Complaints e-Book

Complaints eBook

Updated: 7/2/2020

Introduction to the SES Complaints Training

Updated: 7/2/2020

Dear Regulator, Welcome to the SES Complaints Training Program ! This program teaches users how to use the Complaints application in the State Examination System (SES), an online tool that facilitates supervisory processes between state agencies and companies. SES offers a standardized and automated experience for all users, supports information sharing between agencies, and fosters general transparency of the complaints process. Program Overview This self-paced three-hour training program prepares regulators to successfully create, process, and close a complaint in the SES production environment. Each of the topics within this program is built into 45-minute modules that include:  System navigation resources;  Knowledge check questions; and  A hands-on practice experience using the SES training environment. Note: To complete the hands-on practice, you will need a login packet to the training environment that has been provided to your agency. The How to Use the SES Training Environment Login Packet guide provides more details around this process.

The structure of this program is as follows: 1. Getting Started

a. SES Complaints Training Welcome Letter (this document) b. How to Use the SES Training Environment Login Packet

2. Modules

a. Entering a Complaint b. Completing the Information Request Exchange c. Processing a Complaint d. Sharing a Complaint

Program Completion Once you have completed the training, please share your certificate of completion with your Account Administrator and they will provide you with access to the SES production environment. Please also inform your Complaints Training Contact so that your login packet can be distributed to the next learner. On the following pages you will find a set of Frequently Asked Questions (FAQs) and the Module Navigation Guide. Review these resources before continuing the program so you are prepared to complete the program. Need Help? As you complete each module, you may have questions or need assistance. Don’t hesitate to contact the support team at sestraining@csbs.org.

Sincerely, SRR Technical Learning & Development Team

1 | P a g e

More About SES and Consumer Complaints

Is the Consumer Complaints application its own system within SES?

Yes, the Consumer Complaints component and the Supervisory Activity component of SES talk to each other and share data. For example, agencies can view the count of complaints within the scheduling module which provides a quick link to the company record where you can see the complaints details.

Is it possible to update or escalate a complaint into an investigation or an exam to the point where the complaint IRs get transferred into the SA record?

No, not currently. In SES, users may connect a complaint to a supervisory activity (exam or investigation) at the time the exam is set up, or later by editing the basic exam details.

If a complaint does find there is a violation of state or federal guidelines, will we be able to issue a letter / action to the company via the complaints system prior to closing the complaint? As the functionality stands today, you could potentially send the letter through the information request feature and ask the company to acknowledge receipt of the letter by responding back to your information request. Otherwise, this will need to be done outside of the system.

What does it mean to be added to the “Complaints Group”?

The Complaints group is a permission that allows users to view or manage complaints in SES. As of the latest system release (8/21/21), users who exclusively use SES Complaints only need to be assigned to the SES Complaints group. They do not need to be assigned a supervisory activity role. A single user can only hold one role within the SES Complaints group. Below is a summary of the Complaint roles:

Role

Complaint Supervisor

Complaint Manager

Complaint Viewer

Description

Has all permissions and receives all notifications for all complaints. Responsible for accepting or rejecting complaint access requests from other agencies.

Has all permissions for all complaints except for the ability to accept or reject access requests to a complaint. Does not receive notifications from the Discussion Board when “All Agency” is tagged in a post.

View-only access to all complaints. Does not receive any notifications and cannot take any actions.

Updated: 8/20/2021

How do I access SES? Is this the same as the SES training environment?

The functionality for SES and the SES training environment is the exact same but the URLs are different. To login to the real or “production” environment, navigate to sso.nmls.org. To prepare and practice what you learn in the SES Complaints Training program, navigate to the SES Training Environment at https://ses-training.appiancloud.com/suite/portal/login.jsp. Here you will use the login credentials found in this eBook.

Updated: 3/25/2021

Regulator Training Accounts Please choose one account below to use for the entirety of the training program. You can select any agency account – it does not need to be the same as your actual agency . It is highly recommended that you store your username and password in a convenient location so it is easy to access throughout the program. Also, please be considerate of others. These accounts are shared across all agencies. To prevent unintentionally interrupting other users, be sure to track your complaint IDs and only act on your own complaints. Thank you for your cooperation!

SES Training Environment Case-sensitive Password for All Accounts: Test123!

