2017 Citi Complaint Training Attorneys Collectors 2 Overview

2017 Citi Complaint Training Attorneys & Collectors

2 Overview Confidential

Overview of Training 3 This training will cover Citibank’s policy and process for handling complaints received on the phone. After this training you will be able to: Identify complaint trigger language Identify what is a complaint Identify what is not a complaint How to escalate a complaint How to properly document the complaint Confidential

4 Citibank Complaints Confidential

How To Identify a Complaint 5 The term Consumer includes any individual who is: A current or former customer of a Citi product or service; or Impacted by a Citi financial product, service or asset, including an individual who does not have a Citi financial product or service; or Applying for a product or service (i. e. "Potential Consumer") Confidential

How To Identify a Complaint (Cont. ) 6 In addition to the verbatim and example phrases provided on the next few slides, you should also consider the demeanor as potential signs of dissatisfaction such as: Tone or an increase in volume Voice inflection or an increase in pace of speech Communication style Continued repetition of key words by the consumer Confidential

Complaint Types & Triggers 7 Over the next few slides specific complaint types & verbiage will be covered. Confidential

Complaint Types & Triggers (Cont. ) 8 A Complaint Has: Expressions of Dissatisfaction Example Verbatim Example Triggering Phrases • "I want to file a Complaint" • dissatisfied • “I am unhappy about…” • ridiculous • Wrongdoing • "I had a terrible experience with. . . " • sick of this • Consumer displeasure • "Citi screwed this up“ • disappointed • Request for escalation / speak to supervisor • "This was not what I requested“ • frustrated "I'm really annoyed by this" getting no where Threat to file regulatory complaint • • • "You are going to lose a customer" • want a manager Dissatisfaction as it relates to • • • "I'm going to notify the CFPB" • how can that be • Point of sale (POS) card declines • "This is crazy" • unacceptable • "I'm extremely frustrated with this" • annoyed • "You are harming me" • that is crazy • "Very disappointed in Citi" • unbelievable • "I want to speak to a supervisor/ manager / Executive Office / Executive / Member of your Operating Committee“ • unhappy • upset • harm me • "Your manager needs to call me back“ • "You embarrassed me when you declined my card" Confidential

Complaint Types & Triggers (Cont. ) 9 A Complaint Concern Has: An allegation of unacceptable employee behavior • Language related • Activity of the employee • Treatment of customer Example Verbatim Example Triggering Phrases • "Agent was rude and offensive" • ignored • "Used derogatory language" • inappropriate treatment • "Treated me second class" • offensive • "They didn't believe me" • impolite • "Employee (name) just ignored me" • didn't listen • "The agent hung up on me" • harass • "Lied to me" • lied Confidential

Complaint Types & Triggers (Cont. ) 10 A Complaint Has: Product issue including product design or performance • The customer's issue could indicate a systemic/pervasive issue • Inherent flaw not previously identified • Barriers to termination • Consumer access to information Example Verbatim • "I've called four months in a row to get my benefit" • "I got this product/service because it was supposed to. . . " • Example Triggering Phrases • multiple times • tried to cancel • doesn’t/won't work "I'm being prevented from cancelling" • I keep calling • "I never got my reward points as promised" • I have tried multiple times • "Your website doesn't work and now I got charged a fee" • no benefit • "Your system did not process my payment on time" • "This product hasn't helped me at all“ • "My card keeps getting declined over and I'm sick of it" Confidential

