SES Complaint e-Book

Initiating a Complaint

Introduction SES allows agencies to manage complaints. Initiating a complaint is the first step in entering a complaint into the system.

Note: Users assigned to the Complaints group in SES can initiate a complaint. See Managing Users for more information.

Accessing Complaints To begin entering a complaint, you must go to the Complaints application within SES. Follow the steps below to navigate from the Supervisory Activity application to the Complaints application.

1. Click Manage Complaints .

Note: This opens a new tab in your browser.

2. Click Enter New Complaint .

3. Select the desired method for Searching for a Subject of a Complaint.

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Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

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Searching for a Subject of a Complaint

Introduction After initiating a complaint, you must search for a subject of the complaint. There are two options when searching for a subject: entering a known subject ID or following a guided search wizard.

Note: Users assigned to the Complaints group in SES can search for the subject of a complaint. See Managing Users for more information.

Complaints cannot be entered on depository companies/institutions at this time. The company information that displays in the search results represents non- depository companies with an account in NMLS. In a future version of the complaint system, agency complaint users will be able to enter and process a complaint on a depository. Entering the Subject ID Use this search option when you know the SES ID, NMLS ID, Entity Tracking Number, or State License Number for the subject.

1. Click Enter Subject ID.

2. Select Company, Branch, or Individual.

Note: Regardless of whether you are entering a complaint for a company, branch, or individual, the complaint is ultimately tied to the company’s record. The company is sent the information requests and can respond to the complaint; individuals do not need to create an SES account.

a. Search by Company allows you to enter SES ID, NMLS ID, Entity Tracking Number, or State License Number.

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b. Search by Branch allows you to enter the NMLS ID. c. Search by Individual allows you to enter the NMLS ID or the individual’s name. 3. Confirm the entity’s d etails. 4. Click Enter Complaint . Searching for Subject Use this search option when you are entering a complaint for an entity and you do not know the SES ID, NMLS ID, Entity Tracking Number, or State License Number.

1. Click Search for Subject .

2. Use the icons at the top of the page to search by name, location, employee, keywords, phone number, or website.

3. Click I Do Not Have This Information to advance through the search options. 4. Search results appear for NMLS/SES Companies and Non-NMLS Entities.

Note: Employee, keyword, and website only sear Non-NMLS entities.

a. NMLS/SES Companies are pulled into SES from NMLS 1.0. Clicking the SES ID opens the company’s record in a new tab and provides the option to initiate onboarding if this has not yet occurred. b. Non-NMLS Entities are records created by other agency Complaints users. They are assigned an Entity Tracking Number by the system. Clicking the Entity Tracking Number opens the Non-NMLS Entity record and provides the option to update the entity information if your agency created it. Or you can check the discussion about the entity. 5. Click Subject Not Found if the search results do not return the entity you are searching for and advance to the next search option.

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6. Once you have found the desired entity, click the row of the desired company .

7. Click Enter Complaint .

8. After all search options have been exhausted, click Create New Non-NMLS Entity .

Note: The option to create a new Non-NMLS Entity is intentionally difficult to find. This is to prevent or limit duplicate Non-NMLS Entities.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Entering a Complaint

Introduction After searching for a subject or creating a non-NMLS entity, you can enter a complaint in SES.

Note: Users assigned to the Complaints group in SES can enter a complaint. See Managing Users for more information.

Entering a Complaint for a Company, Branch, or Non-NMLS Entity Company, branch, or Non-NMLS Entity information is automatically populated in the Subject Details section and cannot be edited.

Note: Regardless of whether you are entering a complaint for a company, branch, or individual, the complaint is ultimately tied to the company’s record , unless it is a non-NMLS entity. The company is sent the information requests; individuals do not need to create an SES account.

1. Complete all required fields. 2. Select Bypass Preliminary Evaluation . 3. Click Create Complaint .

Note: You also have the option to submit complaint for preliminary evaluation. See the Completing Preliminary Evaluation of a Complaint article for more information. If you do not submit the complaint for preliminary evaluation, you are assumed as the agency Point of Contact (POC) for the complaint.

Entering a Complaint for an Individual The individual’s NMLS ID is carried over from the previous search q uery and you must enter the individual’s name.