Username (case-sensitive)

Name (owner) of SES Account

Agency Name

Connecticut Department of Banking

CT-DOB.complaintsuser1 CT-DOB Complaints User 1

Connecticut Department of Banking

CT-DOB.complaintsuser2 CT-DOB Complaints User 2

Hawaii Division of Financial Institutions

HI-DFI.complaintsuser1

HI-DFI Complaints User 1

Hawaii Division of Financial Institutions

HI-DFI.complaintsuser2

HI-DFI Complaints User 2

Idaho Department of Finance

ID-DOF.complaintsuser1

ID-DOF Complaints User 1

Idaho Department of Finance

ID-DOF.complaintsuser2

ID-DOF Complaints User 2

Indiana Department of Financial Institutions

IN-DFI.complaintsuser1

IN-DFI Complaints User 1

Indiana Department of Financial Institutions

IN-DFI.complaintsuser2

IN-DFI Complaints User 2

Office of the State Bank Commissioner of Kansas KS-OSBC.complaintsuser1 KS-OSBC Complaints User 1

Office of the State Bank Commissioner of Kansas KS-OSBC.complaintsuser2 KS-OSBC Complaints User 2

Maryland Commissioner of Financial Regulation MD-OFR.complaintsuser1 MD-OFR Complaints User 1

Maryland Commissioner of Financial Regulation MD-OFR.complaintsuser2 MD-OFR Complaints User 2

Montana Div. of Banking & Financial Institutions MT-BFI.complaintsuser1

MT-BFI Complaints User 1

Montana Div. of Banking & Financial Institutions MT-BFI.complaintsuser2

MT-BFI Complaints User 2

Nebraska Department of Banking and Finance

NE-DBF.complaintsuser1 NE-DBF Complaints User 1

Nebraska Department of Banking and Finance

NE-DBF.complaintsuser2 NE-DBF Complaints User 2

Ohio Department of Financial Institutions

OH-DFI.complaintsuser1

OH-DFI Complaints User 1

Ohio Department of Financial Institutions

OH-DFI.complaintsuser2

OH-DFI Complaints User 2

Vermont Department of Financial Regulation

VT-DFR.complaintsuser1

VT- DFR Complaints User 1

Vermont Department of Financial Regulation

VT-DFR.complaintsuser2

VT- DFR Complaints User 2

West Virginia Division of Financial Institutions

WV-DFI.complaintsuser1 WV-DFI Complaints User 1

West Virginia Division of Financial Institutions

WV-DFI.complaintsuser2 WV- DFI Complaints User 2

Updated: 4/2/2021

SES Complaints Training Frequently Asked Questions (FAQs)

This resource provides answers to questions commonly asked by Regulators who are completing the SES Complaints training program.

How do I log into the SES Training Environment? SES Training Environment . Your agency has been assigned two login packets to be used for the Complaints Training. Please contact your agency’s Complaints Training Contact if you have not received one of these packets. If you have trouble using the packet, consult the How to Use the Training Environment Login Packet resource in theGetting Started section of this program. How do I get help throughout the training program? For specific questions about this training program, contact the SRR Technical Learning & Developmentteam by sending an email to sestraining@csbs.org. For questions about SES functionality and post- training support, you can contact the Regulatory User Group (RUG) Call Center by calling 1-800-699- 0911 or emailing rug@csbs.org. Do I have to be logged into the NMLS/SES Customer Service Portal to access the knowledge articlesfeatured in the modules? No. Although the SES Complaints knowledge articles are stored in the NMLS/SES Customer Service Portal we have compiled a Complaints eBook for your convenience while completing this program. Youdo not have to be logged into the portal to access the eBook. After I click Start to begin a course, what should I do next? The course will open and play in the same window. Depending on the speed of your internetconnection, you may see a black rectangle for several seconds before the content appears. I have waited for the content to load for over a minute and still do not see it. What should I do next? If the content does not load, please clear your browser cache. This will erase any unused stored browsermemory. Instructions for doing so in Chrome and Internet Explorer are linked. If your issue persists, please contact the SRR Technical Learning & Development team by sending an email to sestraining@csbs.org.

The content window appears small. How do I expand it? Use the expand icon (

) at the top right corner of the course player to expand to a full

screenversion of the course.

Once I click Exit at the end of module, how do I know whether I have completed the course? Once you click exit, you will be directed back to the course overview page. Navigate to the History tab toview your completion record.

Updated: 3/25/2021

Complaints eBook Navigation Guide

To see available actions, hover over each button. For more details, consult this document.

1. Table of Contents 2. Multiple page view 3. Notes 4. Share eBook 5. Print eBook; choose “custom range” to print the entire eBook

6. Download eBook Note: Materials viewed online automatically update when changed. If downloaded or printed, please revisit the online version and re-download or print periodically to view latest system updates.