Complaint Types & Triggers (Cont. ) 11 A Complaint Concern Has: Sales, service or marketing practice Example Verbatim Example Triggering Phrases Sales: • "I never signed up for (Product or Service)" • they told me • "I thought I was signing up for X but instead they gave me Y" • I wasn’t told • wouldn’t /won’t stop • you didn’t do • I didn’t sign • I didn’t approve • I was never given • I don’t see where it says that • no help • Aggressive sales or tactics • Lack of follow up Marketing: • System issue • • Bait and switch "That advertisement was confusing and didn't understand what I was signing up for" • Misinformation / Misrepresentation • "I was led to believe something different" • Disclosure of information • "They said this is the best interest rate anywhere but. . " • Terms/features/teasers Servicing: • Telemarketing • "You promised you would notify me when. . " • it seemed like • Cancellations (Dissatisfaction causing cancellation or with Citi cancelling) • "You never did what I requested" • confused (beyond clarification) • "The employee told me I could do this" • you never told me • "It doesn't say I need to do that anywhere" • "I have attempted to get this resolved multiple times/four months in a row" Cancellation: • "I want to cancel because this never works like I thought" • "You should not have cancelled my account" • "I'm cancelling because I don't want to deal with Citi anymore" Confidential

Complaint Types & Triggers (Cont. ) 12 A Complaint Concern Has: Example Verbatim Problem with handling and resolution (e. g. , multiple hand-offs, excessive time lag) 'Problem handling & timeliness of resolution: • multiple transfers "I have been transferred to four different agents and I'm not getting what I need" • longer than promised • didn't take care of • Problem handling • Timeliness • Consumer dissatisfaction with prior handling or resolution • Example Triggering Phrases • "This is taking longer than what you promised • me" was supposed to be resolved • "I spoke to Employee (name) who assured me this was resolved and it is not" • disagree with credit bureau resolution • won't call me back • "No one has returned my phone call" or "I was never contacted as promised" Confidential

Complaint Types & Triggers (Cont. ) 13 A Complaint Concern Has: Disagreement with industry dispute/resolution practices and inappropriate Collection & Recovery activities • Disagreement with result of industry dispute/resolution practices • Failure to comply with collection activity requests or inaccuracies Example Verbatim Disagreement with result of industry dispute/resolution practices: *Any subsequent contact by the consumer expressing dissatisfaction over the resolution or response to the dispute above will result in a Complaint such as: • "Its taking you way too long to resolve this billing dispute" • "I disagree with the outcome of my dispute" Collections & Recovery examples: Dissatisfaction with the failure to comply with collection activity requests or inaccuracies identified during collection & recovery interactions shall be identified as Complaints. • "I am not your customer and if I don't owe this debt, you are collecting on the wrong person" • "I've told you to stop calling me at work" • "I have already paid my debt, stop calling me" Confidential Example Triggering Phrases • disagree with dispute outcome • I’m not the right person • I don’t owe anything

Complaint Types & Triggers (Cont. ) 14 A Complaint Concern Has: Dissatisfaction related to the Fraud process or experience Example Verbatim • “My card was declined and I told you I was traveling to Mexico /making a large dollar charge. ” • "I have been declined several times in the last few months/weeks" • Dissatisfaction with decline if customer proactively contacted Citi for travel and or large purchase plans • “I am upset that I was required to call back from my home phone number when I needed to use my card earlier. ” • Authenticated customer expresses dissatisfaction with authentication method or experience (prior or current) • “I was never told about my card being closed for compromise until I received the new cards. ” • • Dissatisfaction related to compromise communications or the auto-reissue process/experience “I’m upset that you closed my account before even sending me a new card. ” • “I did not receive a text message upon being declined as I was supposed to be. ” • Security closure process or experience • • Method of communication “My card was declined and you didn’t call me until two days later. ” • Delay in contact to the customer • “I’m upset that I did not receive an immediate notification upon being declined. ” • Communication is inaccurate or confusing • Inability for customer to self-service Confidential Example Triggering Phrases • I had told you • Unable to use a product • You were supposed to know • Continually declined

