customer service. While the service can help better serve members by providing timely answers to questions, there are compliance issues that can arise. Although some chatbots are limited to a set menu of questions or categories of information, others can be more complex and mimic conversation. These more “free-flowing” interactions between a member and chatbot can create potential for compliance risks. “If a member using a chatbot notifies the credit union about a transaction error with a debit card or a service such as Zelle, Regulation E requires that the credit union begin an investigation within 10 days of the notice of error, even if it is in a chatbot,” said St. John. To ensure compliance, organizations must set up a monitoring program for the chatbot that captures specific words or phrases such as “unknown transaction” or “error” and sends the information to a person who can review the conversation and take appropriate action. The other issue that the Consumer Financial Protection Bureau has reported are complaints from consumers about chatbot “doom loops” that send consumers in circles without resolving a problem, answering a question or offering to connect them to a human. “It is always a good idea when using technology to communicate with members to offer them the ability to call a human being,” said St. John. Not only does the pathway to a person help the credit union avoid creating a negative image of its service to members, but it reinforces the industry’s commitment to “people helping people.” “ Chatbots or automated messages on websites and in credit union apps are a convenience for members who want to ask questions outside traditional business hours or during the day when they are unable to make a phone call to customer service. While the service can help better serve members by providing timely answers to questions, there are compliance issues that can arise. ” 15 THE NAFCU JOURNAL November–December 2023
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