Complaint Program Policy

Version: 1.0

Effective Date: July 11th, 2024

Last Reviewed: July 11th, 2024

Next Review Date: July 10th, 2025

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1. Policy Statement and Objectives

1.1 Purpose

It is Wingspan’s policy to effectively manage and report End User complaints regarding financial products and services. This policy ensures that Wingspan meets compliance obligations, identifies and mitigates risks, improves product design, and prevents consumer harm or legal violations.

1.2 Background

A complaint is any expressed dissatisfaction from an End User regarding a financial product enabled by Wingspan. Complaints can be oral or written and received from various sources, including End Users, regulatory agencies, and any communications with the end user including phone calls. It is crucial to distinguish complaints from routine inquiries or requests for information.

1.3 Covered Products

The following products offered by Wingspan are covered by this policy:

1.3.1 Financial services accounts are Wingspan accounts that include features and services that can store or move funds. Examples include:

• Billing: origination of debit transactions from third parties through ACH, Credit Card, or other Settlement networks;
• Payments: origination of credit transactions to third parties through ACH, FedWire, or other Settlement networks;
• Business Banking (Wingspan Wallet) and Tax Withholdings: deposits into the Wingspan Banking program.

2. Complaints Intake and Management

2.1 Complaints Intake

Complaints can be received directly from the End User via email, chat or phone calls, and directed to a partner bank. Wingspan will track, respond to, and resolve complaints within established timeframes.

2.2 Complaints Investigation and Resolution

• Direct Complaints: Complaints received directly from End Users should be investigated and resolved, including notifying the End User, within 30 calendar days.
• Partner Bank Complaints: Complaints directed to the partner bank from End Users are subject to stricter timelines, often less than 10 days. Prompt research and resolution are crucial to avoid service disruptions.

2.3 Additional Standards for Complaint Management

2.3.1 Complaint Record Retention

Complaints will be retained in Wingspan’s files for a minimum of five (5) years from the date of the account closure or last activity. This ensures compliance with regulatory requirements and allows for thorough audit and review processes.

2.3.2 Escalation Turnaround Time

Wingspan strives to complete an operational SLA within 1 business day; however, all complaints will be resolved no later than 10 business days. For escalated complaints, Wingspan aims to provide a resolution within ten (10) business days from the date of escalation. This timeline is critical for promptly addressing high-priority issues and maintaining trust with our End Users and regulatory bodies.

2.3.3 Documentation Standards

Every complaint must include a timestamp and date of when the complaint was received, investigated, and resolved. The name of the reviewer handling the complaint should also be documented in our customer contact management system. Additionally, any policy changes resulting from the complaint review process will be communicated to the 3rd party bank for review and implementation.

2.3.4 Categorization of Complaints by Severity

Complaints will be categorized based on their severity to prioritize and address issues effectively. The categories are as follows:

• Critical: Complaints involving potential legal violations, significant financial impact, or severe service disruptions. These require immediate attention and resolution.
• High: Complaints that may not pose immediate legal risks but have a considerable impact on customer satisfaction and operational efficiency.
• Medium: Routine complaints that indicate areas for improvement but do not pose significant risks or impacts.
• Low: Minor issues or inquiries that are easily resolvable and do not significantly affect the overall service or customer experience.

3. Tracking and Reporting Complaints

3.1 Tracking Complaints

Complaints must be tracked using the Wingspan Complaint Tracking Template. This includes both direct complaints and those received via the partner bank. Separate logs must be maintained for each bank partner.

3.2 Monthly Reporting

Wingspan will submit a completed complaint log to the 3rd party bank by the 1st of each month, reporting on the previous month's complaints.

4. Researching and Responding to Complaints

4.1 Research Tips

• Start researching complaints promptly.
• Identify impacted accounts and ensure the complainant has rights to the information.
• Document events in chronological order with supporting evidence.
• Outline the investigation process in the response.
• Address the complainant's requested remediation clearly.

5. Escalation and Official Complaints

5.1 When to Escalate

Complaints received directly from agencies like the Attorney General, BBB, CFPB, FDIC, or OCC should be routed to the partner bank and the 3rd party bank within 24 hours. These "Official Complaints" are subject to stricter timelines and require prompt attention.

6. Qualification for "Banking Complaints"

Banking complaints encompass explicit negative feedback related to the following areas:

• Payment Delays:
  • Rejections
  • Returns
  • Bugs or issues in payment/payout process
• Tax Withholdings:
  • Discrepancies between balance amounts
  • Delays in tax account creation due to verification processes
  • Issues with deposits and withdrawals from the tax account
• Wallet:
  • Debit card issues (shipping address, loss, stolen, non-functional)
  • Problems with deposits and withdrawals from the wallet account
  • Unintended payments sent to the wallet
  • Lost or stolen cards
• Identity Theft:
  • Unauthorized account access
  • Fraudulent transactions
  • Personal information misuse
  • Creation of fraudulent accounts
• Account Management:
  • Errors in account statements
  • Difficulties in account closure
  • Problems with account updates
  • Unauthorized changes to account details
• Security Concerns:
  • Breaches of account security
  • Insufficient fraud prevention measures
  • Issues with two-factor authentication
  • Concerns over data privacy
• Technical Issues:
  • Bank Issue & downtimes
  • Errors in online transactions

7. Attestation for No Complaints

If no complaints are submitted, an attestation form must be filled out and sent at the end of the month.

8. Definitions and Examples

8.1 Definition of a Complaint

A complaint is any customer communication that expresses dissatisfaction with a service or system, alleges an error, or alleges a violation of state or federal regulations and/or law.

8.2 Examples of a Complaint

• Payment Rejection: "My payments have not been sent to my external bank. I know that I typed my account numbers correctly. Can you please fix this?"
• Identity Theft: "I believe someone hacked my account and changed my bank details. I am concerned about identity theft."
• Missing Deposits: "I transferred $2,500 to my Wingspan tax withholdings, but it hasn't shown up in my account after five business days."
• Product Complaints: "I am not satisfied with the tax withholdings product as it did not send money to the IRS on time."

This policy ensures a systematic approach to managing, tracking, and resolving complaints to maintain compliance and improve customer satisfaction.

Revisions

Comments Log

• Version 1.0

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