PHILIPPINE BUSINESS BANK

CONSUMER PROTECTION PROGRAM

A. OVERVIEW

The issuance of Bangko Sentral ng Pilipinas (BSP) Circular No. 857 Series of
2014 – BSP Regulations on Financial Consumer Protection underscores that
financial consumer protection is a fundamental responsibility of BSP-
Supervised Financial Institutions (BSFIs) corporate governance and culture.
All Banks shall be governed by the basic principles and ethical business
practices in dealing with their consumers. Likewise, BSFIs are expected to
observe the Consumer Protection Standards at all times in all dealings with
Financial Consumer.

B. CONSUMER PROTECTION OVERSIGHT FUNCTION

B.1 ROLES AND RESPONSIBILITES OF THE BOARD AND SENIOR

MANAGEMENT

BOARD OF DIRECTORS

The Board shall be primarily responsible for approving and overseeing

the implementation of policies governing major areas of the Bank’s
consumer protection program, including the mechanism to ensure
compliance with the set policies.

The Roles of the Board shall include the following:

a) Approve the Consumer Protection policies;

b) Approve Risk Assessment Strategies relating to Effective Recourse

by the Consumer;

c) Provide adequate resources devoted to Consumer Protection;

d) Review the applicable policies periodically

SENIOR MANAGEMENT

The Senior Management shall be responsible for proper implementation

of the Consumer protection policies and procedures duly approved by
the Board. Also, its role shall focus on ensuring effective management of
day-to-day consumer protection activities.

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B.2 CONSUMER PROTECTION RISK MANAGEMENT SYSTEM (CPRMS)

The Bank’s Consumer Protection Risk Management System (CPRMS)

shall form part of the Corporate-wide Risk Management System. It is a
means to identify, measure, monitor and control consumer protection
risks. Risk Management Strategies shall include appropriate
management controls and reasonable steps to ensure that:

a) it identifies and remedies any recurring or systematic problems;

and

b) identifies weaknesses in internal control procedures or process.

This may be done by:

- analyzing complaints/requests data;

- analyzing causes for complaints/requests;

- consideration whether such identified weaknesses may also

affect other processes or products, including those not directly
complained of/requested; and

- correcting; whether reasonable to do so, such causes taking

into consideration the concomitant costs and other resources.

B.3 BOARD AND SENIOR MANAGEMENT OVERSIGHT

The Board shall be responsible in developing and maintaining a sound

CPRMS which shall be integrated into the overall framework for the
entire product and service life cycle. The Board and Senior Management
should periodically review the effectiveness of the CPRMS, including
how findings are reported and whether the audit mechanisms in place
enable adequate oversight. The Board and the Senior Management
must also ensure that sufficient resources have been devoted to the
program. Likewise, the Board and Senior Management must also make
certain that CPRMS weaknesses are addressed and corrective actions
are taken in a timely manner.

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B.4 COMPLIANCE PROGRAM

The Consumer Protection Program shall form part of the Bank’s over-all
Compliance System. Through the Compliance Office, the program shall
ensure adherence to Bank’s policies, relevant banking laws, rules and
regulations of BSP, SEC, PDIC, DTI and other regulating agencies.

B.5 POLICIES AND PROCEDURES

Policies and Procedures under the Consumer Protection Program shall

be in place and duly approved by the Board. Similarly, all Bank’s policies
and procedures should

a) be consistent with the consumer protection policies and procedures;

b) ensure that consumer protection practices are embedded in the

Bank’s business operations;

c) address compliance with consumer protection laws, rules and

regulations; and

d) be reviewed periodically and kept-up-to-date since these serve as

reference for employees in their day-to-day activities.

B.6 INTERNAL AUDIT

Independent of the compliance function, the Bank’s Internal Audit shall:

1) review the consumer protection practices;

2) adherence to internal policies and procedures; and

3) compliance with existing laws, rules and regulations

Under the Bank’s Manual of Corporate Governance, the Audit

Committee provides oversight over the institutions’ financial reporting
policies, practices and control and internal and external audit functions.

B.7 TRAINING

PBB shall conduct trainings and education programs to enhance to the

highest degree, the professionalism, excellence and skills of its
employees in the performance of their duties and responsibilities.

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 The Bank shall ensure continuing education of personnel about.
Consumer Protection laws, rules and regulations, including related
policies and procedures.

C. CONSUMER PROTECTION STANDARDS OF CONDUCT

The following Consumer Protection Standards reflect the core principles,

which the Bank is expected to observe at all times in their dealings with
financial consumers. These should be embedded into the corporate culture of
the Bank, enhancing further its defined governance framework while
addressing conflicts that are inimical to the interests of the financial
consumer.

a) Disclosure and Transparency

The Bank shall take affirmative action to ensure that its consumers have a
reasonable holistic understanding of the products and services, which they
may be acquiring or availing. In this context, full disclosure and utmost
transparency are the critical elements that empower the consumer to make
informed financial decisions. This is made possible by providing the consumer
with ready access to information that accurately represents the nature and
structure of the product or service, its terms and conditions, as well as its
fundamental benefits and risks.

