Consumer Complaints
Compliance and Supervisory Procedures for
2999 Tyrone Blvd N, St. Petersburg, FL 33710
Access Reverse Mortgage Corporation
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Consumer Complaints
Consumer Complaint Policy and Procedures
The consumer landscape is changing: consumers have heightened service expectations from
institutions, and many have become quicker to register complaints through a range of online and
offline channels, such as telephone, in person, social media sites, email, and the traditional
written complaints. In addition, the regulatory agencies are providing consumers with greater
access to file complaints directly.
Consumer complaints should be viewed as an expression of legitimate concern regarding the
way Access Reverse Mortgage Corporation provides mortgage broker services. In many cases,
escalation of consumer complaints can be mitigated by promptly responding with accurate and
thorough information at the time of initial communication. Verbal complaints, properly handled,
may prevent a customer from providing a written complaint either through the Access Reverse
Mortgage Corporation, social media sites or regulatory agencies.
Complaints may be indicative of a compliance weakness. If handled in a constructive manner,
complaints are an opportunity to improve products and services, enhance consumer relations and
minimize potential regulatory impact. It shall be the policy of Access Reverse Mortgage
Corporation to handle all consumer complaints with care and to resolve these matters promptly
and, when applicable, within regulatory requirements. All complaints from customers will be
given courteous and fair attention.
This policy addresses the following types of consumer complaints received through online or
offline channels (i.e. telephone, in person, social media sites, email, regulatory agency, and direct
written communications.):
•
•
•
Legal or Regulatory
Product or Service (to include complaints with third party service provider vendors)
Allegations of fraud
I. General guidelines
The following apply to complaints received through all online or offline channels (i.e.
telephone, in person, social media sites, email, regulatory agency, and direct written
communications, 'Communication Channels'):
•
Upon receipt of a consumer complaint, immediately notify appropriate Access Reverse
Mortgage Corporation contact person(s); perform an investigation to determine the facts
surrounding the complaint; and provide a response to customer.
Access Reverse Mortgage Corporation
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Consumer Complaints
•
Ensure that any potential compliance issues have been addressed and resolved in
accordance with requirements.
•
Resolve any issues or concerns that may have been uncovered during the investigation.
This could involve such things as changes in procedures, policies, forms design, possible
changes in system functionality, additional training, etc.
•
Upon receipt of a written complaint, document the date and time of receipt in the upperright hand corner of the written document.
•
Verbal complaints are to be documented on a complaint log.
•
If the complaint is received via email insert the following in the subject line prior to
forwarding to contact person(s): “Consumer Correspondence – Confidential”
II. Types of Complaints and Required Actions
Access Reverse Mortgage Corporation’s policy distinguishes between the following types of
customer complaints:
A.
Legal or Regulatory Complaints:
These are complaints in which:
•
a consumer has filed a complaint through a federal or state regulatory agency (i.e. Better
Business Bureau, DFI, FDIC, OTS, FTC, Attorney General, Law Enforcement, CFPB,
etc.);
•
a consumer has retained or is threatening to retain an attorney in connection with a
complaint against or dispute with the company;
•
a consumer has raised questions or concerns that Access Reverse Mortgage Corporation’s
products, services or practices may violate applicable laws, rules, or regulations imposed
by any governmental agency or authority; or
•
a consumer has indicated they have been discriminated against.
Required Action
•
A consumer may register a complaint about Access Reverse Mortgage Corporation to a
variety of regulatory/legal agencies. These agencies in turn will submit the letter to
Access Reverse Mortgage Corporation for response.
Access Reverse Mortgage Corporation
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Consumer Complaints
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If the consumer has involved an attorney, consult Access Reverse Mortgage
Corporation’s legal counsel before communicating on any matter related to the consumer.
•
Consumers may also file complaints directly with Access Reverse Mortgage Corporation
through any of the Communication Channels indicating they have been discriminated
against, or raise questions or concerns that Access Reverse Mortgage Corporation’s
products, services or practices may violate applicable laws, rules, or regulations imposed
by any governmental agency or authority.
B.
Product or Service Complaints:
These are complaints in which:
•
a consumer has raised concerns about the quality, nature, cost, or timeliness of Access
Reverse Mortgage Corporation's products or service levels;
•
a consumer submits a notice of error under Regulation E* which is received no later than
60 days after sending a periodic statement, enables identification of the consumer’s name
and account number, and indicates why the consumer believes there is an error and
includes details surrounding the alleged error;
•
there is a qualified written request under RESPA* which must be in writing, include the
name and account of the borrower, and include a statement of the reasons for belief that
there is an error; or
Required Action

Regulation E* requires that a financial institution conduct an investigation and determine
if there was an error within 10 business days and report the results to the consumer within
3 business days upon completion of the investigation.

