Understanding and Managing the CFPB Complaint Process
The CFPB (Consumer Financial Protection Bureau) has been inviting consumers to “tell their story” and file complaints since July, 2011.

When the CFPB launched its monthly report of consumer complaints in July 2015, Director Cordray said “Consumer complaints are the CFPB’s compass and play a central role in everything we do. They help us identify and prioritize problems for potential action.”

While the CFPB may not be the primary regulator for your financial institution, it’s critical to understand how the CFPB complaint process has changed regulatory expectations, and what your bank or credit union should be doing to proactively manage complaints.

Covered Topics

  • Learn how the CFPB uses complaint information to guide investigations, develop enforcement actions, and require reimbursement to consumers.
  • Learn the regulatory “expectations” for complaints that include
    • Accepting complaints – what is a “complaint”, how are they recorded and how are they resolved?
    • What’s a “reasonable” timeframe to respond to a complaint?
    • What type of complaints required escalation and immediate attention?
    • What types of complaints indicate potential UDAAP (unfair, deceptive, or abusive acts or practices)?
    • What type of complaints may indicate potential “consumer harm”?
    • What type of complaints should result in changes to products, services, or practices?
    • What steps should be taken when the complaint involves a third party vendor?
  • What do recent enforcement actions tell the financial service industry about the importance of complaints?
  • How is social media used by regulators in the complaint process?
  • What do the employees in your financial institution need to know about handling complaints? How should complaints be tracked and evaluated? What type of training should be completed for handling complaints?
    • Complaint Policy, Procedures and tracking form in WORD that can be modified for your financial institution
    • Helpful UDAAP compliance resources and regulatory guidance, including FDIC Abusive Practices –Third Party Procedures checklist
    • UDAAP Risk Assessment checklist
    • Checklist for “Evaluating Consumer Harm”
  • Regulatory resources


Senior Management, Compliance Officers, Risk Managers, Branch Managers, Call Center Managers, Loan & Deposit Operation Managers, Marketing Staff, and Product Development Specialists


Susan Costonis is a compliance consultant and trainer. She specializes in compliance management along with deposit and lending regulatory training and began her career in 1978. Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve.

Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.

Credit Information

Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits


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