1. Key Information

1.1 Ensures that offering documents of products and services contain

the information necessary for customers to be able to make an
informed judgment of the product or service and, in particular, meet
the full disclosure and risks of the products should be highlighted
prominently in a succinct manner. Where a product is being offered
on a continuous basis, its offering documents should be updated in
accordance with the requirements set out in the regulations.

1.2 Readily and consistently makes available to the customer a written

copy of the Terms and Conditions (T&C) that apply to a product or
service. The contents of the T&C must be fully disclosed and
explained to financial customers before initiating a transaction.
Where and when warranted, reference to the T&C should be made
while transacting with the consumer and before consummating the
transaction, if such reference is material to the understanding of the
consumer of the nature of the product or service, as well as its
benefits and risks.

The T&C should include at least the following:

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 1) The full price or cost to the customer including all interest, fees,
charges, and penalties. The T&C must clearly state whether
interest, fees, charges, and penalties can change over time. The
method for computing said interest, fees, charges, and penalties
shall be presented in accordance with Circular 730 dated 20
July 2011;

2) General information about the operation of the products or

services including the customer’s obligations and liabilities;

3) Cooling-off period, if applicable.

4) Cancellation, return and exchange policies, and any related

cost;

5) The actions and remedies which the Bank may take in the event
of a default by the customer;

6) Procedures to report unauthorized transactions and other

contingencies, as well as the liabilities of parties in such case;
and

7) A summary of the Bank’s complaints handling procedure.

1.3 Advises customers to read and understand the applicable T&C,

when considering a product or service.

1.4 Ensures that its staff communicates in such a manner that clients
can understand the terms of the contract, their rights and
obligations. Staff should communicate with techniques that address
literacy limitations (e.g. materials are available in local language).

1.5 Provides customers adequate time to review the T&C of the product
or service, ask questions and receive additional information prior to
signing contracts or executing the transaction. The staff of the Bank
should be available to answer the questions and clarifications from
the financial customer.

1.6 Ensures that staff assigned to deal directly with customers, or who
prepare advertisement materials (or other material of the Bank for
external distribution) or who markets any product or service should
be fully knowledgeable about these products and services,
including statutory and regulatory requirements, and are able to
explain the nuances to the consumer.

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1.7 Uses a variety of communication channels to disclose clear and
accurate information. Such communication channels should be
available to the public without need for special access
requirements, which may entail additional expense. Communication
channels should be sufficiently responsive to address the literacy
limitations of the financial consumer. Said channels may be written
and/or verbal as may be warranted.

1.8 Discloses pricing information in public domains (e.g., websites).

1.9 Updates customers with relevant information, free of charge in a

clear, understandable, comprehensive, and transparent manner, for
the duration of the contract. Such information covers the
characteristics and the risks of the products sold by the Bank and
their authorized agents.

1.10 Imparts targeted information to the specific groups of clients to

whom specific products are being marketed, with a particular
consideration for vulnerable customers. Communication channels
employed for such targeted marketing initiatives may be
accordingly calibrated.

1.11 Offers enhanced disclosure for more complex products, highlighting

the costs and risks involved for the customer. For structured
investment products, a Product Highlight Street (PHS) is required.
The PHS should be clear, concise, and easily understandable by
individual customers. It should contain information that empowers
the customer to appreciate the key features of the product and its
risks. It is prepared in a format that facilitates comparison with other
products. The PHS should be available at no cost to the public and
made available to consumers upon request. Before signing any
contract, the Bank should ensure that the customer has freely
signed a statement to the effect that the customer has duly
received, read, and understood the PHS.

1.12 Notifies the customer in writing of any change in:

1.12.1 Interest rate to be paid or changed on any account of the

customer as soon as possible; and

1.12.2 A non-interest charge on any account of the customer

within a number of days as provided under existing
regulations prior to the effective date of the change.

If the revised terms are not acceptable to the customer,

he or she should have the right to exit the contract

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 without penalty, provided such right is exercised within a
reasonable period. The customer should be informed of
this right whenever a notice of change is made.

1.13 Provides customers with a proof of the transaction immediately

after the transaction has been completed. The customer should be
given a hard copy of each of the documents signed by the clients
(including, but not limited to the contract) with all terms and
conditions. The Bank ensures that documents signed by the
customer are completely filled and that there are no blank terms.

1.14 Regularly provides customers with clear and accurate information

regarding their accounts (e.g., Statement of accounts that includes,
among others, covering period, opening balance/value of
transactions, all kinds of interest, fees and charges, closing
balance, inquiries for outstanding balances, proof of payments for
loans).

1.15 Informs customers of their rights and responsibilities including their

right to complain and the manner of its submission.

2. Advertising and Promotional Materials

2.1 Ensures that advertising and marketing materials do not make

false, misleading, or deceptive statements that may materially
and/or adversely affect the decision of the customer to avail of a
service or acquire a product.

