Major Regional Bank -- Head of Fair and Responsible Banking - Executive Director

NOTE: Britt Faircloth is at Citizens Bank but the posting is not a position with Citizens. She can facilitate an introduction for interested CFPB alum, send indications of interest to Britt.M.Faircloth@citizensbank.com

Major Regional Bank
Location: Remote
Job Title: Head of Fair & Responsible Banking – Executive Director
Reports to: Chief Compliance Officer

About the Company
1. Being the right-sized financial services company for middle market and corporate businesses is the foundation of the company. Few companies combine our five decades of serving the California middle market with the global presence provided by a large international conglomerate, the parent of our holding company. We are consistently one of the most financially sound companies in California, with several billion in assets as of June 30, 2019. We are equipped to provide the right mix of financing services to help your business grow.
2. To achieve our mission to be the “company of choice” for middle market and professional services companies, we are focused on our vision to be the premiere California regional financial services company that can provide the sophistication and expertise of a larger institution with the personal “high touch” services of a smaller company.
3. We are a subsidiary of a global financial services conglomerate that operates in over 30 countries, including branches and representative offices in Asia, Oceania, Europe, Middle East, Africa, and the Americas.

Job Summary:
The Executive Director, Head of Fair and Responsible Banking is responsible for the management and performance of the bank’s Fair and Responsible Banking Program, including Fair Lending; Unfair, Deceptive, or Abusive Acts or Practices (UDAAP); Servicemember Protections; Community Reinvestment Act; and Complaints Management.

Principal Duties and Responsibilities:
a) This role will report directly to the Chief Compliance Officer for the organization. The total team within Compliance is around 90 people.
b) Direct reports into the Chief Compliance Officer include:
i. Head of Financial Crimes Compliance
ii. Head of Governance, Programs and Reporting
iii. Head of Compliance Advisory
iv. Head of Fair and Responsible Banking (this role)
v. Head of Privacy
c) This role sits in Second Line of Defense and will oversee all of Fair Lending, UDAAP, Compliance and Community Reinvestment Act (CRA).
d) This role will manage a team of 3 direct reports.
i. ED Community Reinvestment Act Officer (CRA)
ii. Director of Fair Lending (open requisition)
iii. Director of UDAAP and Complaints
e) In total there are 2 FTE that sit under the Chief CRA Officer and another 3 FTE under the Director of Fair Lending.
f) The Fair & Responsible Banking office provides the expertise for all Fair Lending topics. This office will opine separately from the business advisory team on the specific attributes that feed into the model and all Fair Lending or UDAAP matters. They provide feedback throughout the entirety of the process from the Pricing Committee, Marketing Compliance team, etc.
g) There is a FLOD team that manages Complaints. This Complaints team logs the complaints and then is responsible for reviewing the Complaints and then actioning them.
h) The Fair & Responsible Banking group has several assessments that they must execute like the Fair Lending Risk Assessment, UDAAP Risk Analysis, Loan Regression Analysis, CRA Compliance, etc.
i) There are no major projects on the docket in the near term, but there are several process enhancements that need to be addressed. Some of this revolves around UDAAP and maturing the Fair Lending program.
j) The bank is in the process of building out and launching their Credit Card Division. They are at the beginning of developing this model.
k) Act as subject matter expert and advise the lines of business, operational areas and Compliance colleagues on Fair and Responsible Banking issues, including business initiatives and regulatory changes.
l) Manage the execution of the Fair & Responsible Banking governance framework.
m) Provide strong leadership skills in spearheading discussions with senior management, engaging stakeholders, clearly articulating issue and identifying collaborative solutions to mitigate risk.
n) Provide oversight in matters regarding statistical analysis, regression and model risk management.
o) Oversee performance of detailed and rigorous assessments regarding business and operational processes and procedures; analyzes results and makes recommendations on the adequacy and reliability of controls.
p) Oversee performance of annual fair lending risk assessment and periodic fair lending reviews (underwriting, pricing, marketing, redlining, steering, etc.) to evaluate the bank’s level of compliance with fair lending laws, regulations, and guidance
q) Oversee performance of periodic UDDAP/Customer Fairness assessments
r) Oversee performance of Bank’s Community Reinvestment Act program
s) Oversee performance of 2nd line Complaints Management program
t) Research regulations, staying apprised of regulatory developments and conduct impact analysis for respective lines of business.
u) Develop and prepare Board and management reporting on applicable program components and metrics.
v) Assist in the coordination of audit and exam materials.