Note: Regardless of whether you are entering a complaint for a company, branch, or individual, the complaint is ultimately tied to the company’s record. The company is sent the information requests; individuals do not need to create an SES account.

1. Complete all required fields.

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Note: You have the option to associate the individual to a company and enter the company’s NMLS ID. If you do not associate the individual to a company, you cannot complete the information request process in SES complaints.

2. Select Bypass Preliminary Evaluation . 3. Click Create Complaint .

Note: You also have the option to submit complaint for preliminary evaluation. See the Completing Preliminary Evaluation of a Complaint article for more information. If you do not submit the complaint for preliminary evaluation, you are assumed as the agency POC for the complaint.

What Happens After You Enter a Complaint? After creating a complaint, SES assigns a unique identifier for each complaint, referred to as the Complaint ID.

To continue processing the complaint after entering it:

1. Navigate to the home page. 2. Click the Complaint ID hyperlink for the complaint you created.

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3. Process the complaint by sending information requests, adding research and communication, or entering any alleged violations.

Note: Agencies and companies can see different information in a complaint record. Certain fields are shared between the two different user types; others are only available to agency users.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/26/2020

Completing Preliminary Evaluation of a Complaint Introduction When entering a complaint, you have the option of sending it for preliminary evaluation. This functionality is helpful for when a higher profile complaint is being entered and may require further review before it is formally entered into SES. Some agencies may use this functionality if complaints are entered by administrative staff but must be reviewed by an official complaints staff member before it can be formally entered into SES.

Note: All users assigned to the Complaints group in SES can complete the preliminary evaluation of a complaint. See Managing Users for more information. Communication that preliminary evaluation of a complaint needs to be completed must be communicated outside of SES.

Completing Preliminary Evaluation of a Complaint 1. Click the Complaints tab.

2. Click Show Filters .

3. Select Pending for Status.

4. Click the Complaint ID .

5. Click Complete Preliminary Review .

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6. Make any desired changes to the complaint information and assign the Agency POC. 7. Select Proceed to Processing . 8. Click Submit Evaluation .

Note: You also have the option to close the complaint if it is a duplicate, invalid, or it was referred to another agency. See Sending a Complaint for Referral for more information.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

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Creating a Non-NMLS Entity

Introduction If you cannot find a record for the subject for your complaint in SES, you must create a non- NMLS Entity. Non-NMLS entities do not have a record in NMLS. Non-NMLS entity records are created by SES agency users to help identify the subjects of complaints who may be uncooperative or refuse to create an account in NMLS to formally comply to the complaints process in SES.

Note: Users assigned to the Complaints group in SES can create a non-NMLS entity. See Managing Users for more information.

Creating a Non-NMLS Entity 1. Click Enter New Complaint .

2. Click Search for Subject .

3. Use the icons at the top of the page to search by name, location, employee, keywords, phone number, or website.

4. Click I Do Not Have This Information to advance through the search options.

5. Search by name, location, employee, keywords, phone number, or website.

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6. Click Subject Not Found if the search results do not return the entity you are searching for and advance to the next search option.

Note: If you are unable to locate the desired entity using all search options, you are presented with the option to create a Non-NMLS Entity. It is recommended that you exhaust all search options before proceeding with creating a new Non- NMLS Entity to prevent duplicate entities. Consider reviewing the discussion (link to discussion article) for Non-NMLS Entities created by other agency users that have similar characteristics to the subject you are searching for to see more details about the entity.

7. Click Create New Non-NMLS Entity.

8. Complete the form.

Note: Entity name is the only required field, but adding as much detail as possible will help other agencies identify this entity when conducting a search for subject.

9. Click Save Entity .

Note: For help in using other agencies’ knowledge about non -NMLS entities, see the Using Discussion for Non-NMLS Entities article. For information about creating a complaint for a non-NMLS entity, see the Entering a Complaint article.

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Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

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Using Discussion for Non-NMLS Entities

Introduction A key feature when creating a Non-NMLS Entity is the Discussion page. This functionality works like current social media platforms and enables users to tag other complaints users across agencies to share details about an entity.