7. Mute/unmute page sounds 8. Full screen mode 9. Page zoom 10. Add a page specific note 11. Search eBook

Module 1:

Entering a Complaint

Updated: 6/29/2020

SES Complaints – More about Consumer Complaint Subjects Let’s talk more about the types of entities, users can create a complaint on using SES: - Depository or 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. - Depository or 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. 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. Need more help? Contact the SES Call Center 1-800-699-0911.

Updated: 9/18/2020

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 with the Complaint Supervisor and Complaint Manager roles can initiate a complaint. See SES Agency System Roles and Groups for more information.

You can enter a complaint for depository or non-depository companies, branches, and individuals whose licenses may or may not be managed in NMLS, as well as Non-NMLS entities. See SES Complaints - More about Consumer Complaint Subjects for more information.

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

1. From the SES homepage, click Manage Complaints or click the waffle icon and select Complaints .

Updated: 8/20/2021

Note: Either selection 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.

Creating a Complaint from the Company Record You can also create a complaint for a company from the company’s record page in SES. 1. Navigate to the desired company’s record via Company Search.

2. Click Related Actions > Create a Complaint .

Updated: 1/22/2021

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

Updated: 1/22/2021

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 with the Complaint Supervisor and Complaint Manager roles can search for the subject of a complaint. See SES Agency System Roles and Groups 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. Using Robust Search You can search for the subject of a complaint via the Company Search option in the header of the system. See the information in Searching for a Subject below for more details.

Updated: 8/20/2021

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. 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 details. 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.

Updated: 6/11/2021

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.

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.

Updated: 6/11/2021

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

Updated: 6/11/2021

Entering a Complaint

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

Note: Users with the Complaint Supervisor and Complaint Manager roles can enter a complaint. See SES Agency System Roles and Groups 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.

Note: You have the option of entering several optional data points as part of the complaint creation process.

Related Supervisory Activities

• • • • • • •

Related Complaints Related Companies

Related Non-NMLS Entities

Related Individuals

Agent Location Documents

Agent Locations

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

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

Updated: 2/9/2022

Entering a Complaint for an Individual The individual’s NMLS ID is carried over from the previous search query 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.

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 Review . 3. Click Create Complaint .

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

Updated: 2/9/2022

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.

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. See More about Agency View vs Company View of a Complaint Record for more information.

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

Updated: 2/9/2022

Completing Preliminary Review of a Complaint Introduction When entering a complaint, you have the option of sending it for preliminary review. 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: Users with the Complaint Supervisor and Complaint Manager roles can complete preliminary review of a complaint. See SES Agency System Roles and Groups for more information. Communication that preliminary review of a complaint needs to be completed must be communicated outside of SES.

Completing Preliminary Review 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 .

Updated: 2/9/2022

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

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.

Updated: 2/9/2022

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 Complaint Supervisors and Managers can refer a complaint to another agency. See SES Agency System Roles and Groups 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 is actively using SES to process complaints at this time.

If an agency is not actively using SES to process complaints at this time, you can close the complaint and indicated the reason for closure as “Referred to another agency” and identify the desired age ncy there. See Closing a Complaint for more information.

5. Click Submit Referral .

Note: All Complaint Supervisors and Managers at the agency to which the complaint was referred receive a notification to accept or reject the referral and the status is displayed on their homepage.

Updated: 4/7/2022

If the referral is rejected, you are notified, and 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: 4/7/2022

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 with the Complaint Supervisor and Complaint Manager roles can create a non-NMLS entity. See SES Agency System Roles 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.

Updated: 11/6/2021

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.

Updated: 11/6/2021

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

Updated: 11/6/2021

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 with the Complaint Supervisor and Complaint Manager roles can use Discussion for Non-NMLS Entities. See SES Agency System Roles and Groups 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 .

Updated: 4/7/2022

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 “All Agencies” for Tag Agency tags the discussion post for all agencies actively using SES to process complaints at this time. If your agency is tagged in a post, users with the Complaint Supervisor role receive a notification.

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.

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

Updated: 4/7/2022

Enrolling a Company User to SES Complaints

Introduction Before you can send information requests (IRs) to a company in SES, you must initiate User Enrollment. Enrolling 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 enrollment. For more information on company enrollment, see SES Company Enrollment Process.

Note: Users with the Complaint Supervisor and Complaint Manager roles can onboard a company to SES. See SES Agency System Roles and Groups for more information.

