How To Prevent Involuntary Account Closures

“I know we have issues. I just don’t know where to find them.” This is what an executive at a large bank recently told me. Bank executives know they have opportunities to improve the customer experience, better manage their risk, and create new revenue streams. Yet, they don’t always know where to begin.

Artists call this opportunity, white space.

In order to begin filling your white space, you need a framework that considers the internal and external forces that you are experiencing. One of your most undervalued forces is your customer feedback. Understanding your customer feedback is just as critical to evaluating opportunities for growth as is understanding your competitive forces, macroeconomic forces, and regulatory forces.

The PositivityTech® intelligent platform merges these forces, and fills this white space with patterns, forecasts, and priorities, at scale — based on your own customers’ voices. Using artificial intelligence and advanced predictive algorithms, PositivityTech turns your customers’ voices into data, showcasing your risks, opportunities, and competitive advantages.

Let’s see what this growth opportunity might look like when considering financial institutions’ account closures.

See why financial institutions are closing customers’ accounts

Recently, Chime faced criticism for closing customer accounts without warning. In a recent American Banker article, reporter Kate Berry wrote about Senate Banking Committee Chairman Sherrod Brown’s request to the Consumer Financial Protection Bureau (CFPB) to address these issues. In a letter to the CFPB, Brown wrote:

“Chime’s abrupt, involuntary closures of its customers’ accounts — and locking them out of access to their funds — can cause lasting damage to their financial condition… There are a number of consumer risks involving nonbanks, from privacy concerns, fraud, data breaches, and proper disclosure that these companies are not actually banks.”

As you know, the cost of acquiring a new customer greatly exceeds the cost of retaining a current customer. Account closures directly impact the P&L, and many initiatives exist to prevent customers from ending their relationship with their banks. Improved targeting for retention programs is informed by what your customers are telling you. While Chime, a fintech, may be in the media for involuntary account closures, most financial institutions are struggling with this issue, too.

Below are the institutions with the greatest number of complaints to the CFPB about account closures, as seen in PositivityTech:

Here is an example of an actual Chime customer complaint to the CFPB about an involuntary account closure, as seen in PositivityTech:

In the table from PositivityTech below, you can view the number of complaints about issues with closing an account from Chime customers to the CFPB, as compared to other customer complaints from other financial institutions. You can also see that a greater percentage of complaints about opening an account come from Chime customers, too.

Are companies adding enough new accounts to make up for these account closures? How can these account closures be prevented? When you know what your issues are and how to find them, you can begin to solve them, to meet customers’ needs, and to grow your P&L.

Create new revenue streams

We need to pay attention to our customers’ voices. With PositivityTech, customer conversations are integrated into our technologies so that financial institutions can pursue a human-centered approach that truly serves customers. Our customers are sharing their challenges with us and telling us what we need to know.

By listening to customers and using their voices as information sources, you can grow your relationships with your customers through targeted differentiation. You can monitor your progress, be prepared for your customers’ actions, and you can create policies and practices, and grow your business in ways that serve them. You can create new much-needed revenue streams, based on what your customers tell you they need and want.

See what PositivityTech can reveal about your company — and discover your opportunities for growth. Schedule a demo by emailing me at marcia.tal@positivitytech.com. I look forward to giving you the tools you need to fill your white space.


Inside 6 Billion High-Risk Customer Conversations

When we consider large-scale data sources in financial institutions, we may think about credit reports, transaction data, and customer behavior data. Similarly, what value do we apply to customer conversation data? Is your institution approaching your customer conversation data as a large-scale data source with golden nuggets of valuable insights waiting to be uncovered? With the PositivityTech intelligent platform, you can do just that and turn negatives into positives.

In the United States alone, call centers across industries receive approximately 50 billion calls each year. Many of these calls, driven by frustration, present major risks for your business and can lead to customers:

  • Closing their accounts and ending their relationships with your institution
  • Not making their payments
  • Bringing legal action
  • Citing bias and discrimination
  • Highlighting areas of regulatory concern

A critical step to meeting customers’ concerns is understanding who your customers are — and why they are complaining.