RESPA* requires that not later than 60 days after receipt of a qualified written request
the loan servicer must make appropriate corrections in the account of the borrower and
transmit a written notification of the corrections made. After conducting an investigation,
the servicer must provide a written explanation that includes contact information where
the borrower can obtain more assistance from the borrower and either a statement of
reasons why the borrower’s account is correct, or the information requested by the
borrower.
Personnel should follow Access Reverse Mortgage Corporation’s internal procedures for
assessing and responding to complaints within this category.
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Consumer Complaints
*NOTE: Regulation E and RESPA have additional regulatory requirements that dictate
timing, investigative, response and maintaining a log of complaint and resolution. The
descriptions above are included as general guidelines and great care should be taken to
follow additional requirements.
C.
C. Allegations of Fraud:
These are complaints in which:
•
a consumer has indicated they were/are victims of possible fraud, identity theft, criminal
activity and /or financial loss;
•
a consumer alleges funds are missing from an account;
•
a consumer alleges illegal activity by a Access Reverse Mortgage Corporation employee;
or
•
a consumer alleges breach of information
Required Action
•
If you receive a consumer complaint that asserts allegations of fraud, criminal activity or
financial loss, immediately contact Compliance Officer for guidance and assistance with
the investigation and response.
•
If the complaint alleges Breach of Customer Information contact the Compliance Officer.
•
If the complaint involves employee misconduct refer to Code of Conduct located within
Employee Handbook.
III.
Business Unit Manager Responsibility
•
Upon receipt of a consumer complaint, immediately notify appropriate Access Reverse
Mortgage Corporation contact person(s); perform an investigation to determine the facts
surrounding the complaint; and provide a response to the customer.
•
Ensure that any potential compliance issues have been addressed and resolved in
accordance with requirements and the resolution has been fully documented.
•
Resolve any process issues or concerns that may have been uncovered during the
investigation. This could involve such things as, change in procedures, policies, forms
design, possible changes in system functionality, additional training etc.
•
Upon receipt of a written complaint, document the date and time of receipt, and your
name in the upper-right hand corner of the document.
Access Reverse Mortgage Corporation
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Consumer Complaints
•
Verbal complaints are to be documented.
•
Promptly respond. Response should be commensurate with the channel in which the
complaint was received. Each situation is unique and the following is intended to be
guidance: verbal complaint – immediate response with follow up in 24 hours, or upon
time committed to customer; social media – immediate response; email - immediate but
not more than 24 hours; written direct to Access Reverse Mortgage Corporation – 10
calendar days; regulatory agency channel – as stated on notice.
•
Follow-up with consumer by the date committed to consumer.
•
Follow-up with any actions identified within the response to consumer. These actions
must be documented and maintained with the consumer complaint documentation. Notify
consumer of actions taken if there was a commitment or expectation identified in the
response.
•
If the complaint is received via email insert the following in the subject line prior to
forwarding to contact person(s): “Customer Correspondence – Confidential”
Each business unit manager is also responsible for:
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retaining evidence of staff training and providing training records upon request
•
providing consumer complaint records upon request
•
retaining consumer complaint records in accordance with department record retention
schedule. These records would be: the consumer complaint, investigative documents, and
Access Reverse Mortgage Corporation’s response.
IV.
Requests for Consumer Complaint Records
Periodically, examiners and auditors will request copies of consumer complaints and
corresponding bank response. In some instances, business units may receive these types of
requests multiple times a year. Also, at least annually, the compliance officer will request this
same information in order to produce the Consumer Complaint Trends. Accordingly, these
records should be readily available upon request.
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Consumer Complaints
V. Staff Training
Training on Access Reverse Mortgage Corporation’s Consumer Complaint Policy and
Procedures will be provided to appropriate staff upon hiring and additional training will take
place every 2 to 3 years. Evidence of this training will be retained within the business unit and be
made available upon request.
VI.
Record Retention
The Operations Manager will be responsible for maintaining a record file of consumer
communication and supporting documentation for 3 years.
Access Reverse Mortgage Corporation
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Consumer Complaints