Enrolling a company to SES Complaints

1. Click Company Search .

2. Enter the information for the company user you want to enroll in SES.

3. Click Search .

4. Click the SES ID .

5. Click Company User Enrollment in the top right.

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

Updated: 8/20/2021

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 User Enrollment and Account Setup articles for more information. As an agency user of the enrolling agency that initiated company user enrollment, you can send a quick reminder notification to the company to complete enrollment if they do not respond to the email from Okta by clicking the Send Reminder icon. Once the company completes the enrollment and assignment processes, you will receive a notification of completion.

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

Updated: 1/22/2021

Module 1 Exercises Your Turn

Select any agency user account from the Regulator Training Accounts page to complete the practice scenarios below in the SES Training Environment. This hands-on practice allows you an opportunity to experience the complaints functionality before you begin using the real production environment. Keep in mind, utilizing the SES Training Environment is your opportunity to test all the available features without any limitations – except that we ask that you do not use or upload real complaint data. Please use your imagination to create fictitious but life-like scenarios to prepare you for the real application. If you would prefer to print the scenarios for the program, navigate to Quick Print Module 1 – 4 Scenarios at the end of the eBook and then click the print icon to select make your selection and print the scenarios pages. Scenario 1 Using the Initiating a Complaint , Searching for a Subject of a Complaint , and Entering a Complaint knowledge articles, enter a complaint on the NMLS/SES company provided in your login packet. We recommend that you practice both methods of searching for the company and if you would like, create multiple complaints on the entity to practice the process. Optional : If you envision your agency will incorporate the process of escalating the initial complaint data for review, please practice sending a complaint for preliminary evaluation and completing the preliminary evaluation. Refer to the Completing Preliminary Examination of a Complaint knowledge article to assist with this process. Be sure to assign your training account as the agency POC of the complaint. Scenario 2 Now that you are familiar with searching for a known company and entering the complaint into SES, proceed with creating a new non-NMLS entity. Use the Creating a Non-NMLS Entity knowledge article to complete this process. The knowledge articles referenced below in bold can be found immediately following the scenarios.

Updated: 8/21/2021

NOTE : Keep in mind, these are entities that do not (and do not want to) exist in NMLS. Think unknown or unreachable entities that are not licensed to conduct business. In the production environment, you will first want to see if the potential non-NMLS entity exists in NMLS or if another agency’s complaint user has already created the entity as a “Non-NMLS Entity.” You can use multiple search options to identify companies that do exist in NMLS as well as those that were created by other complaints users as non-NMLS entities. Scenario 3 A key feature when creating a non-NMLS entity is the Discussion page. This functionality works very much like current social media platforms and enables users to tag other complaints users at the same agency or a different agency to share identification details about an entity. For example, a complaints user in Idaho can tag complaint users in Nebraska to see if they have ever heard of the non-NMLS entity. Nebraska can respond back to the post and even request an update to the non-NMLS entity information, for example, "We know of this entity under a different name and here's the information..." Using your Non-NMLS Entity provided in your login packet and the Using Discussion for Non-NMLS Entities knowledge article, navigate to your Non-NMLS Entity and make updates to the Discussion page. Scenario 4 In the next module, you will learn that after entering a complaint on a NMLS/SES company, you will have the opportunity to send an information request to the company using SES. In order to complete this task, the company must be onboarded to SES. Using the Initiating Company Onboarding knowledge article, search for any company in the Training Environment and initiate the onboarding process. NOTE : All companies coming over from NMLS must go through the onboarding process. Non-NMLS entities do not exist in NMLS and therefore cannot be onboarded or communicated with via the system. Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/9/2021

Module 2:

Completing the Information Request Exchange for a Complaint

Updated: 6/29/2020

SES Consumer 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 review. 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. Let’s talk more about how the information request process works in SES. 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 IRs added to a complaint can be sent to the company even if the company has not yet completed enrollment in SES. When you send the information requests, you can create a new user account or send a reminder for the company to finish enrollment. The company is not able to view the details of an IR or submit responses until company enrollment is complete. Once the information requests have been sent to the company by the agency, - 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

Updated: 1/22/2021

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. • 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 Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 1/22/2021

Managing Information Requests for Complaints Introduction After entering a complaint, you have the option of creating an information request asking for the company to provide your agency with the documentation necessary to resolve the complaint.

Note: Users with the Complaint Supervisor and Complaint Manager roles can add information requests. See SES Agency System Roles and Groups for more information. The agency POC and users with the Complaint Manager role 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. Select the desired Available Next Action .

Updated: 3/8/2022

a. Save IR and send later : Saves the IR and moves it to “Ready to Send” status and it can be sent using the steps in the “Sending an Information Request to the Company” section below . b. Save IR and add another : Saves the IR and immediately opens another form for creating another IR. c. Save IR and continue to sending : Only available to the Agency POC and Complaints Supervisors. Saves the IR and takes y ou to the “Send Information Requests” screen. d. Send to company now : Only available to the Agency POC and Complaints Supervisors. Allows you to send the IR to the company immediately. Generates a form where you can add comments, documents, and a file sharing link. If the company is not yet in SES, you can initiate company enrollment from this screen, as well.

