Our client, a leading financial services firm, is looking for a Director, Fair Lending to join their growing team.
03rd May, 2022
Job Description & Synthesis
This position will report to the VP, Regulatory Risk and Fair & Responsible Banking Officer and is responsible for the implementation and management of our client's Fair & Responsible Banking Programs including Fair Lending and CRA. This position works with the business operation teams to conduct detailed compliance examinations and reviews of company business and third-party servicers to ensure compliance with applicable laws, regulations and internal policies and procedures. This includes working with the Fair and Responsible Banking Officer to develop and execute the fair lending testing plans; develop and maintain the Fair & Responsible Banking programs, policies, procedures and education; and performing an annual risk assessment.
The Director, Fair & Responsible Banking will work both independently and in conjunction with other Compliance mangers and management to identify, evaluate and mitigating fair lending risks across the enterprise including during the proposed change or implementation of new products, services or process changes. This position is responsible for working with operations and executive management to identify and analyze gaps and weaknesses in business processes, systems and ensure corrective actions are taken to mitigate any risk. The Director will also have oversight responsibility for the Bank’s CRA program through the management of the CRA Officer. The Director, Fair & Responsible Banking will prepare appropriate risk metrics, and reports on the Fair & Responsible Banking programs for management and board of directors’ committees as required.
Specific Responsibilities
Ensures and maintains appropriate controls are in place to manage fair lending and CRA risk.
Prepares annual Business Area and Board Fair & Responsible Banking training.
Conducts a Fair Lending Risk Assessment (“FLRA”) annually to identify and assess risks as they relate to fair lending compliance throughout the entire loan life cycle.
Oversee conduct risk assessments for CRA and other supporting business area coverage as defined by the Risk Management risk assessment methodology.
Develops, coordinates and implements an annual fair lending testing plan to ensure compliance with applicable requirements.
Reviews and evaluates alleged discrimination complaints no less than quarterly to assess resolution, response and trends to determine if actions or enhancements are recommended.
Keeps current on fair lending related laws and regulations and communicate them across the company.
Compares current and proposed business and support area practices with fair lending-related best practices.
Works with business and support areas to develop and/or revise processes and controls to be fair lending compliant.
Provides direction concerning Fair Lending or Compliance Training matters associated with projects.
Identifies, evaluates and mitigates fair lending risks by assessing new products, services or process changes.
Identifies and develops a plan for future testing or other detective controls to ensure that implementation of the new product, service or process change will comply with applicable fair lending laws and regulations.
Ensures issues are identified early, that all project team members understand the implications so that the path of the project adjusts appropriately to ensure compliance with applicable requirements.
Prepares appropriate risk metrics, and report on the Fair Lending program for management and board of directors committees as required.
Provides management with reporting and trending analysis on results of testing and monitoring.
Provides summary reporting on results.
Tracks issues noted during testing and monitoring to ensure remediation efforts are on track
Validates that issues deemed closed by management have been appropriately mitigated.
Provides summary reporting on issue status and resolution.
Key Responsibilities
Bachelor’s degree or equivalent experience.
7+ years of consumer and/or regulatory compliance experience acquired in a compliance consultant-type role for legal, compliance, examination or audit (preferably within finance services industry), or a combination of 5+ years in consumer regulatory/compliance experience with a law degree/CRCM.
6+ years of operational knowledge of business lines supporting consumer lending.
Ability to understand complex regulatory requirements.
Strong/Proficient knowledge in ECOA(Reg B), Fair Lending, CRA and UDAAP.
Some degree of knowledge regarding the following regulations: FDCPA, GLBA, FCRA and FACTA, Global Privacy, BSA/AML/OFAC, TILA (Reg Z), FTC Credit Rules, E-Sign.
15% travel.
Ability to understand complex regulatory requirements.
Strong oral and written communication skills.
Proven ability to maintain strict confidence in challenging circumstances.
Excellent organizational, project management, and problem solving skills with a strong attention to detail.
Experience working on multiple concurrent projects and under tight deadlines.
Must demonstrate the ability to work well with people from many different disciplines with varying degrees of knowledge.
Solid proficiency in Microsoft Office applications.
Preferred Education, Skills and Experience
Certifications in regulatory, audit or risk management disciplines.
Experience with credit, underwriting, pricing and/or modeling