Consumer Compliance and CRA Manager

Senior-level officer responsible for developing, implementing, and administering all aspects of the Consumer Compliance Program and the Community Reinvestment Act (CRA) program.

Responsibilities:

• Develop, communicate, and implement the strategic vision for consumer compliance risk mitigation in support of the bank’s priorities and business initiatives. Provide proactive strategic and tactical leadership for consumer compliance initiatives.
• Develop and maintain governance for the Consumer Compliance Programs, including independent interaction with the board of directors, executive management, and regulatory authorities. Set the agenda and key discussion topics for the Compliance Governance Committees. Agenda topics include all monitoring reviews and their results; all past-due action plans; new and/or amended regulations; internal and external training scheduled, provided, and attended during the quarter; complaints received during the quarter, their root causes, and recommended corrective action; and loan pricing and underwriting exceptions, including the Fair Lending status of those exceptions.
• Develop, implement, and maintain enterprise-wide and departmental policies to manage compliance risk, and supervise the Compliance Risk Assessment and Policy Unit. Set the bank’s appetite for Compliance risk. Review and approve all new and revised products, processes, channels, delivery systems, advertisements, and marketing campaigns, and ensure that appropriate mitigants are established to reduce the risk of violations of law. Build consensus with senior management and the board of directors for compliance initiatives.
• Maintain extensive expertise in compliance regulations, regulatory issuances and examination materials, industry trends, and best practices. Monitor pertinent regulatory changes and analyze the impact of new and revised regulations on the bank’s business, operational, and compliance processes. Update testing processes as required.
• Perform risk assessment analyses of the functions under direct testing supervision and responsibility to determine compliance-review frequency and develop the Annual Plan. Develop the Annual Plan as a risk-based annual consumer compliance monitoring plan and adjust it on an interim basis. Direct its implementation and completion, with responsibility for the overall quality of work performed. Direct and control compliance testing to mitigate exposure to regulatory sanctions, fines, and penalties and to ensure compliance with federal and state regulations and organizational policies and procedures. Approve and validate corrective action plans.
• Develop the annual compliance training needs assessment and ensure its execution. Use the assessment to develop appropriate training programs, oversee program execution, and maintain adequate records of both the assessment and training program. Prepare and present training for the Board of Directors and Senior Management.
• Lead consumer compliance due diligence and integration teams for all mergers and acquisitions. Prepare risk analysis of merger targets and report analysis results to the Consumer Compliance Committee, Board of Directors and Senior Management.
• Identify, evaluate, and report to Senior Management and Consumer Compliance Committee any current or prospective risks from potential violations of, or nonconformance with laws, rules, regulations, and prescribed practices.
• Lead and direct the work of others, including hiring, performance coaching, evaluation, and corrective action when necessary to address performance problems. Coordinate and provide training to Consumer compliance monitoring staff as needed to achieve objectives and support professional development.
• Ensure that filed cases are reviewed, and conduct reviews, when necessary, to identify customer complaints involving potential regulatory issues or concerns. Determine the root causes, work with the respective staff to correct the issues, and follow up on the status of corrective action.
• Lead consumer compliance officers in preparing for and supporting regulatory examinations by the OCC, Federal Reserve, and State of Florida. Ensure that supervisory authorities receive information presenting the bank’s consumer compliance programs as effective, thorough, and compliant with the law. Ensure that any corrective action is implemented effectively and efficiently within required time frames and reported promptly to the Board of Directors and the Consumer Compliance Committee.
• Identify, evaluate, and monitor current or prospective risks to earnings or capital arising from violations of, or nonconformance with, laws, rules, regulations, prescribed practices, internal policies and procedures, or ethical standards. Make recommendations to the respective Risk Management Committee to assess, reduce, eliminate, or control those risks.
• Engage with the business and Enterprise Data Management Office to identify and help remediate data related items including but not limited to data quality, data classification and data descriptions.
• Supervise the Bank’s Fair Lending program and ensure completion of its analysis, testing, risk assessment, and reporting activities. Analyze approved and denied loans using a data analytics program and HMDA-reportable loans. Review pricing and underwriting exceptions through comparative file testing to determine whether Fair Lending violations occurred. Perform peer-bank analysis to determine whether the Bank’s lending practices are in line with those of peer banks and conduct redlining analysis to determine whether customer segments within the Bank’s assessment areas have been inadvertently overlooked. Oversee or perform the annual Fair Lending Risk Assessment and present it annually to the Board Audit, Executive, and Consumer Compliance Committees. Keep abreast of regulatory changes and industry comments, advisories, bulletins, and other materials concerning Fair Lending.
• Ensure that HMDA Data Integrity is reviewed quarterly. Ensure that a report of Loan Pricing and Underwriting exceptions is prepared and presented to the Consumer Compliance Committee quarterly. Ensure that the HMDA LAR is transmitted annually by March 1.
• To identify, evaluate, monitor, and make any recommendation deemed necessary to their respective Risk Management Committee in order to assess, reduce, eliminate or control any current or prospective risks to earnings or capital arising from violations of, or nonconformance with, laws, rules regulations, prescribed practices, internal policies and procedures or ethical standards.

Minimum Education and/or Certifications Requirements:

Bachelor’s degree required; an advanced degree such as a juris doctor is a plus. A bachelor’s degree in Business Administration or Liberal Arts is preferred. Certified Regulatory Compliance Manager (CRCM) or other professional certification preferred.

Minimum Work Experience Requirements:

• At least 10 years of related experience, including experience working closely with regulatory agencies.
• Related experience may include compliance-focused Internal Audit, Risk, Loan Review, or work with a regulatory agency.
• Prior experience managing a department and team of professionals.
• Contacts with community leaders and nonprofit organizations preferred. Service on community boards of directors or committees preferred.

Technical and/or Other Essential Knowledge:

• Extensive knowledge of consumer compliance regulations, including the ability to create an effective and efficient compliance management system. Required knowledge includes regulatory requirements; loan and retail operations and documentation; banking products; the Community Reinvestment Act; and general knowledge of demographics and statistical analysis. Auditing skills are helpful.
• Required technical experience includes Lotus Notes, Internet use, advanced MS Office skills in MS Word, MS Excel, and MS PowerPoint, MS Project Level II, and MS Visio Level I.