Complaint Types & Triggers (Cont. ) 15 A Complaint Concern Has: Example Verbatim An allegation related specifically to Fair Lending/Discrimination: Lending/Fair Banking principles or • "You are discriminating against me" discrimination • "This is because I am black / white / Asian / • Fairness/Deceptive (UDAAP-Unfair, Deceptive, or Abusive Acts or Practices) • Discrimination • Protected classes/adverse treatment old / young / disabled / minority / income / religion, etc. " • "You are treating me this way because I am (protected class)“ Example Triggering Phrases Examples of Fair Lending/Discrimination: • discriminated against • treated differently • predatory • not treated equally Examples of Fair Banking (UDAAP/TCF): Fair Banking (UDAAP/TCF-Treating Customers Fairly): • "This is unfair, these fees are too high" • "I was misled to believe" • "What you're doing to me is completely unfair" • "Why am I being treated this way" • "I was told one thing but you did another" • "I was never told" • "You are exploiting your capabilities" • "There's no way I could have avoided this" • "I paid for this benefit, and you're not letting me use it" • "Taking advantage of me" Confidential • unfair • abusive • deceptive • confusing / don't understand (beyond clarification) • mislead • frustrated • mistreated • making it impossible • deceiving • this is so difficult

Complaint Types & Triggers (Cont. ) 16 A Complaint Concern Has: An allegation of a violation of law or regulatory requirement • Specific law/regulatory citation Example Verbatim Complaints that require escalation to Level 3: Example Triggering Phrases • any specific regulation or law • person affected by a specific regulation (disabled, military, etc. ) • "You overcharged me according to RESPA" • "You violated my right to privacy" • "According to FDCPA, you can't call me after • 9 pm" • • "Your branch does not accommodate people with disabilities" • "I am in the military and have not been receiving the correct interest rate on my loan as previously promised" • "I have asked you to stop contacting me with solicitations or marketing information but you keep calling/mailing/emailing me" Complaints/Concerns which do not require escalation to Level 3: • "that's against the law" (without mention of an unlawful act) • "you are in violation of my rights" (without mention of the violation) • "I received collection calls on Sunday" Confidential violated (and indicating the law) against the law (and indicating the unlawful act)

What is a complaint (cont. ) 17 Customer Complaints Customer “Complaints” are written or verbal submissions by a customer that express dissatisfaction with, or communicate suspicion of wrongful conduct by a practice or act of the Service Provider or Citi regarding the customer’s personal experience with the financial product or service. The collector should be versed in listening to the customer/consumer in order to pick up key words, phrases, and language to assist in identifying dissatisfaction, and to ensure satisfaction in the resolution.

Complaint Types & Triggers (Cont. ) 18 Debt Management Complaints Citi must be notified of all complaints received by the Service Provider from a customer, attorney, third party, or any other party regarding debt management companies. Whether the communication is verbal or written, Citi wants to be made aware of any allegations that allege violations of federal, state, and/or local laws. This is to control and identify debt management companies in the industry that are not adhering to debt management legislation. Confidential

What is NOT a Complaint 19 Service Requests, Inquiries & Feedback Not all consumer interactions where there is a request for action from the consumer are considered Complaints. Specifically, the following categories of interaction are not Complaints. The following slides will contain examples of noncomplaint items. Confidential

Inquiries 20 Inquiries are requests for information from the consumer that do not contain an expression of dissatisfaction. Consumer inquiries may include questions regarding existing accounts, and general requests for information. The request does not have an expression of dissatisfaction. Confidential

Service Requests 21 Service Requests are requests to perform account maintenance, execute a transaction, or perform other routine servicing requests of a similar nature, provided that the request does not have an expression of dissatisfaction. An initial contact or notification regarding a dispute that follows industry practices and resolution processes prescribed by consumer protection laws is defined as a Service Request. Credit Bureau reporting requests or disputes Initial allegations of fraud, account takeover or identity theft Merchant billing disputes Validation of Debt if it is an initial request Collections – An expression of dissatisfaction because a consumer is appropriately in Collections is not considered a Complaint Subsequent contact by the consumer expressing dissatisfaction over the handling, resolution, or response to the disputes will be treated as a Complaint. Confidential