Get to know your customers

Yes, institutions know their customers because they analyze their customer behavior and transaction patterns. Now, imagine adding this powerful data to understand your customers: customer conversations. By using customer conversation data, institutions can understand who their customers are, based on what they tell you about themselves.

Simplicity, empathy, and equity: Get to know why your customers are complaining

Once you know who your customers are based on their conversation data, then you can understand why they are complaining — by providing them with simplicity, empathy, and equity. Customers need to understand policies, know that they’re being listened to, and see that they’re on an equal playing field with their institutions. Ensuring that these core components are in place and equipping individuals who create policies with direct access to these raw conversations, will enable your institution to avoid practices that lead to unintended consequences and will improve customer outcomes.

The scale of customer complaints is enormous and ready to be tapped with PositivityTech

If your business is like most businesses, you are approaching customer narratives transactionally and to meet immediate needs. Yet, you may not be approaching them as strategic assets that can pinpoint systemic problems, give you a competitive edge, and lead to business growth. The current scale of customer complaints — and the value you’re missing — is enormous:

  • 6+ billion “high-risk customer conversations” a year take place in the U.S.
  • 90% of businesses state that customer experience will overtake price and product as brand differentiators.
  • A typical business hears from 4% of their dissatisfied customers; for every customer that bothers to complain, 26 others remain silent.
  • $75 billion is lost by businesses annually due to poor customer service.

Four major pain points for financial institutions

Explore some of your greatest pain points — as publicized in the media and in your own customers’ complaints, as seen in PositivityTech:

Pain Point #1: Overdraft fees

Two years ago, we reported on a major issue that customers face: overdraft fees. In their responses to customer complaints about overdraft fees, banks often provide monetary relief, acknowledging the challenges they face in the execution of regulations.

In the media: These 10 banks are rethinking overdraft fees. Here’s why and how

In this American Banker article, Ally Bank CEO Jeffrey Brown captures the issues that overdraft fees present: “Overdraft fees are a pain point for many consumers but are particularly onerous for some. It is time to end them… Eliminating these fees helps keep people from falling further behind and feeling penalized as they catch up.”

Inside PositivityTech: Customer complaint about overdraft fees

“Please help. I applied for an apartment and this apartment turned out to be fraudulent. I filed a claim with XXX and I submitted the screenshot they requested and they still three months later close the case and continue to have my account negative over {$1000.00} and have continued to accumulate {$35.00} overdraft fees for months. I have contacted XXX and asked for this money to be returned and they say that the case is closed and I have to re-open a new case.”

Pain Point #2: Student loans and income sharing agreements

Income sharing agreements, a student loan product, are currently under regulatory scrutiny.

In the media: Can banks allay concerns about emerging student loan product?

In this American Banker article, one of the major issues with income sharing agreements is pinpointed: “Critics say banks could face reputational risks from working with a sector that is increasingly targeted for alleged consumer protection abuses, such as requiring expensive prepayment penalties, which some experts argue is illegal under the Truth in Lending Act.”

Inside PositivityTech: Customer complaint about student loans

“I secured this ‘income sharing’ loan, which was not correctly explained to me by the agent, with the very clear definitive understanding I was agreeing to a 36 month term… They don’t talk about interest rates but they only talk about a percent of your income and sell you on the concept that if your income goes down then so does your payment.”

Pain Point #3: Closed accounts

When financial institutions close accounts in an attempt to prevent fraud, they may mistakenly close accounts that are not fraudulent.

In the media: Chime customers file hundreds of CFPB complaints over locked accounts: report

In this Banking Dive article, Chime’s move to close accounts is explained: “In an attempt to root out fraud related to the government-backed pandemic aid, the fintech may have inadvertently closed hundreds of legitimate customer accounts.”

Inside PositivityTech: Customer complaint about closed accounts

“XXX closed my account out of nowhere. They said I was not in compliance with the XXXX bank’s internal policies. All I do is receive my direct deposits from work, and spend my money on things I need. I have not violated any rules or regulations. They closed my account and left me stranded with no money.”