2.2 Ensures that advertising and promotional materials are easily

readable and understandable by the general public. It should
disclose clear, accurate, updated, and relevant information about
the product or service. It should be balanced/proportional (reflecting
both advantages and risks of the product or service);
visible/audible; key information is prominent and not obscured; print
is of sufficient size and clearly legible.

2.3 Ensures that promotional materials are targeted according to the

specific groups of consumers to whom products are marketed and
the communication channels employed for marketing financial
services.

2.4 Ensures that all advertising and promotional materials disclose the
fact that it is a regulated entity and that the name and contact
details of the regulator are indicated.

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 3. Conflict of Interest

3.1 Discloses properly to the consumer prior to the execution of the

transaction that the Bank or its staff has an interest in a direct/cross
transaction with a consumer, if any.

3.2 Discloses the limited availability of products to consumers when the

Bank only recommends products which are issued by their related
companies, particularly when commissions or rebates are the
primary basis for recommending the particular product to
consumers.

3.3 Discloses the basis on which the Bank is remunerated at the pre-
contractual stage.

3.4 Ensures that adequate systems and controls are in place to

promptly identify issues and matters that may be detrimental to a
customer’s interest (e.g., cases in which advice may have been
given merely to meet sales targets, or may be driven by financial or
other incentives.

b) Protection of Client Information

1. Confidentiality and Security of Client Information

1.1 Have a written privacy policy to safeguard its customers’ personal

information. This policy should govern the gathering, processing,
use, distribution, storage, and eventual disposal of client
information, in accordance with Data Privacy Act. The Bank should
ensure that privacy policies and sanctions for violations are
implemented and strictly enforced.

1.2 Ensure that privacy policies are regularly communicated throughout

the organization. Opportunities include employees’ initial training
sessions, regular organization-wide training programs, employee
handbooks, posters and posted signs, company intranet and
internet websites, and brochures available to clients.

1.3 Have appropriate systems in place to protect the confidentiality and

security of the personal data of its customers against any threat or
hazard to the security or integrity of the information and against
unauthorized access. This includes a written information security
plan that describes its program to protect customer personal
information. The plan must be appropriate to its size and
complexity, nature and scope of its activities, and the sensitivity of
customer information it handles. As part of its plan, the Bank must:

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 1.3.1 Designate employee accountable to coordinate its
Information Security Program.

1.3.2 Identify and assess the risks to customer information in

each relevant area of the Bank operation, and evaluate
the effectiveness of the current safeguards for controlling
these risks.

1.3.3 Design and implement a safeguards program, and

regularly monitor and test it.

1.3.4 Select service providers that can maintain appropriate

safeguards.

1.3.5 Evaluate and adjust the program in light of relevant

circumstances, including changes in the firm’s business
or operations, or the results of security testing and
monitoring.

1.4 Have appropriate policies and practices for employee management

and training to assess and address the risks to customer
information. These include:

1.4.1 Checking references and doing background checks

before hiring employees who will have access to
customer information.

1.4.2 Asking new employees to sign an agreement to follow

the Bank confidentiality and security standards for
handling customer information.

1.4.3 Limited access to customer information of employees

who have no business reason to see it.

1.4.4 Controlling access to sensitive information by requiring

employees to use “strong” passwords that must be
changed on a regular basis.

1.4.5 Using automatic time-out or log-off controls to lock

employee computers after a period of inactivity.

1.4.6 Training employees to take basic steps to maintain the

security, confidentiality, and integrity of customer
information. These may include locking rooms and file
cabinets where records are kept; ensuring that employee

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 passwords are not posted in work areas; encrypting
sensitive customer information when transmitted
electronically via public networks; referring calls or other
requests for customer information to designated
individuals who have been trained in how the Bank
safeguards personal data; and reporting suspicious
attempts to obtain customer information to designated
personnel.

1.4.7 Regularly reminding all employees of company policy to

keep customer information secure and confidential.

1.4.8 Imposing strong disciplinary measures for security policy

violations.

1.4.9 Preventing terminated employees from accessing

customer information by immediately deactivating their
passwords and user names and taking other measures.

1.5 Have a strong IT System in place to protect the confidentiality,

security, accuracy and integrity of customer’s personal information.
This includes network and software design, and information
processing, storage, transmission, retrieval, and disposal.
Maintaining security throughout the life-cycle of customer
information, from data entry to disposal, includes:

1.5.1 Knowing where sensitive customer information is stored

and storing it securely. Make sure only authorized
employees have access.

1.5.2 Taking steps to ensure the secure transmission of

customer information.

1.5.3 Disposing customer information in a secure way.

1.5.4 Maintaining up-to-date and appropriate programs and

controls prevent unauthorized access.

1.5.5 Using appropriate oversight or audit procedures to detect

the improper disclosure or theft of customer information.

1.5.6 Having a security breach response plan in the event the

Bank experiences a data breach.

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 2 Sharing of Customer Information

2.1 Inform its customers in writing and explain clearly to customers as

to how it will use and share the customer’s personal information.

