ALEXANDRIA, Va.–NCUA’s consumer complaint program is performing well, but there are issues related to internal controls over complaint processing and communications with stakeholders, according to a new report from the agency’s Office of Inspector General (OIG).
The OIG said it performed an audit of the complaint resolution function at NCUA for the period from Aug. 24, 2015, through June 30, 2018.
“Results of our audit determined that overall, the NCUA processes consumer complaints efficiently and effectively and in accordance with applicable laws, regulations, policies, and procedures. We also determined examiners use consumer complaint information and trends data during pre-exam scoping activities,” the OIG audit states. “However, we noted some areas where the agency could improve internal controls over the consumer complaint program.”
The Recommendations
The OIG report includes nine recommendations for NCUA management as well as three suggestions, including:
- Maintain a complete audit trail for all cases entered into the Salesforce system. The OIT said NCUA management responded it will do so and will perform quarterly audits tracing samples of cases through the system by no later than Dec. 31, 2021.
- Improve and document Salesforce internal control responsibilities to include developing policies and procedures related to the deletion of consumer complaint cases; periodically assessing user roles to determine required system permissions and provide access that allows for least privilege; and performing and documenting periodic reviews of Salesforce generated audit logs. In response, NCUA management said it will update existing internal control responsibilities related to the deletion of consumer complaint cases and update documentation accordingly to reflect improvements by Dec. 31, 2021. It will also periodically assess user roles for relevance and accuracy and perform quarterly reviews of Salesforce generated audit logs beginning Dec. 31, 2021.
- Establish a formal process to monitor the effectiveness of internal controls over the consumer complaint process to include quality control reviews and timely remediation of internal control exceptions. NCUA said it will do so by year-end.
- · Periodically review the Operations Manual to ensure it includes relevant information, addresses all control risks, and management holds employees accountable for following established policies. NCUA said it will do so by year-end.
- Revise policies and procedures related to determination letters to ensure the agency communicates a clear, and accurate message to both consumers and credit unions. NCUA said it will do so by Dec. 31.
- Revise the Supervisory Committee Guide for Federal Credit Unions to reflect the current consumer complaint process and responsible office. NCUA responded by saying it will draft language for inclusion in the appropriate guide or manual reflecting the current consumer complaint process and responsible office by June 30, 2021.
- · Establish a process to solicit input from consumers and credit unions to identify issues in the consumer complaint process and use resulting input as appropriate to improve the NCUA’s consumer complaint program. NCUA said it will do so by year-end.
- Finalize and issue an Instruction outlining the roles and responsibilities of the NCUA’s consumer complaint process to ensure consistent and relevant guidance for all NCUA staff to include consumer protection laws and regulations that the NCUA enforces. Rescind or cancel all NCUA or regional Instructions no longer applicable. NCUA said it will do so by Sept. 30, 2021.
- Communicate comprehensive pattern and trends data, complete with analysis, related to the NCUA’s consumer complaint program to assist internal stakeholders with understanding consumer complaint data to meet the agency’s consumer compliance objectives. NCUA said it plans to do so June 30 and then will do so on a quarterly basis.
Three Suggestions
The three suggestions made by NCUA’s OIG include:
- Conduct quarterly reviews to determine whether analysts uploaded violation data in the CCV module at the time they closed complaints. NCUA said it will do so by year-end.
- Establish performance goals for the Consumer Assistance Center. NCUA said it will do so by Sept. 30.
- Implement measures to ensure complaints, within CAC purview, are delivered to all credit unions within ten business days. NCUA said it will implement a goal of delivering 95% of complaints within CAC purview to credit unions within 10 business days by June 30.