Pain Point #4: Loans without borrowers’ consent

When financial institutions provide individuals with loans without their consent, consumers may find themselves in debt, without knowing why.

In the media: GreenSky facilitated loans without borrowers’ consent: CFPB

This American Banker article details the scale of loans that GreenSky provided without consent and the customer complaints they faced as a result: “GreenSky has been fined $2.5 million and forced to refund up to $9 million in loans the fintech allegedly allowed its merchant partners to take out on behalf of customers who hadn’t authorized the financing.”

Inside PositivityTech: Customer complaint about loans

“We received a bill for {$14000.00} from XXX on XX/XX/2019, with an interest rate over 25%. However, we have never agreed to any loan from XXX, we have never signed any financing paperwork or approved anything related to a XXX account or loan whatsoever.”

Empower people to turn negatives into positives

With PositivityTech, you can finally analyze your customer voice data and link complaints to the policies and tactics specific to customer frustrations. You can demonstrate that as you actively listen to your customers’ voices and proactively address issues, you will also inspire others to raise their voices. You will save a magnitude in fines, improve customer retention, attract new customers, and significantly increase your bottom line. This is good for your customers, your brand, and your business.

I invite you to schedule a PositivityTech demo today. The scale of your customer conversation data is enormous and ready to benefit you and your customers. Please email me at marcia.tal@positivitytech.com


Does Income Level Impact Customer Experience?

Does a customer’s income influence their level of frustration when they complain to the CFPB? Does a customer’s income influence their perceived discrimination when they complain to the CFPB? To begin evaluating the role that social economics play in customer complaints to the CFPB, PositivityTech ingested Census Bureau income data and integrated it with CFPB complaints from the last year, ultimately identifying these insights:
  1. Complaints escalated to the CFPB are concentrated in mid-income ranges.
  2. Customers’ perceived bias, as identified by PositivityTech’s Bias Index, is consistent across income ranges and reveals variability when customers complain about specific products.
  3. Customers’ severe frustrations, as identified by PositivityTech’s Severity Score, are consistent across income ranges, and reveal variability when customers complain about specific products.
  4. Customers’ levels of frustration and perceived bias vary by financial institution, and are influenced by the target market / product mix, organizational culture, and policies.

Do income levels impact customer complaints?

Almost 75% of the complaints escalated to the CFPB last year are from customers with incomes that range between $35,000 and $99,000.
Customer complaints that reveal PositivityTech’s highest Bias Index and customer complaints that reveal PositivityTech’s highest Severity Score are compared to the entire set of customer complaints to the CFPB in the last 12 months. As showcased in the graph below, there is consistency of income distribution across all three of these groups.
Here is a complaint from a customer with a high income, which reveals a high Bias Index and high Severity Score: I felt like I [had] a discrimination experience with customer service… When I made contact through a video relay service, they thought it was theft identification and flagged it to the fraud department. I understand their concern about security… I am deaf and using an interpreter to communicate with them. They had a communication barrier. XXX seems not to follow the America Disability Acts Law procedure. The customer care service representative threatened me and violated my rights. Here is a complaint from a customer with a low income, which reveals a high Bias Index and high Severity Score: I received a letter that claimed that activity on my account with XXX was indicative of high risk of failure to pay. This is simply not true as I have maintained an excellent payment and credit history. I called in and spoke to a telephone representative who did not provide good customer service and arrogantly told me to reapply if I wanted the card. I believe that I am a victim of XXXX and XXXX discrimination and redlining. While XXXX may be a low-income area, I am not in financial distress and have been a great customer.

Income levels differentiate perceived bias and levels of frustration when coupled with product-specific complaints

  • Higher income complaints with high perceived bias are concentrated in mortgages and credit cards.
  • Middle income complaints with high severity scores are concentrated in credit reporting and debt collection.
  • Lower income complaints are concentrated in credit reporting and debt collection.