2.2 Obtain the customers’ written consent, unless in situations allowed

as an exception by law or BSP-issued regulations on confidentiality
of customer’s information, before sharing customers’ personal
information with third parties such as credit bureau, collection
agencies, marketing and promotional partners, and other relevant
external parties.

2.3 Provide access to customers to the information shared and should

allow customers to challenge the accuracy and completeness of the
information and have these amended as appropriate.

2.4 Appropriate penalties should be imposed by the Bank to erring

employees for exposing or revealing client data to third parties
without prior written consent from client.

c) Fair Treatment

1. Affordability and suitability of product or service

1.1 When making a recommendation to a customer:

1.1.1 Gather, file, and record sufficient information from the

customer to enable the Bank to offer an appropriate
product or service to the customer. The information
gathered should be commensurate to the nature and
complexity of the product and service either being
proposed to or sought by the customer and should
enable the Bank to provide an appropriate level of
professional service. As a minimum, information includes
the customers’ financial knowledge and experience,
financial capabilities, investment objectives, time
horizons, needs, priorities, risk affordability, and risk
profile.

1.1.2 Offer products or services that are in line with the

needs/risk profile of the consumer. The Bank should
provide for and allow the customer to choose from a
range of available products and services that can meet
his needs and requirements. Sufficient and right

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 information on the product or service should enable the
customer to select the most suitable and affordable
product and service.

1.2 Inform or warn the customers that if they do not provide sufficient
information regarding their financial knowledge and experience, the
Bank is not in a position to accurately determine whether the
product or service is appropriate to them, given the limited
information available. This information or warning may be provided
in a standardized format.

1.3 Ensure that the customer certifies in writing the accuracy of the
personal information provided.

1.4 Ensure to offer market-based pricing.

1.5 Design products that are appropriate to the varying needs and
interests of different types of consumers, particularly the more
vulnerable consumers. Adequate product approval should be in
place. Processes should be proper to ensure that products and
services are fit for the targeted consumer.

1.6 Do not engage in abusive or deceptive acts or practices.

1.7 Seek customer feedback for product design and delivery and use
this feedback to enhance product development and improve
existing products. Likewise, investigate reasons for client drop out.

1.8 Do not use high pressure/aggressive sales techniques and do not

force clients to sign contracts.

1.9 Have a system in place for approval when selling high-risk

instruments to consumers.

2. Prevention of over-indebtedness

2.1 Have appropriate policies for good repayment capacity analysis.

The loan approval does not rely solely on guarantees (co-signers or
collateral) as a substitute for good capacity analysis.

2.2 Properly assess the creditworthiness and conduct appropriate client

repayment capacity analysis when offering a new credit product or
service significantly increasing the amount of debt assumed by the
customer.

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 2.3 Ensure to have an appropriate system in place for credit analysis
and decisions including appropriate criteria to limit the amount of
credit.

2.4 Monitor enforcement of policies to prevent over-indebtedness. The

Board and Senior Management of the Bank should be aware of the
concerned about the risks of over-indebtedness of its customers.

2.5 Draw the customer’s attention to the consequences of signing a

contract that may affect his financial position and his collateral in
case of default in payment of a loan/obligation.

2.6 Prepare and submit appropriate reports (e.g., loan quality, write-
offs, restructured loans) to management.

2.7 Ensure that corrective measures are in place for poor long-term
quality of loan portfolio linked to over-indebtedness.

2.8 Have specific procedures to actively work out solutions (i.e.,

through workout plan) for restructured loans / refinancing / writing-
off on exceptional basis for clients in default who have the
“willingness” but without the capacity to repay, prior to seizing the
assets.

3. Objectivity

3.1 Deal fairly, honestly, and in good faith with customers and avoid
making statements that are untrue or omitting information which are
necessary to prevent the statement from being from false or
misleading.

3.2 Present a balanced view when selling a product or service. While

the Bank highlights the advantages of a product/service, the
customer’s attention should also be drawn to its disadvantages and
downside risks.

3.3 Ensure that recommendations made to customer are clearly

justified and explained to the customer and are properly
documented. If the requested products are of higher risk rating than
a customer’s risk tolerance assessment results, the Bank should
draw to the customer’s attention that the product may not be
suitable for him in view of the risk mismatch. In such instances,
there should be a written disclosure of consequences which is
accepted by the client.

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 3.4 Ensure that the customer’s suitability and affordability are assessed
against specific risks of the investment products:

3.4.1 Financial Needs Analysis (FNA) and Client Suitability – to

assess the customer’s risk profile and suitability of the
product.

3.4.2 Customer’s Declaration Form – to confirm his acceptance

and understanding of the highlighted features of the
product.

3.4.3 FNA, Client Suitability and Declaration Form should be

duly completed to make sure that the product sold is
suitable and affordable for the customer.

4 Institutional culture of fair and responsible treatment of clients

4.1 There should be a Code of Conduct (Code) applicable to all staff,

spelling out the organizational values and standards of professional
conduct that uphold protection of customers. This Code should be
reviewed and approved by the Board. The staff signs a document
by which they acknowledge that they will abide by the Code. To
ensure adherence to the Code, the Bank is required to implement
measures to determine whether the principles of consumer
protection are observed, the clients’ concerns are appropriately
addressed and problems are resolved in a timely manner. These
may be included among others, the regular conduct of customer
satisfaction survey.