Note: Users assigned to the Complaints group in SES can use Discussion for Non- NMLS Entities. See Managing Users for more information.

Accessing the Discussion for a Non-NMLS Entity 1. Click Non-NMLS Entities .

2. Search for the desired non-NMLS entity by Entity Tracking Number.

Note: Click Show Filters to search by other criteria.

3. Click the Entity Tracking Number for the desired non-NMLS entity.

Note: The chat bubble icon in the Posts column indicates activity on the Discussion page for a non-NMLS entity.

4. Click Discussion .

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Using Discussion for Non-NMLS Entities Use the platform like any other social media platform or internet forum. You can enter comments, request information changes about the entity, and tag other users or agencies.

Selecting Request Info Change notifies the original agency that created the non-NMLS entity since only they can update the entity ’ s information in the system.

You can upload documents to your board posts. Also, if you or your agency is tagged in a post, you receive a notification.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Onboarding a Company User to SES Complaints Introduction Before you can send information requests (IRs) to a company in SES, you must initiate onboarding. Onboarding a company to SES initiates notifications inviting the company to join the system, so it is best practice to let the company know that they should anticipate emails from SES prior to initiating onboarding. For more information on company onboarding, see the articles in the NMLS/SES Customer Portal.

Note: All users assigned to the Complaints group in SES (except the account administrator) can onboard a company to SES. See Managing Users for more information.

Onboarding a company to SES Complaints

1. Click Company Search .

2. Enter the information for the company user you want to onboard onto SES.

3. Click Search .

4. Click the SES ID .

5. Click Initiate Onboarding in the top right.

Note: If the Initiate Onboarding button does not appear, then the company has already been onboarded to SES by another agency. You can also confirm this if there is an SA Contact and Complaint Contact assigned on the company record page.

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6. Enter the required information for the individual at the company who you would normally contact for complaints purposes.

7. Click Create New User .

Note: The newly created user receives an email from Okta instructing him/her to activate an Okta account. The user should refer to the Company Onboarding and Account Setup articles for more information.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Adding and Sending an Information Request for a Complaint Introduction After entering a complaint, you can send information requests (IRs) to the company associated to the subject. You can only send information requests to a company even if the subject of a complaint is a branch or individual.

Note: All users assigned to the Complaints group in SES can add information requests. See Managing Users for more information. Only the agency POC can send information requests to the subject of a complaint.

Adding an Information Request to a Complaint 1. Navigate to your complaint. 2. Click Information Requests > Add Information Requests .

3. Complete the information request form and upload any relevant documents.

Note: The documents uploaded at this stage of the information request process are expected to be downloaded by the company and used in relation to this specific information request (e.g., completion of a form).

4. Click Add to Queue .

5. Repeat steps 2-4 until you have added all desired information requests to the complaint. 6. Click the View Queue quick filter.

7. Confirm the information requests in the queue.

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Note: If you are an agency complaint user who is not the agency POC, once you confirm the IR, your only option is “ Save Information Requests. ” This adds it to the queue so the POC can then review and choose whether to send it to the company.

8. Select Continue to Sending . 9. Click Continue to Sending.

Note: You also have the option to save the information requests and continue adding more later.

10. Continue at step 3 below.

Sending an Information Request to the Company 1. Navigate to your complaint. 2. Click Send Information Requests .

Note: Only the agency POC for the complaint can send information requests to the subject of a complaint.

3. Enter a Bulk Due Date .

Note: All information requests are selected by default. Deselect an information request by clicking anywhere on the row. The bulk due date will be applied to all information requests that do not have a due date set. Update an individual due date by clicking on the due date link.

4. Click Click here to Validate the selected Information Requests .

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Note: This step validates the due dates entered for the IRs you selected to send to the company are in the future.

5. Enter comments to company (if applicable), upload necessary documents, and select whether you would like to be notified when the company responds to the IRs.

Note: The initial set of IRs accompany the complaint when it is first sent to the company. It is important that the company has been onboarded prior to sending the IRs so they are prepared to begin using the system. If the company has not completed the onboarding process, the system will prevent you from sending the IRs. The documents uploaded at this stage of the information request process are expected to be introductory documents that might help to explain the information request. Do not upload specific forms to be completed here.

