- within Finance and Banking topic(s)
- with Inhouse Counsel
- in United States
Background
A financial institution was accused of charging excessive or unfair overdraft fees that allegedly caused significant financial burden on its customers. This overdraft fee practice attracted regulatory scrutiny, resulting in a consent decree between the institution and the Consumer Financial Protection Bureau (CFPB). The consent decree required the institution to pay fines and reimburse its customers for overdraft fees paid within a known time frame. This situation led to a broader conversation within the banking industry regarding overdraft fee best practices.
Given the large scale of the remediation effort as required by the consent decree, and in order to preserve goodwill with the institution's current and former customers, the institution required the help of Ankura's expert resources to support a smooth, punctual, and consumer-friendly execution of the remediation plan.
Ankura's Involvement
Ankura provided expert services in support of the full remediation lifecycle. These services began with the ingestion and analysis of large volumes of data to investigate and confirm customer eligibility and resulted in the distribution of redress to hundreds of thousands of account holders. Through the end-to-end remediation process, Ankura:
- Set up a public remediation website with relevant program information and interactive tools for consumers to securely confirm eligibility and view their refund amount and affected transactions. In tandem, Ankura developed scripting and protocols for, stood up, and managed a contact center to provide voice, email, chat, and webform support.
- Worked with trusted printer partners to design checks/letters and coordinate magnetic ink character recognition (MICR) line and payee name verification testing, to ensure check security.
- Performed skip tracing / address research on account holders to ensure effective delivery rates. Following mailing, Ankura tracked and processed returned mail and check re-issuance requests.
- Managed and audited the remediation funds bank account, including implementing and monitoring various anti-fraud controls.
Value Delivered
Established best practices that can be applied in subsequent remediations.
Worked across business groups to liaise with key stakeholders and cut through red tape to efficiently manage all aspects of a remediation program.
Provided additional operational capacity to allow the institution to focus on the big picture and core business operations.
Enhanced strategic decision-making by offering expert insights that drive innovation within the institution.
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