4.2 Ensure that recruitment and training policies are aligned around fair
and responsible treatment of clients.

4.3 Ensure that staff, specifically those who interact directly with
customers, receive adequate training suitable for the complexity of
the products or services they sell.

4.4 Ensure that collection practices are covered during the initial
training of all staff involved in collections (loan officers, collections
staff, and branch managers). In particular, collection staff should
receive training in acceptable debt collection practices and loan
recovery procedures.

4.5 Strictly comply with BSP’s existing regulation on what constitutes

unfair debt collection practices. The Bank’s Code of Conduct should
clearly spell out the specific standards of professional conduct that

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 are expected of all staff involved in collection (including outsourced
staff).

4.6 Institute policy that guarantees that clients receive a fair price for
any foreclosed assets and has procedures to ensure that collateral
seizing is respectful of client’s rights.

4.7 Ensure that Managers and Supervisors review ethical behavior,

professional conduct, and quality of interaction with customers as
part of staff performance evaluations.

4.8 Have a system or internal processes in place to detect and respond

to customer mistreatment as well as serious infractions. In case of
violation of Code of Conduct (e.g., harassment,) sanctions shall be
enforced.

4.9 Inform staff of penalties for non-compliance with Code of Conduct.

4.10 Perform appropriate due diligence before selecting the authorized

agents/outsourced parties (such as taking into account the agents’
integrity, professionalism, financial soundness, operational
capability and capacity, and compatibility with the FI’s corporate
culture) and implement controls to monitor the agents’ performance
on a continuous basis. The Bank retains ultimate accountability for
outsourced activities.

4.11 Disseminate the main aspect of the Code of Conduct to clients

through printed media or other appropriate means.

5 Remuneration Structure

5.1 Design remuneration structure for staff of the Bank and authorized
agents in a manner that encourages responsible business conduct,
fair treatment and avoidance/mitigation of conflicts of interest.

5.2 Disclose to the customers the remuneration structure where

appropriate, such as when potential conflicts of interest cannot be
managed or avoided.

5.3 Ensure adequate procedures and controls so that sales staff are
not remunerated based solely on sales performance but that other
factors, including customer’s satisfaction (in terms of number of
customer complaints served/settled) and compliance with
regulatory requirements, best practices guidelines, and Code of
Conduct in which certain principles are related to best interest of

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 customers, satisfactory audit/compliance review results and
complaint investigation results, are taken into account.

d) Effective Recourse

The Bank demonstrates the ability to provide effective recourse if it is

able to:

(1) Establish an effective Consumer Assistance Management System

(CAMS).

(2) Develop internal policies and practices, including time for

processing, complaint response, and customer access.

(3) Maintain an up-to-date log and records of all complaints from

customers’ subject to the complaints procedure. This log must
contain the following:

i. Details of each complaint;

ii. The date the complaint was received;

iii. A summary of the Bank’s response;

iv. Details of any other relevant correspondence or records;

v. The action taken to resolve each complaint; and

vi. The date the complaint was resolved.

(4) Ensure that information on how to make a complaint is clearly

visible in the Bank’s premises and on their websites.

(5) Undertake an analysis of the patterns of complaints from customers

on a regular basis including investigating whether complaints
indicate an isolated issue or a more widespread issue for
consumers. This analysis of consumer complaints must be
escalated to the Bank’s compliance/risk management function and
senior management.

(6) Provide for adequate resources to handle financial consumer

complaints efficiently and effectively. Staff handling complaints
should have appropriate experience, knowledge, and expertise.
Depending on the Bank’s size and complexity of operation, a

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 Senior staff member should be appointed to be in charge of the
complaint handling process.

e) Financial Education and Awareness

The Bank demonstrates this principle through various means and in

particular:

(1) Have a clear and defined financial education and awareness

program as part of a wider financial consumer protection and
education strategy and corporate governance. It is an integral
component of the Bank’s ongoing interaction and relationship with
clients. Dedicated and adequate resources should be provided for
the financial education initiatives.

(2) Develop financial education and awareness programs, either on

their own or in partnership or collaboration with industry
associations, which contribute to the improvement of their clients’
knowledge and understanding of their rights and responsibilities,
basic information and risks of financial products and services, and
ability to make informed financial decisions and participate in
economic activities. Financial education programs should be
designed to meet the needs and financial literacy level of target
audiences, as well as those that will reflect how target audience
prefers to receive financial information. These may include:

2.1 Delivering public awareness campaigns and information

resources that would teach consumers on certain aspects of
their financial lives particularly, budgeting, financial planning,
saving, investing, borrowing, retirement planning, and self-
protection against fraud.