6. Click Send Information Requests .

7. Click Confirm .

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Managing Information Requests for a Complaint Introduction SES allows you to update the due date for an information request (IR) to grant an extension. You can also cancel an IR if it is no longer applicable.

Updating the Due Date for an IR 1. Navigate to the desired complaint. 2. Click Information Requests .

3. Click the IR ID hyperlink for the desired IR in a Sent to Company status.

4. Click Update Due Date .

5. Enter the new due date. 6. Click Save Information Request .

Canceling an IR 1. Navigate to the desired complaint. 2. Click Information Requests .

3. Click the IR ID hyperlink for the desired IR in a Sent to Company status.

4. Click Cancel Information Request .

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5. Click Cancel Information Request .

Need more help? Contact the SES Call Center 1-800-699-0911

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Generating Company IR Responses for Complaints Training Program Introduction Once the information request is sent to the company, the next step would be to wait for the company to respond to the information requests (IRs). Because this is a training environment, no real company receives your information requests. To automate the process, we have put in place steps that allow you to respond to the IRs as the company. Follow the steps below to generate company IR responses.

Generate Company IR Responses 1. Click the waffle icon. 2. Select Generate Company IR Responses .

3. Click Search by Complaint ID .

Note: This form opens in a new tab in your browser. If you cannot remember the Complaint ID, check the previous tab to find it.

4. Enter the Complaint ID. Click Search .

5. Add any custom response text (optional). 6. Click Generate Company IR Responses .

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Note: IR Responses should appear in the previous tab once you refresh the page.

Need more help? Email rug@csbs.org

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Reviewing Information Request Responses for Complaints

Introduction Once a company responds to your information requests (IRs), agency complaint users can begin reviewing IR responses. See Managing Information Requests for information on canceling or updating the due date of an IR.

Reviewing IR Responses 1. Navigate to the desired complaint. 2. Click Information Requests .

Note: IRs that have received a response are indicated by a green check in the Status column.

3. Click the IR ID hyperlink.

4. From this screen, you can mark the IR response Quick Look Complete or send it back to the company.

Marking IR Response Quick Look Complete If the IR response is satisfactory, you can mark it Quick Look Complete. This signals to others helping you work the complaint that you have looked at the response and it meets your needs.

1. Click Quick Look Complete .

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Note: Marking an IR response Quick Look Complete informs other complaints users that the IR response has been looked at. The company does not get notified about this selection.

Click Remove Quick Look to revert the IR response to an unreviewed status.

Sending an IR Response back to Company In the case of an insufficient IR Response from a company, all users assigned to the Complaints group can return the response. This back-and-forth between you and the company can happen as many times as necessary until you have a response that is satisfactory. 1. Click Send Back to Company.

2. Provide a response explaining why the IR response is being sent back, uploading any necessary documents. 3. Click Send Back to Company .

Note: If a company’s response to an IR prompts you to think of more questions to ask, you can create and send more IRs to the company.

Need more help? Contact the SES Call Center 1-800-699-0911

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Adding Research and Communication to a Complaint Introduction The Research and Communication page is used to capture all communications related to a complaint that took place outside of SES. It is also used to document work and research that was done (e.g., capturing original complaint information found on the CFPB portal). This area is optional when processing a complaint, but is suggested as a best practice to use.

Note: All users assigned to the Complaints group in SES can add research and communication to a complaint. See Managing Users for more information.

Adding Research and Communication to a Complaint 1. Navigate to your complaint. 2. Click Research/Communication > Add Research/Communication .

3. Complete the research and communication form and upload any relevant documents.

Note: You can enter a description of communications (phone, mail, email, or in- person) for either the consumer or the subject.

4. Click Add Research/Communication .

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Updating a Complaint

Introduction After entering a complaint, information received from the consumer or the subject may require an update to what was entered into the system when the complaint was first created.

Note: All users assigned to the Complaints group in SES can update a complaint.

Updating a Complaint

1. Navigate to your complaint.

Note: You can update the complaint from the Summary or Details pages.

2. Click Update Complaint.

3. Make the desired updates to the Update Complaint section.

Note: The Agency POC can be updated at any point prior to the closure of a complaint.

