That's a very good question. To reiterate, the reportable complaints we receive from banks are, by definition, complaints that have been handled and responded to. Our role is to ensure that they're handled in a way that meets consumer protection measures. For example, they have to be dealt with within 56 days, and the consumer needs to benefit from a written response. In the absence of satisfaction, there's an escalation process to an independent ombudsman that we call the ECB.
From a supervisory perspective, we have many sources of intel. Complaints reported by banks are one. Complaints received directly from consumers or merchants are another. We undertake our own risk assessments, reviews and so on, and we interact closely with financial partners.
Ultimately, a complaint or set of complaints can point to a particular risk in an institution that might be speaking to non-compliance. Where there is a risk of non-compliance or confirmed non-compliance, we undertake investigative work to determine the nature of that and what the breach is, and we take appropriate actions accordingly, which could range from a notice to a publication of a violation, accompanied by a financial penalty.
In some cases, we learn of these things from the ECB itself—the external complaints body. There are scenarios in which a particular issue in an institution presents itself as possibly being systemic, in which case we will engage multiple institutions to understand whether there is a systemic issue. Where we discover non-compliance, we take actions as warranted.
To the earlier point that was made, I can tell you that consumers have received by way of redress—i.e., being made whole—millions of dollars. However, I do take the point from this committee that the line of sight on that is maybe something that could be improved, and our commissioner has agreed to accept that as a takeaway, on her ninth day on the job.