2.2 Developing financial education tools or information materials

that are updated and readily understood and transparent such
as customized advice and guidance (face to face training);
printed brochures, flyers, posters, training videos (e.g. about
money management, debt management, saving), and
newsletters; websites, and interactive calculators that deliver
key messages and “call to action” concerning better money
management (e.g., protect your money, know your product,
read and understand the T&C, check your statements, pay
credit card bills on time, safeguard your Personal Identification
Number, understand fees and charges) and consumer
responsibility to ask the right questions.

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(3) Clearly distinguish between financial education from commercial
advice. Any financial advice for business purposes should be
transparent. Disclose clearly any commercial nature where it is also
being promoted as a financial education initiative. It should train
staff on financial education and develop codes of conduct for the
provision of general advice about investments and borrowings, not
linked to the supply of a specific product.

(4) Provide via the internet or through printed publications unbiased

and independent information to consumers through comparative
information about the price and other key features, benefits and
risks, and associated fees and charges of products and services.

(5) Regularly track, monitor, and assess campaigns and programs and
use the results of the evaluation for continuous improvement.

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D. DESIGNATION OF CONSUMER ASSISTANCE OFFICER (CAO)

1. Given their skills in handling various customer transactions, the Business

Manager (or in his/her absence, the Branch Service Head) shall act as the
CAO who shall be the one to receive the complaints raised to the
branch/branch lite by financial consumers and endorse the same to CPU,
if needed. The designation of the Business Manager/Branch Service
Head as CAO shall be upon the approval of the Branch Banking
Group/Branch Operations & Control Group.

2. To handle complaints received through extension offices and other

banking units aside from the Consumer Protection Unit (CPU), one (1)
CAO shall be appointed per Head Office location (e.g. Main Building,
Annex Bldg.) to receive client complaints and endorse them to the CPU.
The designation of such CAO’s shall be duly coordinated by the CPU with
the former’s Group/Center Head.

E. GUIDELINES/PROCEDURES IN CUSTOMER COMPLAINTS HANDLING

PBB clients/customers may lodge their complaints/concerns through the

following means:

1. Walk-in or personal visit to the Branch/Head Office (H.O.) Unit

A) Client/Customer

1) Shall visit the Branch/H.O. Unit and fill-out the Customer Complaint
Form (CCF – Annex A- Revised Form).

2) Complete details of the complaint shall be provided in the form.

B) Consumer Assistance Officer (CAO)

1) Shall validate the complaint received from the client/customer.

2) If the complaint can be resolved immediately/upfront, explains to

the client the resolution of the complaint.\

3) If the complaint cannot be resolved immediately, explains to the

client the following timeline:

PROCEDURE SIMPLE* COMPLEX*

Acknowledgment Within 2 days Within 2 days
Processing and resolution (assess, Within 7 days Within 45 days
investigate and resolve)

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Communication of resolution Within 9 days Within 47 days
*All periods are reckoned from receipt of complaint.

The above timeline also applies on complaints received via telephone

or e-mail.

4) Transmits the CCF to Consumer Protection Unit via e-mail.

C) Consumer Protection Officer (CPO)

1) Shall acknowledge the complaints received from the Branch/H.O.

Unit.

2) Shall obtain and record the details of the complaints in the

Consumer Assistance Management System (CAMS)

3) Assigns the validated complaint to the concerned Support Group.

4) Generates and submits the Customer Complaint Summary Report

daily to the Consumer Protection Head.

5) Once a complaint has been resolved by the Support Group, CPO

shall tag it as closed in the CAMS.

D) Support Group

1) Retrieves the complaint received through the CAMS or e-mail, as

applicable.

2) Performs the necessary corrective actions based on the nature of

the complaint.

3) The resolution made shall be recorded accordingly in the CAMS or

reply via e-mail, as applicable.

E) Consumer Protection Head

1) Shall monitor and evaluate customer complaints handling process.

2) Analyzes the nature of the complaints and recommend solutions to

avoid recurrence.

3) Extracts generated complaints report monthly except when urgent

to be submitted and reviewed by the HR Head.

20
 4) Recommends the resolution of the case or if needed to be elevated
to proper authorities or needed to be taken up in the Committee on
Employee Discipline (CED) if applicable.

5) Reports to Senior Management on a quarterly basis the complaints

received and the resolutions applied.

6) Reports periodically to the Board all complaints received within the

period as stated.

7) Makes recommendation and assessment on the cases filed to

avoid recurrence in the future.

To assess if the complaints have been resolved at the highest degree of

satisfaction, the Bank also asks feedback through its Complaint Handling
Feedback Form (Annex B). This is sent via email to the concerned client after
a complaint’s resolution. In addition and to ensure consistency in the level of
service rendered after the complaint filing, the Bank monitors the
implementation of the resolution after 30, 60, and 90 days through Service
Recovery Strategy (SRS) Tracking System.