4. Click Update Complaint .

Note: The subject of a complaint cannot be changed unless it is for a Non-NMLS Entity. If you need to change the subject of the complaint for an NMLS/SES

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company , close the existing complaint as “Invalid” and create a new complaint with the correct subject identified.

To change the subject of a complaint for a non-NMLS Entity , navigate to the complaint and click Update Subject .

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Entering Alleged Violations

Introduction As part of working a complaint, you can enter any alleged violations you may have discovered. Typically, these alleged violations are captured by complaints staff before escalating them to your agency’s investigation or examination team.

Note: All users assigned to the Complaints group in SES can enter and manage alleged violations for a complaint. See Managing Users for more information.

Entering Alleged Violations 1. Navigate to your complaint. 2. Click Alleged Violations > Add Alleged Violations .

3. Complete the alleged violation form.

Note: To add more than one alleged violation at a single time, click +Add Alleged Violation as many times as needed.

4. Click Save Alleged Violation.

Need more help? Contact the SES Call Center 1-800-699-0911.

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Closing a Complaint

Introduction After working a complaint, you can close it for several reasons. Typically, a complaint is closed once the complaint has been resolved (e.g., closed with explanation or monetary relief). You can also close a complaint because it was a duplicate or was found to be invalid. Or the complaint may be closed because it was referred to another agency or to an investigation team.

Note: All users assigned to the Complaints group in SES can close a complaint. See Managing Users for more information.

Updating a Complaint

1. Navigate to your complaint.

Note: You can close the complaint from the Summary or Details pages.

2. Click Close Complaint .

3. Select the close reason and enter any closure notes.

Note: Selecting Closed with Monetary Relief allows you to enter an amount and payment date.

Selecting Referred to Other Agency allows you to enter the state agency’s name. However, this does not refer the complaint to the agency. You must refer the complaint via the Related Actions page prior to closure. See Sending a Complaint for Referral for more information. If the agency you wish to refer the complaint to

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does not have any complaints users in SES, you must communicate the referral outside of the system.

4. Click Close Complaint .

Note: You cannot reopen a closed complaint to add an information request or alter any information.

Need more help? Contact the SES Call Center 1-800-699-0911.

Updated: 6/25/2020

Sending a Complaint for Referral

Introduction As part of working a complaint, you may realize that it needs to be referred to another agency (e.g., the consumer submitted the complaint to the wrong regulatory agency). You can only refer a complaint prior to information requests being sent to the company. If information requests are not sent to the company, you can refer a complaint any time prior to closure.

Note: All users assigned to the Complaints group in SES can refer a complaint to another agency. See Managing Users for more information.

Sending a Complaint for Referral 1. Navigate to your complaint. 2. Click Related Actions .

3. Click Refer Complaint to Another Agency .

4. Complete the referral form.

Note: You can only refer a complaint to another agency that has complaints users in SES.

If an agency has no active complaints users, you can close the complaint and in dicated the reason for closure as “Referred to another agency” and identify the desired agency there. See Closing a Complaint for more information.

5. Click Submit Referral .

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Note: All complaints users at the agency to which the complaint was referred receive a notification to accept or reject the referral. If the referral is rejected, you are notified, a nd the status of the referral is “Rejected” in the system. See Accepting or Rejecting a Complaint Referral for more information.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Accepting or Rejecting a Complaint Referral Introduction After working a complaint, another agency may refer a complaint to yours (e.g., the consumer submitted the complaint to the wrong regulatory agency). A complaint can only be referred to your agency prior to information requests being sent to the company or prior to closing the complaint if no information request is sent. Your agency can review the referral and choose to either accept or reject it.

Note: All users assigned to the Complaints group in SES can accept or reject a complaint referral.

Accepting or Rejecting a Complaint Referral 1. Click the Complaint ID hyperlink for the desired referral on the homepage.

Note: This home page will only display the five most recent referrals. The other way to get to a referral is to open it via the Complaints menu at the top of the screen. If the complaint record has an open referral, the status reflects "Referral in Progress" and the task is available to all complaints users on the Summary page for that complaint record.

