Verification
What happens if we don’t verify a pcms password?
Op Risk
Susie sends out a card to her CM and Susie releases the CMs full address, is this compliant?
No. Mailing address can be disclosed to the PCM/SCM/AU if:
Required by a scripted verification process, e.g., CBB redemption.
On an outbound call to confirm we have the correct mailing address for statements, card requests, etc.
Cm calls in and there is a “Get new Address” flag on the account. The agent who takes the call did not verify and update the address during the call. Is this compliant?
No, we must verify/ update the address, offer to resend card, check adjustments if necessary.
What are 5 acceptable override reasons for a late fee? What document did you look in?
One day late, DC error, Disaster benefits activated, job loss, short term disability, illness, medical expenses, divorce, family death, PIF, bank caused error, non-receipt of statement, clerical error
Monetary Adjustment (LATE FEE Strategy) Procedures
An account manager processed a credit line increase with a POA- is this allowed?
NOPE! They may only-Complete a credit line decrease
Obtain/Discuss reasons for DFS-initiated credit line decrease
Power of Attorney / Conservator / Guardian / Trustee Procedures
If an agent is transferring over, and they state the cm is fully verified but verification still pulls up, do I need to verify the pcm?
YES
If TP is calling in to make a payment and wanting the full balance, are we able to release the full balance?
No, we can only proactively inform of the min due if TP wants to make a payment
Customer calls in because they may have lost their card at the gas station they went to. CM was in a panic and asked us to hurry up and shut down the card. Agent did not read ALL talking points for processing l/s. In order to remain compliant, what should agent have done?
Lost/Stolen account procedures:
review recent charges- and read all required talking points to help customer be informed of process
CM received 1 recommended adjustment and 2 overrides due to extenuating circumstances in the last 12 months; customer calls for another Late Fee adjustment due to acceptable extenuating circumstance. Can we adjust? What document did you find this?
The override may NOT be completed because it exceeds the 3 max adjustments allowed in 12 month period.
Monetary Adjustment (LATE FEE Strategy) Procedures
How many ways can a customer send in their POA documentation for an account? And what are they?
3 ways: email, fax, and mail
Power of Attorney / Conservator / Guardian / Trustee Procedures
If pcms password states “durham 362” but pcm states durham rd 362 and we agree, is this compliant?
No, it needs to be stated how it is in the account notes
If CM is calling in because they are having a hard time reading their expiration date and we confirm with them what it is, is this compliant?
No. If the PCM/SCM/AU is having a difficult time reading their account number or expiration date, offer to send a new card (emergency delivery, if necessary). NEVER confirm what they have as the account number/expiration date is correct or not.
Customer calls in to update their address to 1234 Blue Ridge Road, when the agent entered the address they entered 1234 Blue Rich road, and did not confirm the address with the PCM before making the change. Is this compliant?
No, a Finalist Pop-up - A window may pop up with an updated version of the address per the US Postal Service regulations, click Accept.
Name 4 reason we DO NOT use policy adjustments to compensate the customer & what document did you check?
Interest charge, fee adjustments, late fee, BT fee, cash advance fee, return check fee, rewards, promo APR adjustments
Monetary Adjustment (GENERAL) Procedures
POA called in and wanted help getting logged onto Discover.com; the frontline agent transferred over to web for assistance w/out the PCM permission. Can web help them?
No, we cannot.
Power of Attorney / Conservator / Guardian / Trustee Procedure
If pcms name is listed as initials only, but provides full name and we move forward with call, is this compliant?
No. The customer MUST provide the initials not their full name. If they state the full name, ask them for the name as it appears on their card/statement (e.g. name on account is C R Smith, we cannot accept Clark Smith as the Cardmember (CM); CM must give C R Smith).
This CM calls in wanting to know what phone number we have on file and we release it in full, is this the correct thing to do?
No. the FULL phone number can be disclosed to the PCM/SCM/AU IF:
Part of the Mobile Phone Consent scripting
Reading the Out-of-Band (OOB) disclosure
Confirming the phone number when sending cards via the Card Confirmation screen
A brand new customer with a 5 day old account can call in to add an AB to the account before getting welcome kit?
FALSE
A customer calls in because they have a late fee on their recent statement and request it be waived due to them paying in full, however we received the payment late. The agent sees this is not system recommended, no previous fees waived, and does not adjust the fee and ends the call. Is this compliant?
Monetary adjustments procedures (late fee)
Not compliant, because the customer had an override reason for the adjustment and it was eligible for override as it did not max the 3 adjustments in 12 months
Can we take action on an account if the POA says this “***POA SME*** RCVD INVLD POA // FLD 4/20/2021// INVLD DUE TO OFAC SCREENING // SNT INVLD LT” ?
NO! This will show in the warning notes that you can move forward with the call. ***POA SME*** APPNTD {POA/CNSRVTR/ GUARDIAN/ TRUSTEE} XXXX // INVKE DT {Effective date} // FLD {date}
If CM has multiple accounts, do we have to verify them again on the other account?
If the customer is calling in on multiple accounts, agents must follow all verification prompts on each account, even if the same verification questions are displayed on each account.
When can we release the full account number to a CM?
Closed, suspended, revoked status and needs it for a merchant credit, another financial institution/tp payment service will be paying off the account. Account center registration only so a payment can be made.
A customer does not need legal documentation when changing their full name (outside of marriage/divorce)
FALSE
Cm’s wife calls back after hanging up with a rep earlier in the morning to get a fee adjusted. Wife is not listed on the account, and the agent accepts the call and releases information along with waiving a fee. How should this call be handled?
Do not release account info with a TP- do not make an adjustment with a TP without consent of the PCM during that exact interaction. Instead ask if PCM is available and if not ask them to call back together
List 10 things a POA MAY do
on an account- to remain fully compliant