Complaint Management Policy

Overview

Flexbase Technologies Inc. (“Flex” or the “Company”) recognizes that monitoring, tracking, investigating, and responding to complaints in a timely manner is an important component of its overall Compliance Management System (“CMS”) and fundamental to meeting the needs of customers and managing risk.

The purpose of this Complaint Management Policy (this “Policy”) is to ensure that Flex is prepared to resolve complaints in a timely manner and keep executive management and the Board of Directors (the “Board”) apprised of emerging issues or trends identified through the management and handling of complaints.

Scope

2.1. Complaint

Flex defines a complaint as any expression of dissatisfaction, whether oral or written, whether justified or not, in relation to the business of the Company, to which a response or resolution is explicitly or implicitly expected. Complaints range from verbal customer complaints that take place during the course of routine contact to written complaints from customers, attorneys, Attorney General Offices, law enforcement officials, and regulatory bodies. It should be noted that complaints do not need to be valid to qualify (i.e. we will record and track complaints even if we know everything was handled correctly on our end).

2.2. Inquiry

An inquiry is a request from a consumer or other party for information or assistance regarding a product, service, policy or procedure that does not meet the definition of a complaint. If an inquiry indicates a failure to follow established policy or procedure, a breakdown in the policy or procedure, or suggests a potential violation of a federal or state regulation under which Flex operates, it will be classified as a complaint.

Disputes or requests made pursuant to the regulations listed below are not within the scope of this policy. Handling and response policies for such disputes and requests are summarized in their respective regulatory and servicing policies.

• Fair Credit Reporting Act Disputes
  
• Truth in Lending Act Billing Errors
  
•  Electronic Fund Transfer Act Errors
  

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Policy Statement‍

Flex is committed to providing superior customer service and handling customer complaints in a manner that:

• Acknowledges and addresses each complaint efficiently and fairly by appropriately reviewing, analyzing, investigating and documenting the details of the complaint in a timely manner;
• Responds to each complaint appropriately while assessing and assuring compliance with applicable regulatory requirements; and
• Treats complainants with courtesy and respect and appropriately updates them of the progress of their complaint.

This Policy establishes Flex Complaint Management Program (the “Program”), under which Flex will:

• Categorize types of complaints in order to respond appropriately;
•  Record complaints in order to maintain thorough documentation;
• Strive to resolve complaints in an efficient and fair manner;
• Establish an escalation process for complaints that require additional attention
• Review and analyze this Policy annually to ensure effectiveness; and Provide training to all employees who will be involved in handling complaints as necessary.

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Governance

This Policy sets forth the following responsibilities:

4.1. Chief Compliance Officer

The Chief Compliance Officer (“CCO”) has the responsibility to develop, maintain, and administer this Policy based upon the directives set forth in this Policy, industry best practices, and applicable regulatory guidance. The CCO may delegate to others the authority to adopt, develop and implement procedures that support this Policy.

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4.2. Legal

Flex’s legal counsel will work with the CCO or designee to respond to and/or resolve customer complaints that warrant legal review or participation (e.g., complaints threatening litigation, complaints from state Attorneys General, etc.).

4.3. Executive Management

Executive management is responsible for conveying the Board’s emphasis on compliance throughout the Company and fostering, communicating, maintaining, and reinforcing the compliance culture established by the Board. Executive management also must coordinate with the CCO to implement and enforce the Board’s directives.

5. The Complaint Management Program

5.1. Complaint Types

As defined above, a “complaint” is any expression of dissatisfaction, whether oral or written, with Flex’s products or servicing. In order to provide an accurate and timely response, complaints are categorized as follows.

5.1.1. Escalated Complaints

Escalated Complaints are complaints that are delivered or escalated to Compliance and/or Legal and are handled by (or at the direction of) the CCO. Escalated Complaints include:

• Complaints received from the Better Business Bureau, a regulatory agency (e.g., the CFPB, FHA, WA Department of Financial Institutions), a state Attorney General, or any other governmental agency, official, or elected representative;
• Complaints alleging unfair, deceptive or abusive acts and practices (“UDAP”);
• Complaints alleging discrimination, unfair treatment, or any other fair lending-related complaint;
• Complaints received from a customer’s attorney; or
• Standard Complaints that were not resolved in a timely manner within the business or cannot be resolved without the assistance of Compliance or Legal.
  

5.1.2. Standard Complaints

Standard Complaints are complaints that are handled within the business or escalated within the business as necessary. Standard Complaints do not require the assistance of, or a formal response from, legal or compliance.

A request from a customer for information regarding a product or service that does not meet the definition of a complaint (i.e., does not contain an expression of dissatisfaction) is considered an “Inquiry” and is not subject to the requirements of this Policy. Similarly, a dispute (e.g., billing error or credit reporting) does not meet the definition of a complaint and is considered to be a “regulatory dispute” that should be handled according to such Policy.

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5.2. Complaint Channels

Flex will provide customers with a variety of channels through which complaints can be submitted. Customers will be able to provide complaints directly to Flex via email at complaints@flex.one, phone or chat support at flex.one. Receipt of all written complaints, whether received in hardcopy or electronically, must be acknowledged via email within 24 hours.

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5.3. Recording Complaints

All complaints, whether verbal or written, as well as their resolutions, will be recorded in a comprehensive Complaints Log at the time the complaint is made, or as soon as possible thereafter. Employees that log initial information related to the complaint must also return to the Complaints Log to update the entry with root cause and resolution information as soon as available.

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5.4. Resolving Complaints

Flex’s aim is to resolve Standard Complaints as soon as practicable, but not later than 10 calendar days after receipt. In the event that a longer time frame is required, or a delay is anticipated due to the complexity of the matter, the complainant will be notified of the new timeframe in a timely manner.

Flex will resolve Escalated Complaints within 10 calendar days after receipt or within the time frame requested or required by the submitting party. In the event that a longer time frame is required, or a delay is anticipated due to the complexity of the matter, the CCO (or designee) will contact the submitting party to discuss the matter.

Once the customer’s complaint has been resolved, the Complaint Log will be updated to include the root cause, the date of resolution and a summary of the resolution. The Complaint Log will be sent to program partners on a monthly basis.

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5.5. Escalating Complaints

Standard complaints will be escalated within the business as necessary to address the customer's concern. Iftherecipientofthecomplaintisnottheappropriatepersontorespondto the complaint, then it will be transferred to the appropriate employee. If the employee cannot respond to the customer or resolve the customer’s concern, the complaint will be escalated to the next appropriate level of management within the business. If the complaint still cannot be resolved, resolved in a timely manner, or if the resolution requires a formal response from Compliance or Legal, the complaint will be forwarded to Compliance and treated as an Escalated Complaint.

Escalated Complaints will be provided to Compliance immediately upon receipt.

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5.6. Analyzing Complaints

Compliance will review and analyze customer complaint data monthly to identify potential trends or issues that could indicate a potential violation of legal or regulatory requirements. The review and analysis will be shared with executive management and the Board on a periodic basis, but no less than quarterly.

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6. External Complaints

Periodically, Compliance will monitor external channels, including online consumer reporting and complaint agencies (e.g. BBB and CFPB), and social media sites (e.g. Facebook, Twitter, Ripoffreport.com, etc.) to gather and analyze complaints.

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7. Training

The Company will train all employees on Complaints each calendar year, and monitor and track completion of this training. Other periodic or ad hoc trainings may be added as required.

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8. Monitoring

Compliance will periodically monitor complaints and the handling of complaints to ensure compliance with this Policy. The Company will also send the Complaint Log which will include both escalated and standard complaints to program partners on a monthly basis. 

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