With benchmarking, see how frustrated your customers are

Using PositivityTech, you can create customized logic for financial institutions’ benchmark groups. Using a benchmark group of 17 large financial institutions, we identified four institutions with the highest perceived bias based on their customers’ words, and four institutions with the highest customer frustrations based on their customers’ words. Within this group of 17 large financial institutions, one institution has the highest percentage of complaints in both the High Bias Index range and the High Severity Score Index range. Here is a complaint from a customer of this financial institution, which reveals a high Bias Index and high Severity Score: This was very rude behavior and absolutely humiliating. Yet again it wasn’t until after I had the assistance of my fiancé that this representative proceeded to further help. I feel as if I’ve been discriminated based on my gender and/or age… I’d also like to point out that I’ve always attempted to be very rational, respectful, and polite when speaking with these people so this kind of treatment was very unnecessary and demeaning. I plan to switch banks upon the release of my money… I hope these policies and lies do not continue to be implemented and overlooked.

The power of granular segmentation

PositivityTech provides you with the opportunity to understand which segments of your customer base are complaining, and to identify the issues most pressing for these segments. You can gain the most sophisticated, granular views of your segments and address your critical front-end business needs. You can be on the cutting edge by integrating customer complaints as a data source — and turning negatives into positives. See what PositivityTech can do for your business. Schedule a demo by emailing me at marcia.tal@positivitytech.com.

Three Problems That Need To Be Fixed: COVID’s Financial Impact

In the year since COVID-19 lockdowns began in the U.S., customer complaints reveal the ongoing impact of the pandemic and its economic fallout on customers. With the PositivityTech® Intelligent Platform, customer complaint data captures this reality and presents critical opportunities for banks and credit bureaus to repair practices.

Problem 1: Health impacts finances

As early as April 2020, customer complaints, like the one below, began to reveal the impact of their health stress on their financial stress. This impact continued to grow, with complaints to the Consumer Financial Protection Bureau increasing by almost 54% in 2020, according to their recently released annual report. With PositivityTech, we identified that COVID-19-related complaints also continued to increase throughout 2020 and are continuing in 2021.

Sample customer complaint: “I was admitted to the hospital in XXXX. Not only did I have the XXXX and was in the hospital for a long time, I lost my job. I spoke with XXXX and was advised my payments were deferred until XX/XX/2020. I get a credit alert and they have reported me as past due. This is a VIOLATION OF THE CARES ACT AND THE LATE PAYMENT NEEDS TO BE REMOVED!… I was told I was provided protections under the CARES ACT and they failed to adhere to what was offered to me!”

Problem 2: Payment deferrals are not a long-term solution

With many Americans furloughed or unemployed due to the pandemic, banks offer temporary forbearance or forgiveness programs to ease the financial pressure of payments due on loans. Yet, ultimately, are these programs helping customers?

a. When payments were due three months later, customers approved for these programs were often unable to pay.

Sample customer complaint: “My husband recently passed. I am presently in processing for mortgage assistance with my mortgage company. I requested a forbearance because I had been affected by Covid-19. My mortgage company is giving me a hard time even though President Biden has signed an executive order for foreclosures to be put on hold. My property is set for foreclosure sale… I need Help.”

b. Forbearance approvals were misreported, causing delinquencies and plummeting credit scores. Until these issues are repaired, they will create another level of hardship for customers seeking credit.

Sample customer complaint: “I have attached for reference the Forbearance Agreement dated XXXX/2020 along with the Forbearance Letter confirming the forbearance was granted dated XXIXX/2020. This letter specifically states the following – you are not required to make any payments during the forbearance. The three bureaus are reporting the lates in error and it is seriously harming my credit score. These line items need to be removed and/or updated to report accurate information. It is a violation of the Fair Credit Reporting Act to not report accurate information on a credit report.”

Problem 3: Credit bureaus’ inaccurate data is affecting economic recovery

The ongoing problems within credit bureau reporting will continue to create disruptions for economic recovery. Credit bureaus are the central repository of information that all consumers and companies alike depend on, and their veracity is assumed.