2. Telephone

A) Client/Customer

1) Shall call the H.O/Branch Unit, Consumer Protection Hotline or

PBB hotline, following the guide below:

Head Office Contact Numbers Time

Consumer Protection Direct Line
 (02) 8363-4357 9:00 AM – 4:00PM
 (02) 8244-9176 (Monday to Friday)
Domestic Toll Free Hotline
 1-800-1-888-4357
Card-related Concerns Hotline
 (02) 8363-3000 24 hours
Domestic Toll Free Hotline (Monday to Sunday)
 1-800-10-363-3000
Branch Contact Numbers Time
Branch Telephone Numbers 9:00 AM – 4:00PM
(Monday to Friday)

2) The client shall provide the complete details of the complaints.

B) Consumer Protection Officer (CPO) or PBB Helpdesk – Head

Office

21
 1) Shall validate and acknowledge the complaint received.

2) The details of the complaint shall be recorded in the Consumer

Assistance Management System (CAMS)

3) Assigns the validated complaint to the concerned Support Group.

4) Generates and submits the Customer Complaint Summary Report

monthly to the Consumer Protection Head.

C) Consumer Assistance Officer (CAO) – Branch

1) Shall acknowledge and validate the complaint received.

2) Details of the complaint shall be recorded in the CCF.

3) The CCF shall be transmitted to the Consumer Protection Unit via

e-mail or fax.

D) Support Group

1) Retrieves the complaint received through the CAMS or e-mail, as

applicable.

2) Performs the necessary corrective actions based on the nature of

the complaint.

3) The resolution made shall be recorded accordingly in the CAMS or

reply via e-mail, as applicable.

E) Consumer Protection Head

1) Shall monitor and evaluate customer complaints handling process.

2) Analyzes the nature of the complaints and recommend solutions to

avoid recurrence.

3) Extracts generated complaints report monthly except when urgent

to be submitted and reviewed by the HR Head.

4) Recommends the resolution of the case or if needed to be elevated

to proper authorities or needed to be taken up in the CED if
applicable.

22
 5) Reports to Senior Management on a quarterly basis the complaints
received and the resolutions applied.

6) Reports periodically to the Board all complaints received within the

period as stated.

7) Makes recommendation and assessment on the cases filed to

avoid recurrence in the future.

To assess if the complaints have been resolved at the highest degree of

satisfaction, the Bank also asks feedback through its Complaint Handling
Feedback Form (Annex B). This is sent via email to the concerned client after
a complaint’s resolution. In addition and to ensure consistency in the level of
service rendered after the complaint filing, the Bank monitors the
implementation of the resolution after 30, 60, and 90 days through Service
Recovery Strategy (SRS) Tracking System.

3. PBB E-mail

A) Client/Customer

1) May send their complaints/concerns through our Customer

Complaint E-mail address: consumerprotection@pbb.com.ph

2) The client shall provide complete details of the complaints.

B) Consumer Protection Officer

1) Shall acknowledge and validate the complaint received via e-mail.

2) The details of the complaint shall be recorded in the Consumer

Assistance Management System (CAMS).

3) Assigns the validated complaint to the concerned Support Group.

4) Generates and submits the Customer Complaint Summary Report

monthly to the Consumer Protection Head.

C) Support Group

1) Retrieves the complaint received through the CAMS or e-mail, as

applicable.

2) Performs the necessary corrective actions based on the nature of

the complaint.

23
 3) The resolution made shall be recorded accordingly in the CAMS or
reply via e-mail, as applicable.

D) Consumer Protection Head

1) Shall monitor and evaluate customer complaints handling process.

2) Analyzes the nature of the complaints and recommend solutions to

avoid recurrence.

3) Extracts generated complaints report monthly except when urgent

to be submitted and reviewed by the HR Head.

4) Recommends the resolution of the case or if needed to be elevated

to proper authorities or needed to be taken up in the CED if
applicable.

5) Reports to Senior Management on a quarterly basis the complaints

received and the resolutions applied.

6) Reports periodically to the Board all complaints received within the

period as stated.

7) Makes recommendation and assessment on the cases filed to

avoid recurrence in the future.

To assess if the complaints have been resolved at the highest degree of

satisfaction, the Bank also asks feedback through its Complaint Handling
Feedback Form (Annex B). This is sent via email to the concerned client after
a complaint’s resolution. In addition and to ensure consistency in the level of
service rendered after the complaint filing, the Bank monitors the
implementation of the resolution after 30, 60, and 90 days through Service
Recovery Strategy (SRS) Tracking System.

4. BSP Consumer Affairs Email

1) The Bank through consumer protection email also receives

complaints from BSP Consumer Affairs. These complaints are
addressed by the concerned units in accordance with the existing
Service Level Agreement (SLA).

2) All complaints received through different channels are lodged and

monitored through the Bank’s Consumer Assistance Management
System (CAMS). These are then regularly reported to BSP-

24
 Supervised Financial Institutions (BSFls) Consolidated Complaints
Report (BCCR) regularly (Please see attached Annex C). An
executive summary of these complaints and the corresponding
actions taken is reported to PBB’s Executive Committee and to the
Board of Directors.

3) Complaints, requests, and inquiries from financial consumers are

received, acknowledged, investigated, and resolved in accordance
with PBB’s process on handling customer complaints, requests,
and inquiries.

