Complaint Oversight Committee Charter
[Company Name / Logo]
1. Purpose
The Complaint Oversight Committee ("Committee") is established to oversee the management and resolution of consumer complaints and regulatory inquiries, including those from the Consumer Financial Protection Bureau (CFPB), state regulators, and other oversight bodies. The Committee ensures that all complaints are handled in compliance with applicable federal and state laws, regulations, and internal policies, while promoting a culture of responsiveness, accountability, and consumer protection.
2. Scope
The Committee's responsibilities include reviewing, assessing, and ensuring the appropriate and timely resolution of:
Consumer complaints submitted directly to [Mortgage Lender/Servicer Name], as well as those received through regulators such as the CFPB, state regulatory agencies, or other oversight bodies.
Regulatory inquiries and investigations arising from complaints or other matters of concern raised by federal and state regulators, with particular emphasis on compliance with applicable mortgage lending and servicing laws.
Trends and systemic issues identified in complaint data to ensure proactive risk management and regulatory compliance.
3. Authority
The Committee has the authority to:
Review and oversee the complaint-handling process across all business units to ensure compliance with applicable laws, regulations, and industry standards.
Establish and amend policies and procedures for the intake, tracking, investigation, and resolution of consumer complaints.
Direct corrective actions to address deficiencies in the complaint management process, including those related to customer service, compliance, and operational functions.
Escalate unresolved or significant issues to senior management or the Board of Directors when necessary.
4. Responsibilities
The Committee is responsible for:
Review and Oversight of Consumer Complaints
a. Periodic Review: Conduct regular reviews of consumer complaints received through internal channels and regulatory bodies such as the CFPB and state agencies.
b. Timeliness: Ensure that all complaints are acknowledged, investigated, and resolved within established timeframes, as required by internal policies and applicable regulations.
c. Consumer Communication: Oversee the consistency and transparency of communication with consumers regarding the status and resolution of their complaints.Regulatory Inquiries
a. Handling Regulatory Inquiries: Ensure that all regulatory inquiries, especially those from the CFPB and state agencies, are handled appropriately, timely, and in a manner that maintains compliance with relevant regulatory requirements.
b. Escalation Protocol: Establish protocols for escalating high-risk or sensitive complaints and inquiries to senior leadership or legal counsel, when necessary, to minimize potential compliance risks.
c. Cooperation with Regulators: Facilitate appropriate cooperation with regulators during investigations or audits related to consumer complaints or regulatory inquiries.Complaint Data Monitoring and Reporting
a. Trend Analysis: Review complaint data to identify recurring issues, trends, or areas of systemic concern that may require policy changes, process improvements, or regulatory action.
b. Compliance Reporting: Ensure regular reporting of complaint statistics, trends, and any significant issues to senior management, the Board of Directors, and regulatory bodies as appropriate.
c. Root Cause Analysis: Ensure that root cause analyses are performed on significant or recurring complaints, and that corrective actions are taken to prevent recurrence.Policy and Process Improvement
a. Policy Review: Regularly review and update complaint-handling policies and procedures to align with evolving legal and regulatory requirements, industry best practices, and internal risk management protocols.
b. Process Efficiency: Continuously evaluate the efficiency and effectiveness of complaint management processes, recommending and implementing improvements where necessary to optimize consumer satisfaction and compliance outcomes.Training and Awareness
a. Staff Training: Ensure that relevant staff receive regular training on complaint handling procedures, regulatory requirements, and best practices.
b. Culture of Compliance: Promote a company-wide culture of compliance, responsiveness, and accountability, where all employees understand the importance of timely and effective complaint resolution.
5. Membership and Structure
Composition
The Committee will be composed of senior-level representatives from key departments, including:Compliance
Legal
Operations
Risk Management
Customer Service
Internal Audit (if applicable)
The Committee will be chaired by the Chief Compliance Officer (or designee) and will report directly to the Chief Executive Officer (CEO) and the Board of Directors as necessary.
Meetings
a. Frequency: The Committee will meet at least quarterly, with additional meetings scheduled as needed based on complaint volume, regulatory inquiries, or significant emerging issues.
b. Quorum: A majority of Committee members must be present for decisions to be made.
c. Record Keeping: Minutes of all Committee meetings will be documented, and relevant records will be retained in accordance with [Mortgage Lender/Servicer Name]'s document retention policy.Reporting Structure
The Committee will provide regular reports to senior management and the Board of Directors. These reports will include:An overview of complaint volume, key trends, and significant issues.
Details of regulatory inquiries and any material interactions with oversight agencies.
Status updates on the implementation of corrective actions or process improvements.
6. Escalation and Accountability
The Committee will establish an escalation process to ensure that significant complaints, regulatory inquiries, or non-compliance issues are promptly brought to the attention of senior management or the Board of Directors. Additionally, the Committee will monitor the implementation of corrective actions to ensure timely and effective resolution of identified issues.
7. Amendments
This Charter may be amended as necessary, subject to approval by the Committee and the Board of Directors. The Committee will periodically review this Charter to ensure it remains aligned with legal and regulatory requirements, as well as industry best practices.
Effective Date: [Insert Date]
Approved By: [Insert Board or Committee Chair Name]
Last Review Date: [Insert Review Date]
Next Scheduled Review: [Insert Date]
This Charter provides a robust framework for the Complaint Oversight Committee to effectively manage and resolve consumer complaints and regulatory inquiries, ensuring compliance with applicable laws and regulations while enhancing operational efficiency and consumer trust.