“The pandemic has been among the most disruptive long-term events we will see in our lifetimes. Not surprisingly, the shockwaves it sent across the planet were felt deeply in the consumer financial marketplace,” CFPB Acting Director Dave Uejio said in a press release.

Steps Toward Recovery

Using the PositivityTech platform, banks and credit bureaus can see the impact of the pandemic on their customers, and can work together to fix these issues.

You can uncover what your customer complaint data reveals about the risks ahead.

You can understand how to solve the issues your customers are facing.

You can act upon the insights your own data highlights.

Send me an email to gain access to PositivityTech.


Top Reasons Why Banks Pay Monetary Relief

What exactly is monetary relief and when do financial institutions provide it to consumers?

Monetary relief is defined as objective, measurable, and verifiable relief that is provided to the consumer as a direct result of the steps taken or that will be taken in response to a complaint. As of December 2020, CFPB public enforcement actions have resulted in over $12.9 Billion in total consumer relief and fewer than 5% of CFPB customer complaints are resolved with monetary relief. As the new CFPB director focuses on consumer fairness and financial inclusion, how should financial institutions expect monetary relief to play a role?

Acting Director of the CFPB Dave Uejio recently shared one major focus when he stated, “I am going to elevate and expand existing investigations and exams and add new ones to ensure we have a healthy docket intended to address racial equity. This of course means that fair lending enforcement is a top priority and will be emphasized accordingly.”

The PositivityTech® intelligent platform enables you to identify and understand drivers to your biggest pain points — including areas that are not easily found nor analyzed — and can cost you the most. In this case, PositivityTech has identified the small percentage of customer complaints resolved with monetary relief, and can recommend proactive management actions to address these pain points. These actions result in better customer treatment, adherence to regulatory and legal requirements, and improvements in overall business performance.

PositivityTech’s proprietary Severity Score and Bias Index demonstrate:

  • The majority of complaints resolved with monetary relief score in the higher deciles of the PositivityTech Severity Score, indicating severe customer frustration.
  • The Bias Index for complaints resolved with monetary relief is 50% higher than all other company responses to consumers, indicating higher discrimination risk.

Exploring Monetary Relief by Product

Customer complaints resolved with monetary relief are concentrated in the following products:

During the last 90 days, the most significant increase in monetary relief can be found in the money transfer and virtual currency products. The following excerpt from a customer complaint related to money transfer sheds light on the problems that customers face. This customer’s complaint had a high Severity Score and was resolved with monetary relief:

“…I was informed by X that they were closing my account from sending and receiving money anymore and any money in my account will be locked for 180 days. This is unfair and I was given no reason other than what seems to be because my mom was sending me large amounts of money to cover my expenses…”

Exploring Monetary Relief by Issue

Customer complaints resolved with monetary relief are concentrated in the following customer-stated issues:

The PositivityTech proprietary Early Warning Triggers highlight issues to pay attention to. The following two issues triggered are two of the issues that lead to monetary relief resolution.

Competitive Benchmarking: Exploring Monetary Relief by Financial Institution

By comparing different institutions and the percentage of their customers’ complaints resolved with monetary relief, PositivityTech identified that:

  • One financial institution (Bank A) resolves more of its complaints with monetary relief consistently than any other institution.
  • Digital banks, payment companies, and fintechs are increasingly resolving their customers’ complaints with monetary relief.

Identify and Prevent Complaints that Lead to Monetary Relief

PositivityTech gets deep inside the pain points that cost you the most and reveals where you should take action. By turning your customer voices into data, PositivityTech enables you to:

  • Proactively identify which products and issues lead to monetary relief and understand why monetary relief is provided.
  • Prioritize actions to prevent customer frustration and to prevent monetary relief payments.
  • Compare your complaint resolution outcomes with other institutions across the industry.
  • Change policies and procedures to positively impact your bottom line.

With PositivityTech, find out where you stand and take action to improve practices that lead to monetary relief. To learn more, please reach out to me at Marcia.Tal@PositivityTech.com. I look forward to helping you turn negatives into positives.