2. Click the View Details icon in the Referral Details section at the bottom of the page.

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3. Review the full complaint record to determine if the complaint belongs with your agency. 4. Click Respond to Referral .

5. Select Accept or Reject and enter any response comments you may have.

Note: If you accept the request, you must select a Complaint POC.

6. Click Accept Referral or Reject Referral .

Need more help? Contact the SES Call Center 1-800-699-0911.

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Requesting Access to a Complaint

Introduction As an agency complaints user in SES, you have access to view basic information about complaints across all agencies. You can also request access to view the full details of another agency’s complaint .

Note: All users assigned to the Complaints group in SES can request access to view the full details of another agency’s complaint . The access request feature is not available for complaints that are in a pending referral status.

Requesting Access to a Complaint 1. Log in to SES. 2. Click Manage Complaints .

3. Click Complaints > All Complaints .

4. Select the Complaint ID hyperlink for the complaint you want to access.

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5. Click Request Access .

6. Enter any relevant comments. 7. Click Request Access .

Note: You can see the status of your request on the View Access page of the complaint record.

You are notified when the agency grants or rejects access to the complaint.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/26/2020

Accepting or Rejecting Access to a Complaint Introduction Other agencies can request to view the full details of a complaint owned by your agency. When your agency receives a request to view a complaint, all complaints users at your agency will be notified via email. Note: All users assigned to the Complaints group in SES can accept or reject access to a complaint. This gives each agency flexibility around who handles view requests. For example, the complaint POC can take ownership of the view request or a separate individual, like a supervisor, can make these decisions regarding all complaints at your agency. Be sure to discuss with your team who is responsible for this process at your agency. Accepting the request allows all requesting agency’s complaints users to view the entire complaint and preview and download all uploaded documentation.

Accepting or Rejecting Access to a Complaint 1. Click Access Request Report on the homepage of the SES Complaints application.

2. Click the View Details icon for the desired complaint access request.

3. Review the access request details.

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4. Click Review Access Request .

5. Select Accept or Reject and enter any comments you may have.

6. Click Accept Request or Reject Access Request .

Note: Your decision is reflected on the My Agency’s Decisions tab.

Once viewing access is granted, it does not expire. It is the responsibility of the complaints users at the agency to manage who has this extra level of access to their complaint. Viewing access can be removed at any time. See Removing Access to a Complaint for more information.

Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/25/2020

Removing Access to a Complaint

Introduction After granting another agency access to view the details of a complaint, you can remove the access at any time.

Note: All users assigned to the Complaints group in SES can remove another agency’s access to a complaint . See Managing Users for more information.

Removing Agency Access from a Complaint Record 1. Navigate to your complaint. 2. Click View Access.

3. Click the View Details icon for the desired complaint.

4. Click Remove Agency Access .

5. Click Remove Agency Access .

6. Click Confirm .

Note: Your decision is reflected on the Access History tab and a notification is sent.

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Removing Agency Access from the Access Request Report Page 1. Click Access Request Report on the homepage of the SES Complaints application.

2. Click My Agency’s Decisions .

3. Click the View Details icon for the desired complaint access request.

4. Click Remove Agency Access .

5. Click Remove Agency Access .

6. Click Confirm .

Note: Your decision is reflected on the Access History tab of the complaint record.

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Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

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SES Complaints – More about Consumer Complaint Subjects

Let’s talk more about the types of entities, users can create a complaint on using SES:

- Non-depository companies, branches, and individuals whose licenses are managed in NMLS. o This is because SES is linked to NMLS and its’ licensees are automatically populated into SES. - Non-depository companies, branches, and individuals who are licensed by your agency but are not managed in NMLS. o To identify these licensees as a complaint subject, the licensee must first complete the account request form in NMLS. Doing so will allow the NMLS link to bring the entity into SES (on the next business day). At which point, a complaint can then be created. ▪ Keep in mind, the licensee only needs to complete the NMLS account request form, they do not need to complete any additional forms in NMLS to proceed. - Non-NMLS entities. These are defined as unknown or unreachable entities that could be operating without a license. o Non-NMLS entities are created by agency complaint users with the purpose of enabling tracking of these entities across agencies. Since they are unknown or unreachable, you cannot interact with them using SES, but complaints can be created on these entities to inform other agency users of their reported activity. How about the other types of entities you may regulate? The following entity types cannot be the subject of complaints in SES today: - Depository companies and institutions. Although their registration exists in NMLS, depository companies and institutions cannot be identified as the subject of a complaint at this time.

