Consumer complaint received 2021-02-24
Company: BARCLAYS BANK DELAWARE
State: CA
Product: Credit card or prepaid card
Sub-product: General-purpose credit card or charge card
Issue: Problem when making payments
Sub-issue: You never received your bill or did not know a payment was due

Complaint:
Follow-up response to Barclays response of XX/XX/XXXX ( attached ) to CFPB Complaint XXXX of XX/XX/XXXX : Dear Barclays Representative, Thank you for the prompt response to my initial Consumer Financial Protection Bureau ( CFPB ) inquiry. And thank you for clearly stating what Barclays protocols are and that they were followed. But as you did not address my second fair resolution recommendation, it is clear that you have missed the critical point. 

Technically, as you stated, all the existing protocols and processes were followed by Barclays personnel. But to state it directly, so that there is no misunderstanding, Barclays internal processes are inadequate when something goes awry. But they can be improved. The processes currently contain Single-Point-Failures and when those failures occur, they can cost your customers XXXX XXXX of dollars and severe degradation of their credit ratings which can lead to many other significant negative consequences. Let me explain from a technical perspective. 

First off, I want to clarify that I am not some annoying pest. I am a professional system designer that has lead the design of many complex aerospace systems as well as internal operating procedures and processes. That is why the Single-Point-Failures in Barclays internal processes are readily apparent to me. I am not trying to criticize Barclays, I am just acting as an outside non-advocate reviewer that has identified some escapes made by your process designers and providing recommendations on how to correct them. If Customer service is very important to us, as your CFPB complaint response states, then you should seriously consider the findings of this review, and proactively implement process improvements to eliminate the potential erroneous negative consequences for your customers. 

Understanding the Single-Point-Failures : " " Email is an inherently unreliable system. It is much better than it was, but with the onslaught of spam and countering spam-filters, emails may technically be received by the recipient but never seen. There are several other ways that email may not be received or seen, but spam filtering is a common one. It is because of these endemic complications with email that it is essential to establish a bidirectional email communication link before relying on it for critical mailings. 

The Barclays program to minimize internal costs by defaulting to email delivery ( paperless statement notifications ) is a valid attempt at improving efficiency, but it needs to be established with a reliability level appropriate for the consequences of failure. The current processes function fine when everything goes right, but they also need to be designed for potential failure conditions. Sending billing statement notifications via email have the potential Failure Mode of not being received and/or read by the customer for several reasons. If there is no other means of providing this information to the customer ( which there currently is not ), this communication approach has a Single-Point-Failure potential that will result in an interest charge and a late fee to the customer. And this is the worst kind of Single-Point-Failure because it is Unannunciated to both the sender and recipient, and thus it can be repeated over and over again, which is exactly what happens. The subsequent email communication failures have a 100 % probability of occurring since whatever caused the initial email communication link to fail is still in existence and the emails repeatedly go into a black hole. After two or three of these failed billing statement notifications, the Barclays process automatically reports the delinquency to the Credit Agencies and ruins the customers credit rating, which is a very significant consequence. 

In the CFPB response that Barclays provided, it is stated that Barclays notifies the customer before sending negative reports to the credit reporting agencies by including information About Credit Bureau Reporting on the back of the never received emailed billing statements. The failure to notify the customer before reporting them to the credit agencies is obviously subject to the same Single-Point-Failure that not receiving the billing statement is. This failure to notify is a Common Cause Failure as it will always occur when the initial Single-Point-Failures occur. 

Process XXXXedesign to Eliminate the Single-Point-Failures : " " What the current Barclays process is missing is Redundancy. It relies on only one unreliable and never verified system of communication. And that process can result in two levels of consequences to the customer ; an interest charge and late fees which have a negative financial impact, and detrimental credit agency reporting which can have serious financial and life altering impacts to a customer. The amount of Redundancy for each of these consequences can be different, but it needs to be appropriate for the level of significance. 

First off, if email is to be utilized for billing notifications, then a test email needs to be sent to the customer and returned to Barclays to establish a closed-loop email communication link. Barclays does this for the US Post Office mail communication link and the Telephone communication link when they mail the credit card to the customer who then validates that it was received by activating it via telephone. 

Secondly, just because an email link is established, it does not mean that the customer will always receive the paperless statement notification. Depending on the level of Customer Service quality that Barclays wants to establish, a follow-up USPS mailed invoice or a telephone call would provide an independent second communication link to eliminate the Single-Point-Failure of one emailed paperless statement. Dual Redundancy is the appropriate level for the interest charge and late fee consequence. 

Thirdly, if two or three paperless statements are not responded to and it is nearing the timeframe to provide a delinquency credit agency report, the consequence to the customer is significant enough that at least three independent means of communicating to them should be performed ( USPS mail, Return-Receipt mail, Telephone Call or Text, etc. ), or until an actual customer connection is made. It is essential that the customer be aware that there is going to be a negative credit agency report filed and given the chance to rectify the situation before the detrimental report is made. Triple Redundancy is the appropriate level for this consequence. In a world of cold and indifferent automation, reaching out to the customer would be a respectful and decent human courtesy. 

Conclusion : " " Hopefully my point is now clear on Barclays culpability in the unnecessary injurious credit bureau reporting that I, and undoubtedly several other folks, have experienced. And hopefully it is also clear that I am not trying to be hostile and am genuinely trying to help Barclays improve their customer service and consequent customers experience. Ideally, Barclays will see this letter as valid customer feedback, and will adapt to the current era of striving to provide an exceptional customer experience by proactively taking the recommended process design changes seriously. 

Please share this letter with XXXX XXXX. 

Thank You. 


P.S. 
As an indication of how readily Single-Point-Failures occur in Barclays processes, the letter from Barclays that was allegedly sent to me on XX/XX/XXXX was never received. The mention of it in Barclays response to this CFPB complaint was the first I have ever heard of it. If it was sent via email, you just reaffirmed my point about the unreliability of email. It also was not attached to the CFPB response as was stated, so I still do not know what it said.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation