaints the sponsor bank receives about the program | Logged on receipt; investigated within program-agreement timelines; resolution communicated to the sponsor bank |
| Internal (employee) | Employee concerns about compliance, fraud, or unfair practices | Treated under whistleblower protections; logged confidentially; investigated by the Compliance Officer or a designated alternate |
4. Intake Channels
The Company maintains the following channels for receiving complaints. Each channel is monitored and feeds the centralized complaint log described in Section 5.
- Email. A dedicated complaints mailbox monitored daily by Customer Success and the Compliance Officer.
- Customer Success. Any complaint received through support, account management, or onboarding is forwarded to the Compliance Officer for logging within one business day.
- Sponsor bank referrals. Complaints routed from the sponsor bank are logged on receipt and tracked under the program agreement.
- Regulatory referrals. Any complaint or inquiry from a regulator is routed to the Compliance Officer immediately and treated as regulatory criticism.
- Public channels. Customer Success and the Compliance Officer monitor review sites, social media, industry forums, and news at least weekly. Substantive complaints surfaced through public channels are logged.
- Internal reporting. Employees may submit complaints, including whistleblower-style concerns, directly to the Compliance Officer or, where the concern relates to the Compliance Officer, directly to the CEO.
Customer-facing onboarding documentation and the Company website include clear instructions on how to submit a complaint, the channels available, and the expected timeline for acknowledgment and resolution.
5. Centralized Complaint Tracking
All complaints are logged in a centralized complaint tracking system under the Compliance Officer's control. Each complaint record captures, at a minimum: a unique complaint id; date and time received; intake channel; source category; program-agreement category where applicable; complainant identification; associated customer, if any; subject matter and product or service category; initial severity classification; assigned investigator; acknowledgment date and method; investigation notes and supporting documentation; root cause where applicable; resolution and date closed; the communication record with the complainant; escalation history; and the linked issue id under the Issues Management Policy where the complaint surfaces a control gap.
The complaint log is restricted to authorized personnel. Read access is available to the Compliance Officer, the CEO, designated Customer Success staff handling intake, and the sponsor bank's compliance team on request.
6. Classification and Severity
Each complaint is classified at intake by the Compliance Officer or a designated reviewer. Classification drives investigation priority, escalation, and reporting.
| Severity | Definition | Acknowledgment and initial response |
|---|---|---|
| Critical | Allegations involving a regulatory violation, suspected fraud, a sanctions or AML concern, a data privacy or security incident, discrimination, or any matter likely to result in regulatory action or material harm | Acknowledged within 1 business day; Compliance Officer engaged immediately; CEO and sponsor bank notified |
| High | A significant complaint about service failure or unfair treatment that could escalate if unaddressed; an executive complaint relating to a litigation or regulatory threat | Acknowledged within 2 business days; Compliance Officer assigned as investigator |
| Moderate | An individual complaint with limited regulatory exposure; a service or process issue that warrants investigation | Acknowledged within 3 business days; assigned to Customer Success with Compliance Officer oversight |
| Low | A routine concern or minor inconvenience that can be handled within the standard customer-service workflow without compliance escalation | Acknowledged within 5 business days; handled by Customer Success with logging only |
Severity may be adjusted during investigation as new information emerges. Adjustments are documented in the complaint record with the rationale.
7. Investigation and Resolution
The assigned investigator reviews the facts, gathers the required documentation (account records, transaction history, prior interactions), and determines whether the complaint is substantiated. Investigations are fact-based and documented; conclusions are supported by reference to specific records or system evidence. For direct customer complaints the investigator may communicate with the customer directly. For consumer-level complaints the investigator coordinates with the customer, and consumer-facing communication remains with the customer under its own program.
Resolution outcomes are documented and may include: no action required; a service or fee adjustment; a process correction, followed by a control update under the Issues Management Policy; account-level remediation such as a refund, account restoration, or transaction reversal; escalation to the sponsor bank; escalation to outside counsel where legal exposure is identified; or referral for law-enforcement coordination where potential criminal conduct is identified.
The complainant receives a written response describing the outcome of the investigation, the resolution if any, and, where appropriate, information about further escalation rights.
8. Response Timelines
| Severity | Acknowledgment | Investigation target | Final response to complainant |
|---|---|---|---|
| Critical | Within 1 business day | Within 5 business days of intake | Within 10 business days; status updates every 5 business days if longer |
| High | Within 2 business days | Within 10 business days of intake | Within 20 business days |
| Moderate | Within 3 business days | Within 15 business days of intake | Within 30 business days |
| Low | Within 5 business days | Within 30 business days of intake | Within 45 business days |
If a target cannot be met, the investigator documents the reason and provides the complainant with a status update. For regulatory criticism and executive complaints, the sponsor bank is updated on investigation status and any revised timeline.
9. Root Cause and Trend Analysis
The Compliance Officer reviews the complaint log monthly for trends, recurring issues, and emerging risk areas. Trend analysis covers complaint volume by category, volume by customer, severity mix, average resolution time, and any spikes or shifts from prior periods. Where trend analysis indicates a recurring or systemic issue, the Compliance Officer initiates a root cause analysis under the Issues Management Policy, identifying whether the underlying cause lies in policy, training, system controls, vendor performance, or customer behavior, and recommending remediation. A single complaint classified Critical or High also triggers a root cause analysis regardless of trend volume, because individual high-severity matters often expose gaps that affect future activity.
10. Sponsor Bank Coordination and Reporting
The Company and the sponsor bank share a coordinated approach to complaints affecting the program.
10.1 Regulatory Criticism
The Company notifies the sponsor bank in writing within 5 business days of receiving any adverse regulatory communication. The notification includes the relevant portions of written documentation or a detailed summary of an oral communication. The sponsor bank has final approval over any response to the regulator.
10.2 Executive Complaints
The Company notifies the sponsor bank in writing within 2 business days of receiving an executive complaint. The notification includes the details of the matter and the investigation status. The Company proposes a response, subject to sponsor bank review and approval; the sponsor bank may require changes to the proposed response.
10.3 Monthly Complaint Reporting
Each month the Company provides the sponsor bank with a complaints summary in the form the sponsor bank specifies, including the volume of customer complaints, regulatory criticisms, and executive complaints; trend and root cause analyses; material exceptions and aging items; and an attestation by the Compliance Officer.
10.4 Regulatory Examination Support
The sponsor bank leads preparation and response to regulatory examination findings and inquiries. The Company provides complete documents and data related to complaints and investigations on request, and personnel access for interviews and information requests. Company personnel participate in examination meetings only with sponsor bank approval and under its direction. If a regulator contacts the Company directly, the Company immediately notifies the sponsor bank and does not respond substantively without its direction.
10.5 Regulatory Communications
The sponsor bank owns all regulatory communications relating to the program. All written submissions to regulators are prepared or approved by the sponsor bank, and the Company does not communicate directly with regulators without sponsor bank coordination.
11. Regulator-Sourced Complaints and Internal Whistleblower Concerns
Complaints originating from a regulator are treated as Critical regulatory criticism and handled in coordination with outside counsel and the sponsor bank. The Compliance Officer is the primary point of contact; no employee responds to a regulator-routed complaint without consulting the Compliance Officer.
Internal complaints raised by employees, including whistleblower-style concerns about the Company's own conduct or another employee's conduct, are handled confidentially, and the complainant is protected from retaliation. The investigation is conducted by the Compliance Officer or, if the matter relates to the Compliance Officer or senior leadership, by an alternate designated by the CEO with input from outside counsel. Whistleblower complaints alleging potential criminal conduct are escalated to outside counsel and to the sponsor bank.
12. Recordkeeping
All complaint records, including intake details, investigation files, resolution communications, root cause analyses, and trend analyses, are retained for at least seven years from the date of complaint closure. Records subject to a legal hold are retained until the hold is released. Storage and access controls follow the Recordkeeping Policy. Complaint records of every category are retained and made available to the sponsor bank on request.
13. Training and Awareness
All employees and contractors who may interact with customers, consumers, the sponsor bank, or regulators are trained on how to recognize a complaint as distinct from an inquiry or feedback; how to escalate a complaint to the Compliance Officer for logging; the first-contact rule of not committing to a resolution or admission before the matter is logged and reviewed; confidentiality requirements, particularly for regulator-routed complaints and whistleblower concerns; where to direct consumers who contact the Company directly; and the program-agreement complaint categories and escalation triggers. Training is delivered within 30 days of hire, with annual refreshers, as part of the Compliance Training Program.
14. Program Effectiveness and Self-Assessment
The Compliance Officer reviews the effectiveness of this policy at least annually as part of the Compliance Management System annual review. Effectiveness indicators include whether complaint volumes are consistent with program scale; whether resolution timelines are met across severity tiers; whether root cause analyses are converting trends into program improvements; whether the sponsor bank has raised concerns about the completeness or timeliness of complaint reporting; and whether regulator-routed complaints have surfaced gaps the internal process should have caught earlier. Findings are documented and incorporated into updates to this policy and the broader Compliance Management System.
15. Effective Date and Approval
This policy is approved by the Compliance Officer, reviewed annually or on any material program change, distributed to all employees and applicable contractors, and provided to the sponsor bank's compliance team.