Looking Forward

In the future, SES plans to expand functionality to include a public portal, allowing consumers to search for entities, initiate, and track their own complaints. SES will also enable you to enter and process complaints on depository companies and institutions.

Updated: 6/19/2020

Need more help? Contact the SES Call Center 1-800-699-0911.

Updated: 6/19/2020

SES Complaints – More about the Information Request Exchange

All agency complaint users can add information requests, or IRs, to the complaint, however only the agency point of contact (POC) assigned to the complaint can send the IR(s) to the company. The agency POC is the individual who initially entered the complaint or who was assigned as part of completing the preliminary evaluation. At any time prior to closing the complaint, the agency POC can be reassigned by updating the complaint details. It is important to note, the information request exchange in SES is only available for complaints on NMLS/SES companies and cannot be used for non-NMLS entities. Agency: Once the agency creates the information requests for the complaint, they can be sent to the company all at once or in multiple instances. - A specific due date can be set for each individual information request or a bulk due date can be applied to all information requests. - The due date for each request can be updated individually to provide an extension, if needed. - A request can be cancelled if the information is no longer necessary. - The description and documents uploaded for a request cannot be updated until a response has been received by the agency. Company: Once the company has responded, which can be done in multiple instances or all at once, they can no longer make changes to their responses unless the requests are sent back to the company by the agency. Agency: When reviewing the responses, the agency has a few different actions available depending on the quality of the responses received: • Good: If the response is satisfactory you can use the Quick Look Complete tag which signals to others helping you work the complaint that you have looked at the response and it meets your needs. Think of it like unread (bold) and read (no longer bold) emails. The Quick Look Complete tag is only seen by the agency and is not shown to the company. Once the information requests have been sent to the company by the agency, Let’s talk more about how the information request process works in SES.

Updated: 6/19/2020

• Try Again: If the company’s response does not meet your needs, you can send it back to the company asking them to try again. This back-and-forth can happen as many times as necessary until you get what you need to move forward. • Ok, but what about this: If the company’s response prompts you to think of more questions to ask, you can create and send more information requests to the company.

Need more help? Contact the SES Call Center 1-800-699-0911.

Updated: 6/19/2020

SES Complaints – More about Processing a Complaint

Processing a complaint includes:

• Documenting research and communication related to the complaint.

o The goal of this area of the complaint is to document and account for all activity that could occur outside SES. While we do not currently have consumer-facing functionality allowing a consumer to initiate a complaint, you can still track an email exchange or phone call between you and the consumer, or time spent researching on the CFPB’s complaint portal.

• Adding alleged violations identified through the review of the complaint.

o An alleged violation may reference a Federal or State regulation or statute, if applicable, and must include a description. In certain instances, complaints with alleged violations will get escalated to an investigation or examination team.

• Concluding your review by either closing or referring the complaint.

Here are few more details about the referral process in SES. • The referral process allows you to refer the complaint to another agency with active complaint users in SES. The receiving agency can then continue to process the complaint in SES. o Keep in mind, the receiving agency has the option to either accept or reject the complaint referral. If they choose to reject the referral, your agency continues to own the complaint and is responsible for processing it. o Also, it’s important to note that a complaint can no longer be referred to another agency in SES once an information request has been sent to the company. In the instance where an information request has been sent and you realize the complaint applies to another jurisdiction, the complaint can be closed. You would then communicate with the correct agency outside of SES and they would then create a new complaint.

