New York Department of Financial Services (NYDFS) Guidance Regarding Customer Service Requests and Complaints

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The NYDFS has been reviewing consumer complaints and has found that Virtual Currency Entities’ (VCE) processes and documentation relating to customer service requests and complaints are insufficient and in need of additional enhancements.

Quarterly reporting/tabulation becomes a requirement September 1, 2024, and will be expected during exams or upon request by the NYDFS. Enhanced program documentation will be subject to NYDFS request and reviews on November 1, 2024.

Treliant has considerable experience in developing strong customer service requests and complaint resolution programs across various financial services firms, including VCEs.

Our team understands the letter and spirit of the guidance and will work with VCEs to:

  • Uplift policies, procedures, and processes.
  • Review existing customer service logs.
  • Create FAQs to enhance the customer service experience and comply with regulatory expectations.
  • Build quarterly reporting capabilities consistent with the guidance expectations.


The NYDFS expects that VCE customer service and complaint resolution programs will have or incorporate the following controls that are documented in writing:

  1. Enhanced monitoring and maintenance of phone and electronic text communication records.
  2. Monitoring has properly trained human representatives.
  3. Specific criteria for phone and electronic text communication with clients.
  4. Customer inquiry and claim resolution updates that are detailed, accurate and timely.
  5. Written FAQs associated with themes of inquiries and complaints with general company guidance for how customers can address independently.
  6. Quality assurance program for customer interactions.
  7. Customer inquiry and complaint reporting capabilities for examination and as requested.

What Does This Mean for VCEs?

VCEs, and more specifically, the CRO, CCO, and CTO, must take immediate action to meet the September and November timetable. Enhancement timelines, project plans, and milestone tracking need to be produced and distributed by a “change the VCE” project team.

VCEs should consider using independent third parties so that they can understand what other institutions are doing to be compliant with these expectations as well as for “change the VCE” project management.

VCE data systems will need to be updated to collect the required information and to be ready to submit upon request or during examination.

Ready to Talk?

We work with you to understand your needs, so we can tailor our approach to your engagement. Learn more when you connect with our team.


Mike Scarpa

Mike Scarpa is a Managing Director in Treliant’s Regulatory Compliance, Mortgage, and Operations Solutions practice. He helps set Treliant’s regulatory compliance/operations agenda, including key trends, solution offerings, and client pursuits. He also executes on regulatory compliance projects and serves as a subject matter expert.