Feedback 22 Feedback is information about a product or service provided by or on behalf of a consumer used as a basis for improvement. The customer/consumer presents the information for improvement or in the form of a suggestion to change existing activities without an expression of dissatisfaction. Confidential

A Complaint is not: 23 A Complaint is not: Routine service requests Example Verbatim • "I want to open a new account" • "I'd like to execute a transaction" • Account maintenance • "I want to make/stop payment" • Transaction processing • "I want a replacement card" • Consumer assistance • "Can you resend my statement? " • Card declines • "Please update my contact information? " • "Can you lower my interest rate? " • "This interest rate is higher than my friend's" • "These fees should be refunded because I have been a good customer" • "My card doesn't work or was declined" Confidential

A Complaint is not: (Cont. ) 24 A Complaint is not: Question (inquiry) or asking for clarity Example Verbatim • "Can you explain to me…" • "When are you open? " • Comprehension • "Why didn’t …. happen? " • Seeking clarity • “Can you help me? " • "Why were these fees charged? " • "I thought I was supposed to have zero percent interest rate" • "Can you lower my interest rate? " • "Why was my credit line reduced? " • "Will you notify me when that occurs? " • "What day is my payment due? " • "What is my balance? " • "Why has my loan not closed yet? " Confidential

A Complaint is not: (Cont. ) 25 A Complaint is not: Feedback Example Verbatim • "Can I suggest…" • "I wish you had…" • Suggestions • "These fees are not competitive" • Opportunities • "I would like the branch to be open later" • Consumer opinions • "The call center should be open on Saturday" • Commentary regarding our value proposition or lack of competitive terms • "This offer to sign up is not good enough“ • "It would be nice if your product did…. " Confidential

A Complaint is not: (Cont. ) 26 A Complaint is not: Cancellations • Not caused by dissatisfaction (i. e. life events, personal credit decisions) Example Verbatim • "I just don't use the card anymore" • "I have too many credit cards" • "I've never used this product" • "I can't afford this anymore" • "I want to eliminate this payment" Confidential

A Complaint is not: (Cont. ) 27 A Complaint is not: Current Events Example Verbatim • "We were affected by Hurricane Katrina and want to defer our payment" • Natural disaster • "I saw the ad on TV and want my rate lowered" • Industry wide event • • National advertisement "My card was compromised in the Home Depot breach and I need to block the account" Confidential

A Complaint is not: (Cont. ) 28 A Complaint is not: Example Verbatim Industry dispute/resolution practices: Request/inquiry that follows industry dispute/resolution practices and Collection & Recovery activities • "My credit bureau report is inaccurate" • "My account is not delinquent" • "I've been current on paying my account but my CBR shows it as delinquent" • Credit Bureau Reporting related (i. e. Request to amend or dispute) • Billing or Transaction disputes • Request to open fraud investigation • "I did not make these transactions" • Unauthorized or Incorrect Electronic Funds Transfers • "Costco charged me twice" • QWR, NOE, and RFI typically related to mortgage servicing • "My card was stolen" • Collection/recovery activity • "I think someone has my account information" • "I'd like to file a claim" • "I don't want any more calls (Cease & Desist)" – can include collections related calls Collections & Recovery Examples: 'If a Consumer expresses dissatisfaction because they are appropriately in collection or recovery, it should not be considered a complaint. • "I don't want to pay this debt" Confidential

A Complaint is not: (Cont. ) 29 A Complaint is not: Example Verbatim Fraud Communications that follows industry practices and activities • "My card was declined: • "I shouldn’t have to verify with any more information. ” • "I do not want to close my account; I have too many auto billers tied to this account. ” • General dissatisfaction associated with POS interruption • Dissatisfaction with need to complete additional verification (per policy) • "This is the second security close I have had to take this year due to compromise; this is very inconvenient. ” • Inability to pass verification • • Need to close account due to high risk "I am upset that you cannot tell me which merchant my card was compromised. ” • Multiple compromise reissues • " I don’t want you to close my account even though • Inability to release merchant name associated with breach • it was compromised" • Required to close account • "You should have caught these fraud transactions sooner. ” Allowing Fraud to occur • • "You should have contacted me first before declining me. ” • No Contact prior to decline Confidential