Updated: 6/19/2020

The closure process is straight forward. • Closure reasons include

Closed with explanation

o

Closed with monetary relief

o

Closed with non-monetary relief

o

Duplicate

o

Invalid

o

o Referred to Investigation (at your agency)

o Referred to other State Agency (used when the receiving agency does not have users in the complaints system and therefore the referral process cannot be used in SES) • If the referral options are selected at closure, the referral to the appropriate agency must be communicated outside of SES so that a new complaint can be started by the agency, if applicable. The goal with providing these options at closure is to enable the agency to track all complaints they have processed. • At this time, aclosed complaint cannot be reopened by the agency. If new details surrounding the complaint resurface, a new complaint can be created to document these updates. Like most areas of the complaint system, all complaints users can process a complaint, including closing or referring a complaint as well as accepting or rejecting an incoming referral. You are encouraged to discuss protocols and coordinate with your complaint users to ensure work is not duplicated.

Need more help? Contact the SES Call Center 1-800-699-0911.

Updated: 6/19/2020

Viewing a Complaint

Introduction When a complaint is entered into SES and information requests are sent to your company, you can view the details in the system.

Note: Users must be assigned to the Complaints group in SES to view a complaint. See Managing Users for more information.

Viewing a Complaint 1. Log in to SES.

2. Click Manage Complaints .

3. Click the Complaint ID hyperlink.

Need more help? Contact the SES Call Center 1-800-269-6189.

Updated: 6/19/2020

Assigning and Reassigning the Complaint POC

Introduction When a complaint is received for your company, you must assign a point of contact (POC) for the complaint.

Note: Only the user designated as the SES Complaints Contact receives the task to assign a complaint’s POC. See Company Onboarding for more information.

Assigning the Company POC 1. Click the Assign Point of Contact task on the homepage.

Note: The company’s SES Complaints Contact also receives an email with a link to the task.

2. Review the complaint information. 3. Select the Company Point of Contact at the bottom of the page.

Note: Only users in the Complaints group in SES appear in this list. See Managing Users for more information.

4. Click Submit .

Updated: 6/19/2020

Reassigning the Subject POC Beginning with the New Hampshire SES Release in August 2020, once a POC is assigned to a complaint, that user can reassign it to another user at the company.

Note: Your company’s SES account administrator and the complaints contact can also reassign the subject POC.

1. Log in to SES. 2. Click Manage Complaints .

3. Click the Complaint ID hyperlink.

5. Click Reassign Subject POC .

6. Select the Company Point of Contact at the bottom of the page.

Updated: 6/19/2020

Note: Only users in the Complaints group in SES appear in this list. See Managing Users for more information.

7. Click Reassign POC.

Need more help? Contact the SES Call Center 1-800-269-6189.

Updated: 6/19/2020

Responding to a Complaint Information Request Introduction Agencies can send information requests (IRs) regarding a complaint through SES. This article explains how to respond to those information requests.

Note: All users in the complaints group in SES can draft IR responses, but only the point of contact (POC) can send IR responses to the agency. See Managing Users and Assigning and Reassigning the Complaint POC for more information.

Responding to a Complaint Information Request 1. Log in to SES. 2. Click Manage Complaints .

3. Click the Complaint ID hyperlink.

4. Click Information Requests .

5. Click the IR ID hyperlink for the desired information request.

Updated: 6/19/2020

6. Click Respond to Information Request .

Note: You can also assign the information request to other users in the complaints group in SES by clicking Manage Assignment .

7. Select the Available Next Action . 8. Click Send to Agency .

Note: Only the subject POC for a complaint can send an IR response to the agency. If you were assigned an IR and have completed your work, you can indicate to the subject POC that it is ready to send to the agency by selecting Mark Response as Complete.

Need more help? Contact the SES Call Center 1-800-269-6189.

Updated: 6/19/2020

Updating the Complaints Contact

Introduction The complaints contact is the user for a company that receives notification when a complaint is entered and information requests are sent. The complaints contact also receives the task to assign a subject point of contact (POC) for each complaint entered into the system. This article explains how to update the user assigned as the complaints contact, should it need to be changed.

Note: Only the SES company account administrator can update the complaints contact.

Updating the Complaints contact 1. Log in to SES. 2. Click Manage Company Profile .

3. Click Assign Contacts .

4. Select the updated Complaints Contact. 5. Click Assign Contacts .

Note: Only individuals with SES accounts assigned to the complaints group appear in this list. See Managing Users for more information.

Updated: 6/21/2020

Need more help? Contact the SES Call Center 1-800-269-6189.

Updated: 6/21/2020