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

Note: The agency POC and users with the Complaint Manager role 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 .

Updated: 3/8/2022

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 confirm your notification preferences when the company responds to the IRs.

Note: The initial set of IRs accompany the complaint when it is first sent to the company. 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. Enter an optional response file sharing link. This allows the company to provide responses that may require an external file sharing solution (i.e, those that exceed 1GB in size).

7. Click Send Information Requests .

Note : The IRs added to a complaint can be sent to the company even if the company has not yet completed enrollment in SES. When you send the information requests, you can click Company User Enrollment to create a new user account or send a reminder for the company to finish enrollment. The company is not able to view the details of an IR or submit responses until company enrollment is complete.

Updated: 3/8/2022

8. Click Confirm .

Updating the Due Date for a Single IR 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. A notification is sent to the company for both of these actions.

Note: If you extend the due date for an IR, the original due date is maintained and displayed in detailed view of an IR in the system.

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 .

Updating Due Dates for IRs in Bulk 1. Navigate to the desired complaint. 2. Click Information Requests .

3. Click Update Due Dates .

4. Select the new desired due date . 5. Select the information requests that you wish to update due dates for by clicking anywhere on the row. 6. Click Update Due Dates .

Updated: 3/8/2022

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 .

5. Click Cancel Information Request .

Removing Information Requests You can remove any information requests that are in the “Ready to Send” status.

1. Navigate to the desired complaint. 2. Click Remove Information Requests .

3. Click the X icon next to the IRs you want to remove.

Updated: 3/8/2022

Note: The x icon changes to a clock icon, indicating that it is pending removal.

4. Click Remove Information Requests .

5. Click Confirm .

Sending Reminders for Information Requests You can send a reminder to the company for any information requests that have not been responded to. This reminder sends a notification to the Subject POC for the company. If the complaint does not have a Subject POC assigned, then the Complaints Contact receives the email notification.

1. Navigate to your complaint. 2. Click Information Requests .

3. Click the Send Reminder icon for any information request in the Sent to Company status.

4. Click Send Reminder on the confirmation screen.

Note: The system records the date and time the reminder was sent. Click +Show Reminder History to see it.

Updated: 3/8/2022

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

Updated: 3/8/2022

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 .

Updated: 6/25/2020

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

Need more help? Email rug@csbs.org

Updated: 6/25/2020

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.

Note: Users with the Complaint Supervisor and Complaint Manager roles can review information request responses for complaints. See SES Agency System Roles for more information.

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. Search for the desired information request.

Note: To search through the full list of IRs and response text, click Show Filters .

Updated: 11/6/2021

4. Click the IR ID hyperlink.

5. 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 .

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 a Consumer Complaints role with the Manage Complaints permission 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.

Updated: 11/6/2021

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 Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 11/6/2021

Module 2 Exercises Your Turn Using the same account used in Module 1, navigate to the SES Training Environment to complete the practice scenarios below. The knowledge articles referenced below in bold can be found immediately following the scenarios. Scenario 1 Using the Adding and Sending Information Request for a Complaint knowledge article, practice adding information requests to the complaints you created in Module 1. Scenario 2 Now that you have added information requests, proceed with sending them to the company using the Adding and Sending Information Request for a Complaint knowledge article. Remember, only the agency POC on the complaint can send the information request to the company, so be sure you are using the correct agency account. Scenario 3 Continue using the Adding and Sending Information Request for a Complaint knowledge article to practice updating the due date of an individual information request as you would in the “real” environment when you choose to give the company an extension. This should take place after the initial request has been sent. Also, we recommend cancelling at least one information request as you would if you no longer needed the requested information. Scenario 4 Use the Generating Company IR Responses for Complaints Training Program knowledge article to generate information request responses on behalf of the company. Feel free to complete this process for all complaints for which you have sent an information request. Scenario 5 Now practice reacting to the information request responses using the Reviewing Information Request Response for Complaints knowledge article. Remember, these

Updated: 8/21/2021

are fictitious scenarios so be sure to use your imagination and practice all available options. Need more help? Contact the Regulatory User Group at 1-800-699-0911 or by email at rug@csbs.org.

Updated: 6/9/2021

Module 3:

Processing a Complaint

Updated: 6/29/2020

SES Consumer 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: 1/22/2021