To assess if the complaints have been resolved at the highest degree of

satisfaction, the Bank also asks feedback through its Complaint Handling
Feedback Form (Annex B). This is sent via email to the concerned client after
a complaint’s resolution. In addition and to ensure consistency in the level of
service rendered after the complaint filing, the Bank monitors the
implementation of the resolution after 30, 60, and 90 days through Service
Recovery Strategy (SRS) Tracking System.

F. GUIDELINES IN FILLING UP OF CUSTOMER COMPLAINT FORM (CCF)

1) The Customer Complaint Form (CCF) shall serve as record and receipt of
complaints/requests from the clients/customer. Said form shall be used for
all transactions other than those ATM related transaction, which would
use the Bancnet prescribed form.

2) The required client’s information, transaction details and complaint details

should be obtained and recorded in the form.

3) Each CCF shall have a Reference Number, base on the following rules:

Example
Branch/Unit Code - MOB/HRG
Year - 2016
Sequence Number - 001

As such, Reference Number per example above would be:

MOB-2016-001,
HRG-2016-001

4) Immediately after receipt of the accomplished CCF, same should be sent

via e-mail or fax to Service Quality Center-Consumer Protection Unit. The
Customer’s copy portion (lower portion of CCF) shall be cut and given to
client for their reference.

25
 5) If Complaint is received after regular banking hours or during non-banking
days (thru the Helpdesk), acknowledgment shall reckon on the next
banking day.

6) Client has the option to report complaint through the Branch or directly to
H.O. c/o Training and Service Quality Center – Consumer Protection Unit.

G. ALTERNATIVE OPTION TO FILL OUT THE CUSTOMER COMPLAINT

FORM (CCF) AND COMPLAINT HANDLING FEEDBACK FORM

1) In compliance with safety and health protocols under the new normal
settings, the Bank is implementing the accomplishment of Customer Care
Feedback Form (CCFF) using the Quick Response (QR) code (Annex D)
as an alternative way of giving feedback regarding the customer service
experience encountered during the visit in the branch.

2) The CCFF may now be accomplished by using personal mobile phone.

Scan the QR code that the bank has provided and access the form. It is
important that the gadget being used is connected to wireless fidelity (Wi-
Fi) or mobile data.

3) If the customer/client is using iPhone/IOS device, it is advised to open the

Camera application and point the phone at the QR code. Make sure the
QR code is inside the box on the screen and then tap the pop-up
notification to start. If there is no notification pop up, proceed to the phone
setting then enable the Scan QR Codes feature.

4) If the customer/client is using Android Phone, press and hold the home
button of the phone then select the Lens. Point the camera at the QR code
then tap the magnifying glass icon and subsequently the pop-up
notification.

H. HANDLING OF DATA INFORMATION

1) In addition to the online accomplishment of Customer Care Feedback

Form, the Bank also added in the form an authorization by the
customer/client regarding the collection and processing of personal
information they provide the Bank and that these are protected under RA
10173, Data Privacy Act of 2012.

26
I. FUNCTIONS OF THE COMPLIANCE OFFICE

a. Prepares the Bank’s Compliance Program, updates the same and, in

coordination with concerned units of the Bank, ensures adherence to
Bank’s policies and procedures, relevant banking laws, rules and
regulations of the BSP, SEC, PDIC and other regulating agencies.
Assists concerned units identify compliance/business risks and
analyzes the corresponding sanctions for non-compliance;

b. Oversees and coordinates the implementation of the Bank’s

Compliance Program;

c. Conducts on site/off site compliance testing on pre-selected units of

the bank;

d. Ensures designation of Unit Compliance Coordinator (UCC) by the

respective group heads; provides concerned units with checklists of
regulatory and reportorial requirements of BSP, PDIC and other
regulatory agencies to serve as their guide in ensuring compliance
thereto; coordinates with the Bank’s Legal Services Division on Legal
issues;

e. Provides advisory services to offices and staff regarding their queries

on compliance matters; likewise, provides the front-line staff and
officers a clear understanding of banking laws, policies and regulations
of the BSP and other regulatory agencies;

f. Consults when necessary, with appropriate department of the BSP,

PDIC, SEC and other regulatory agencies regarding the interpretation
of certain provisions of laws or regulations, and Anti-Money Laundering
Council for the proper implementation of the requirements of the Anti-
Money Laundering Act, as amended on covered and suspicious
transactions and freezing of accounts;

g. Ensures submission of Covered Transaction Reports (CTR) and

Suspicious Transaction Reports (STR) on a bank-wide basis to the
AMLC within ten (10) days from occurrence thereof1;

h. Conducts preliminary evaluation of suspicious transaction reports and

convene the Anti-Money Laundering Committee of the Bank for the
final determination of the grounds for reporting to the AMLC if
necessary;

1
Section X807 of the MORB

27
i. Provides the Board and/or its appropriate committee with reports
concerning the Bank’s state of compliance with rules and regulations
of BSP and other regulatory bodies; and

j. Ensures dissemination of banking laws

********

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