Operations

A complaint program is not a complaints table

Regulators require a program. Most platforms ship a list with a status column.

Consumer complaint handling is one of the most consistently criticized areas in consumer lending enforcement, and the criticism is rarely that complaints were not recorded. It is that they were handled as individual events rather than as a program.

The distinction has teeth. A table tells you what was raised. A program has a clock, an owner, a resolution standard, a consequence, and a pattern view.

The five things a table is missing

  • A clock that starts on receipt. Time to acknowledge and time to resolve, both measured, both reportable. If the clock starts when someone opens the ticket, you are measuring your own responsiveness to yourself.
  • An owner. Unowned complaints do not get worked. A program surfaces unassigned items as an operational queue rather than leaving them in a status.
  • A consequence. This is the one almost always absent: an open dispute should stop money moving on that project. Money moving over an unresolved disagreement is precisely what turns a complaint into an enforcement action.
  • Both sides on the record. Structurally, not as a courtesy. If only the complainant's account is captured, the resolution is not defensible.
  • A feed into risk. Complaint history should change what a merchant is allowed to do. Otherwise the program is documentation rather than control.

Why pausing funding is the hard part

It is commercially uncomfortable. It delays a contractor's payment over a dispute that may turn out to be unfounded, and contractors will object. It is also the single most effective mechanism available, because it aligns everyone's incentive toward resolving the matter quickly.

A complaint that does not stop money is a complaint that nobody has to resolve urgently.

The way to make it acceptable rather than punitive is symmetry: the pause is automatic, the contractor can put their side on the record in writing, and the pause lifts automatically on resolution. Nobody is adjudicating it in a phone call the contractor was not on.

The practical version

Ask what happens to a pending draw when a borrower disputes the work. If the answer is "nothing automatic", you have a table.

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Ask us for the audit pack.

Pick a closed project. We will show you the document you would hand a regulator. If it does not answer the question, nothing else matters.