Complaint Process

Purpose

This procedure is set forth in order to comply with Matic’s Consumer Complaint Policy (MAT0030). This procedure outlines the different types of consumer complaints, provides guidance on effectively investigating and resolving such complaints and establishes best practices for ensuring consumer satisfaction.

Consumer complaints are logged in Matic’s consumer support ticketing system. For information on how a ticket is created, please reference Matic Consumer Complaint Ticket Form step by step guide. 

Here is the OneTrust link to the information outlined below: MAT030.1 Consumer Complaint Procedure

Complaint Types

Distinguishing between the below complaint types is important because it enables Matic to have more accurate tracking, analysis and identification of trends. This helps Matic find areas of opportunity with training, systemic controls and more to improve consumer satisfaction and operational processes. 

2.1 Customer Experience	Information Unclear or Withheld: Agency or Employee did not communicate clearly or did not convey information.  Deceptive Acts or Practices: Agency or Employee acted in a discriminatory or deceptive manner, such as bait and switch allegations. Length of Experience: Experience or phone interaction took an unacceptable amount of time. Negative Tone: Matic and/or Representative had a negative tone or perceived attitude, either verbally or written, and this includes text and email.  Failure to act or implement request: Matic and/or Representative did not fulfill request by consumer.
2.2 Policy or Coverage Dispute	Premium Dispute: Any complaint that involves a change in premium that is alleged to be the fault of Matic or Representative.  Coverage Dispute: A complaint in which the insured is unhappy with coverage or limits, which may, or may not be the cause of a claim denial.  Consent Not Provided: Allegation of lack of consent for the purchase, payment  and/or policy issuance. Policy Cancellation/Lapse (caused by Matic): Allegations that actions of Matic and/or Representative caused a policy to be canceled and/or a lapse of coverage.
2.3 Personal Data Request	These requests are typically not "complaints" but still need to be actioned appropriately.  Please reference MAT030.2 Personal Data Request Procedure for information on how to complete these requests.

Source of Complaint

Tracking the source of a complaint (i.e. the source or channel through which the complaint is being communicated) helps determine who should ultimately be responsible for addressing the complaint. By knowing where the complaint originated, Matic can include the appropriate team or individual to handle it effectively. Additionally, tracking the source allows for better reporting, as it provides valuable insights into where complaints are coming from. This information can highlight trends, identify potential areas for improvement and help Matic allocate resources more efficiently. Overall, monitoring the source ensures a more organized and effective response to consumer complaints.

Customer Contact	A consumer may attempt to reach out to Matic with their complaint through the below channels: Customer Service Department Sales Matic.com Net Promoter Score (NPS) Online Forum (Social Media, Google Review, Blog Post, etc.) To minimize reputational damage from complaints posted on public forums, Matic has established a separate procedure MAT030.03 Online Consumer Complaint Response Procedure.
Partner Services	Complaints that are escalated to Matic’s Partners by loan officers or the consumer themselves
Carrier/Adjuster	Complaints directly escalated to Matic by the Insurance Carrier or Insurance Carrier Representative
Department of Insurance (DOI) or Regulatory Authority	Formal grievances filed by policyholders regarding issues related to insurance policies, claims or company practices. These complaints are reviewed and addressed by a State DOI representative in accordance with regulatory requirements to ensure compliance and consumer satisfaction.  Though it differs by state, requests for information by a State Department of Insurance can come via email, fax and/or postal mail Due dates for responses vary by state
Better Business Bureau (BBB)	Formal grievances filed by consumers regarding business practices, service issues or product dissatisfaction, which are addressed in accordance with BBB guidelines to resolve disputes and maintain company reputation. BBB complaints are shared with the Business to the email [e-mail], creating a Complaint Ticket A response to the BBB is required within 7 business days of notification and will be sent by the Marketing team

Investigation Expectations

4.1 Roles and Responsibilities

Though complaints are primarily handled by Matic’s Customer Service team, complaints can still be escalated through other channels, as explained above. Defining the below responsibilities will help Matic to ensure adherence to internal processes and standards to have a consistent approach.

Sales Advisors	Intake complaint De-escalate the situation and attempt to route the consumer to Matic’s Customer Service team If the consumer is not allowing the call to be routed to Customer Service; Notate all complaint details in AMP Notes Send your manager the AMP Lead for review Advise the consumer that the complaint will be escalated for internal review A Customer Service Manager will send a “Complaint Confirmation Receipt” email to the consumer in 1-2 business days
Sales Managers	Review complaint details provided by your direct report Submit a Complaint Ticket with a summary of the complaint and all details found in initial review
Customer Service Representatives	Intake complaint and notate all details in the complaint ticket De-escalate the situation and/or resolve the matter, if possible If no resolution is possible and/or the consumer is claiming Matic is at fault, escalate the complaint to your direct manager Advise the consumer that the complaint will be escalated for internal review A Customer Service Manager will send a “Complaint Confirmation Receipt” email to the consumer in 1-2 business days
Customer Service Managers	Review complaint ticket Send “Complaint Confirmation Receipt” within 1-2 business days Begin investigation process, outlined below in Section 4.2

4.2 Investigation Process

Customer Service Managers to complete the following:

1. Review all consumer communications: Thoroughly examine all relevant consumer interactions, including sales and service calls, emails and any applicable policy documentation (Application, Declaration Page, Replacement Cost Estimator, etc). 
   • Always refer to the policy documentation directly from the carrier portal for the most up-to-date information
2. Notate all findings: Document all investigation findings within the complaint ticket in a clear and concise manner
3. Assess escalation needs and involve necessary stakeholders: Evaluate whether the issue requires escalation and, if so, tag all relevant stakeholders to the complaint ticket
   • If escalation is necessary (see below Section 4.3 Conditions for Escalation), notate a clear explanation of the required actions for all parties involved, including any response deadlines
4. Respond to the consumer with internal findings and next steps: Communicate the results of the investigation to the consumer, including any internal findings and a clear outline of the next steps, ensuring transparency and setting proper expectations for resolution

4.3 Conditions for Escalation

Escalation of a complaint should occur under specific conditions, such as when the involvement of Legal and Compliance is required or when financial remediation is deemed necessary. Only Customer Service Managers are authorized to escalate complaints to Legal and Compliance. In all cases of escalation, it is essential that the Complaint Investigation template is used for documentation purposes. This standardized process ensures that all stakeholders have a clear, consistent understanding of the situation and the steps taken to resolve it. 

Legal and Compliance Escalations

Investigating managers must escalate the following complaints to the Legal and Compliance Team for oversight and the drafting of formal responses if they originate from:

1. Department of Insurance (DOI) or other Regulatory Authority
   • The Legal and Compliance team must also review Matic's contractual obligations with Insurance Carriers to determine if notification of complaint is required
2. Better Business Bureau (BBB)
3. Insurance Carrier Representatives
   • Customer Service Managers should use discretion when handling confirming questions from adjusters. For example, if an adjuster asks whether the policyholder disclosed their spouse needing to be added to the policy during the original sales call, and the answer is 'yes,' the manager can resolve the issue without escalation and provide a portion of the transcript. However, in situations where there is a more significant concern—such as with a flood claim or an egregious error that could have financial implications—it is important to escalate to ensure the appropriate course of action is taken.

Additionally, an investigating manager must escalate complaints to Legal and Compliance if any of the following are stated or discovered:

1. Threatened or Confirmed Legal Action 
   • Any consumers who threaten legal action or if a law firm, for example, reaches out on their behalf must be escalated to the Legal and Compliance team
2. Egregious Error by a Matic Representative 
   • When a significant mistake or potentially malicious error is identified during an investigation, it must be escalated to the Legal and Compliance team for review to determine if the individual should be placed on an Error Monitoring program. Please refer to Agent Error Monitoring for further details on this internal control. This may include, but is not limited to, providing incorrect information to a consumer, misrepresenting policy terms, failing to adhere to internal quality standards and policies or violating regulatory requirements. Such errors can lead to potential legal consequences, financial losses or reputational harm to Matic. 

As stated above, Legal and Compliance is responsible for drafting formal responses to these complaints, not for conducting the investigations themselves. While the Legal and Compliance team can offer support and guidance on the matter, the investigation should be led by the Customer Service Manager.

Remediation Request Escalations

Matic may provide financial remediation to a consumer if the consumer suffered financial damage due to an error by Matic and/or a Matic representative’s failure to follow established policies, procedures and standards. This failure must be identified through an internal investigation into the consumer's complaint and/or request. Upon identification of an error by Matic and/or a Matic representative that has caused financial damage to a consumer, the Customer Service Manager must follow Matic’s internal MAT030.4 Consumer Financial Remediation Procedure.

4.4 SLA’s

All consumer complaints will adhere to a defined service level agreement (SLA) to ensure timely and effective resolution. Upon initial intake, a standardized escalation acknowledgment must be sent to the customer by the assigned Customer Service Manager within 48 hours. 

Following this initial communication, the complaint's progression falls under a managerial standard of care, requiring continuous oversight. Should a customer request an update, a response must be provided within 24 hours. Furthermore, a proactive update should be issued within 48 hours of the initial escalation acknowledgement. Please note that these timeframes may be adjusted based on the complexity or specifics of the consumer’s request, or if a particular due date has been established. 

Matic Best Practices

Adhering to established best practices when handling consumer complaints helps to prevent misunderstandings, safeguard sensitive information and ensure that all interactions are handled in a consistent manner. All individuals tasked with handling consumer complaints must adhere to the following:

Confidentiality of Transcripts:	Transcripts of communications must not to be shared externally unless explicitly approved by the Legal and Compliance team after a complete investigation. For a complete explanation of Matic’s internal position on transcription sharing, please reference Matic Call Recording and Transcription Practices
Language and Accountability:	Never use definitive language or admit fault prior to completing a full investigation.
Privacy of Internal Communications:	Do not include the consumer on internal communications related to the investigation (i.e. copying a policyholder on an email with the Insurance Carrier)
Communications with Consumers:	Responses must be objective, factual, and formal, free of spelling or punctuation errors, as clarity is essential to avoid any ambiguity.
Referenced Documentation:	Always refer to the policy documentation directly from the carrier portal for the most up-to-date information. Consumers may make changes directly with the carrier that could impact the documentation Matic originally retained, and new versions of the documents do not upload to AMP automatically. This is particularly important for E+S carriers, as we require the most accurate version of SL2 forms to ensure compliance and proper recordkeeping.