30 Escalation and Documentation Confidential

Escalation Levels 1 -2 -3 31 Citi organizes all Complaints into one of three Escalation levels Level 1 = Agent/Collector Resolution Level 2 = Manager Resolution Level 3 = Upper management or Compliance Attorney or VBCS Resolution

Level 1 32 Level 1 Complaint - Collector is able to resolve the complaint with customer while the customer is still on the phone with the collector. If Collector is unable to resolve it must be escalated to Level 2 The Collector is required to Escalate the following complaints after one opportunity to de-escalate. If the customer/consumer requests to speak to a manager and after one attempt to de-escalate (the Collector asks once more if the collector can solve the issue) still wants to speak to a manager or supervisor If the customer/consumer requests to be escalated directly to an Attorney or Level 3 function, with one opportunity to de-escalate by offering to personally assist or transfer to Level 2.

Level 1 33 The collector may attempt to resolve a Complaint/Concern before escalation if: The customer/consumer is amenable to the employee attempting to research and resolve; if not, the collector will escalate as required After resolution is provided, the collector confirms with the customer/consumer that s/he has effectively addressed the customer’s/consumer’s Complaint/Concern and the customer/consumer no longer requests escalation. Ask “Have I Resolved your Concern or Complaint ? ” This should be titled as a Level 1 Resolution in JST. Examples: CM states never gets ahold of anyone when they called but finally got through and collector helped them. CM states why wont you settle for x bcs other creditors will but at end of call the CM settles account.

Level 2 -3 34 If the Collector could not resolve the complaint it is then escalated and should be noted on JST as Escalated to level 2 or 3. Level 2 - Manager Resolution (collection manager or lead) TMLG must send an Acknowledgment letter for all complaint not resolved at the initial point of contact All Level 2 Escalations MUST be resolved within 3 days. Level 3 - Attorney or Citi Resolution. Include Direct Escalations, Regulatory channels, Filed litigation or those that could not be Resolved in level 2. All level 3 Escalations must be resolved within 15 days.

Direct Escalation 35 All Collectors are required to escalate the complaint/Concern directly to level 3 with no De-escalation attempts allowed if: The Contact relates to or already is in Complaint or dispute status. Communications is from regulators, or is from a Local, State, or Federal Agencies, Attorney General, State Bar, or Direct Suit against TMLG. Commination was directed at or to an executive, board, president, operating committee, level 3 attorney, or specifically acts to speak to Harry Moore Communication is from the Better Business Bureau Communication From a Special interest or Consumer advocacy group as CFPB. Complaints/Concerns that directly allege a violation of Specific Law, Regulation threat of suit Regulatory Complaint, violation of FDCPA. All Direct Escalations should be Noted on JST as “Direct Escalation to Level 3”. All Non-Direct Escalations should be attempted to be Resolved at the level 1 Escalation Stage.

Complaint Documentation 36 Identify Escalation Level 1 or Note as Escalated to level 2 or Note as Direct Escalation to level 3 If Escalation to level 2 or 3 is Required Collector notes must contain sufficient information regarding the complaint and attempts to resolve or specific request of consumer. This information is needed for the Acknowledgment letter which must include Contact Details-Brief description of the complaint and Concern Estimated timeframe for follow-up or resolution Way to contact Service provider regarding the complaint/Concern

Complaint Documentation 37 Document all details of the complaint including specific statements made by the consumer in JST by using TMLG Intranet. Reference the work instructions on TMLG Intranet on how document and escalate a complaint—see next slide. Confidential

Complaint Documentation (Cont. ) 38 All of this information is located in the Support section of the Intranet under the Complaints— see below. Confidential

39 Questions? Confidential