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STEP

ACTION

1

2

  • Seek approval to notify Compliance:

    • Internal Comment:

      • Summarize the matter

      • Provide a brief overview of actions taken during your investigation

      • Note any relevant findings/discoveries

      • Request approval to involve Compliance

    • Tag: Cassandra Mercado and Sabin Abad

    • Go to Step 3

3

  • Was approval received by a Team Supervisor?

    • If yes,

      • Update the EBH ticket status to: “Waiting on Compliance”

      • Go to Step 4

    • If no, follow appropriate process(es) and Stop

Info

Note: Updating the EBH ticket status will create a duplicate, linked POLICY ticket in a separate project: EB Compliance. This will allow you to facilitate conversation internally with the Compliance team. When customer interaction is necessary, it would be done via the original Support ticket.

4

  • Locate the linked POLICY ticket created

  • Update the ticket:

    • Reporter(s): Aileen Kozlowski

    • Request Participants: Steven Edwards, Christopher Strain, Cassandra Mercado

    • Ticket Status: “Waiting on Compliance”

    • Comment:

      • Include an overview of the matter, actions taken, findings made, copies of any supporting documents, Engine job link, and request review/input by the Compliance

Info

Note: Ensure you frequently monitor the ticket for updates.

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_Examples
_Examples

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QUALIFIERS FOR COMPLIANCE’S INVOLVEMENT

  • A lawsuit has been filed

  • A customer/customer’s attorney is contacting EverBright to obtain Legal’s information

  • The Attorney General of the customer’s state notifies EverBright of a filed complaint

    • The potential exposure involves $10,000 in cash payments or the value of products/labor provided

    QUALIFIERS

    FOR COMPLIANCE’S INVOLVEMENT

    • Claims of fraudulent and/or unlawful actions and activities (e.g., falsifying records, mischaracterizations, nonregistered/unlicensed company/contractor)

    • Agreement violations

    • Customer privacy violations

    Info

    Note: A customer threatening to hire an attorney, threatening to file a lawsuit, or alleging that they have an attorney are not qualifiers to escalate to Legal. The customer must explicitly state they have performed one of these actions in order to escalate the matter to Legalcompliance issue is any violation or failure to adhere to laws, regulations, policies, or ethical standards that govern an organization's operations. If there is doubt on whether or not a matter requires Compliance’s involvement, please seek validation from Cassandra Mercado.