Fair Banking Officer

Job Description

Job Description

The Fair Banking Officer is responsible for developing, implementing, and administering all aspects of American Riviera Bank’s Fair Lending Program with primary responsibility for ensuring adherence to all fair lending and banking laws and regulations and upholding ethical practices within various product lines such as mortgage, small business, auto lending, personal loans, and retail products. Assists in the administration of the Bank’s compliance program. Responds to compliance questions from Bank staff and supports efforts to comply with laws and regulations. Maintains a thorough knowledge of federal and state regulations to assist in researching, preparing, implementing, maintaining, developing, and tracking Bank compliance for new and existing products and services. Implements and maintains monitoring disciplines, escalation, and reporting standards. The Fair Banking Officer advises Executive Management of emerging Fair Lending issues to ensure objectives are maintained.

Responsibilities and Expectations:

1. Oversees the Bank’s Fair Lending Policy and Program throughout the organization, serving as the primary point of contact for fair lending and banking matters within the Bank, interacting with Board members, senior leadership, and external auditors/regulators.
2. Develops and implements monitoring routines and procedures for the Fair Lending Program, tailored to each product and/or relevant line of business. This should include ongoing monitoring and testing of exceptions to ensure there are not trends indicating fair lending issues exist as well as identifying exceptions that are routinely granted that should be incorporated into procedures, standards, pricing, policies, etc.

1. Performs analyses to detect potential discrimination such as redlining, steering, and disparities in loan underwriting, pricing, and loss mitigation outcomes. Analyzes Fair Lending data across different product lines to identify trends, risks, and opportunities for improvement.
2. Investigate possible concerns by reviewing samples of loan files and report findings and recommendations in written reports and meetings with stakeholders.
3. Lead and complete fair lending risk assessments and applicable required documentation in the Bank’s fair lending analytics and GRC software.
4. Oversees the monitoring of credit risk, marketing, and pricing models in various lending areas to ensure they are free of discriminatory practices.
5. Responds to Fair Lending and Fair Banking compliance questions from Bank personnel.

1. Ensures organization-wide compliance with Regulation B, HMDA, the Fair Housing Act, UDAAP, state fair lending laws, and other relevant regulations, particularly as they apply to mortgage, small business, auto, personal, and retail credit lending.

1. Provide training and guidance to Bank staff on fair lending practices and policies, with specific focus on various lending products.

1. Prepare and present reports to the Board and senior leadership, highlighting program performance, risks, and achievements in different lending areas.
2. Assists the Compliance Manager and CRO/Community Reinvestment Act (CRA) Officer with emerging compliance issues and consults and guides in establishing controls to mitigate risks.

1. Represents the Bank with a high level of integrity, professionalism, and technical expertise.

1. Adheres to Equity Bank’s Core Values, policies and supports management decisions and goals in a positive, professional manner.
2. Complete file audits to assess the level of compliance with specific regulations, including but not limited to Equal Credit Opportunity Act, Truth-in-Lending Act, Real Estate Settlement Procedures Act, Fair Housing Act, Home Mortgage Disclosure Act, Flood Disaster Protection Act, Fair Lending and USA Patriot Act. The review process includes but is not limited to:
   1. Selecting a representative sample of originated and non-originated files for review.
   2. Conducting interviews with staff and management regarding standard practices and procedures.
   3. Analyze selected files to determine level of compliance with specific laws and regulations.
   4. Consolidate issues noted during review and prepare a written report of findings including a summary of overall findings, a list of detailed exceptions and recommendations for improvement.

1. Perform UDAAP marketing compliance reviews.
2. Administer procedures for addressing customer complaints including internal points of contact.

1. Complete Home Mortgage Disclosure Act (HMDA) file audits on closed and non-originated loan files to ensure compliance with Regulation C/HMDA. The review process includes but is not limited to:
   1. Perform individual file monitoring.
   2. Consolidate issues noted during monitoring reviews and prepare a written report of findings including a summary of overall findings, a list of detailed exceptions and recommendations for improvement.
   3. Coordinate efforts with other departments to maintain and prepare the HMDA LAR for annual filing.
2. Assist Management in new product or service initiatives to ensure compliance with applicable laws and regulations prior to implementation.
3. Assist during examinations or audits (both internal and external), including following up on and assisting in resolving cited violated and/or deficiencies.

1. Other responsibilities and duties as assigned.

General:

• Treats people with respect; keeps commitments; inspires the trust of others; works ethically and with integrity; upholds organizational values; accepts responsibility for own actions.
• Completes administrative tasks correctly and on time; supports the Bank’s goals and values; benefits the Bank through outside activities.
• Comply with all applicable OSHA safety standards, including:
  • Read the workplace safety and health poster at the jobsite.
  • Report hazardous conditions to your supervisor and/or HR
  • Report any job-related injury or illness to your supervisor and/or HR, and seek treatment promptly.

Compliance

1. Complies with all bank policies and procedures and all applicable government regulations including, but not limited to:
   • Ensuring products and advertising comply with applicable regulations;
   • Staying current and knowledgeable of all policies, procedures and regulations related to the job functions, and completing all assigned training on time, requesting additional training as needed to be proficient in all job responsibilities;
   • Cooperating with internal and external auditors and bank examiners by providing full cooperation and timely delivery of requested documentation and information; and
   • Reporting concerns about compliance to the CCRO to enable prompt remediation.

1. Complies with Bank policies and procedures relating to the Bank Secrecy Act (BSA), and Anti Money Laundering (AML) and Office of Foreign Asset Control (OFAC) guidance. Report suspicious activity to the BSA Department through a Suspicious Incident Report (SIR).
2. Adheres to privacy and information security policies, and ensure all sensitive internal and external customer information is properly secured and safeguarded. Use secure methods delivering client and/or confidential data by email.
3. Demonstrates knowledge of and adherence to Equal Employment Opportunity (EEO) policy; shows respect and sensitivity for cultural differences; educates others on the value of diversity; promotes working environment free of harassment of any type; builds a diverse workforce and supports affirmative action.
4. Maintains a working knowledge of banking laws and regulations.
5. Maintains a professional level of industry and compliance proficiency by attending banking industry and compliance seminars and subscribing to applicable periodicals.

Required Skills & Education:

These specifications are general guidelines based on the minimum experience normally considered essential to the satisfactory performance of this position. The requirements listed below are representative of the knowledge, skill and/or ability required to perform the position in a satisfactory manner. Individual abilities may result in some deviation from these guidelines.

• Bachelor’s degree in law, finance, business administration, or a related field or equivalent related experience of at least 5 years in a compliance role with subject matter expertise in fair lending, including experience with mortgage, small business, auto lending, personal loans, and/or retail credit products. A master’s degree and/or relevant certifications (e.g., CRCM) would be a plus.
• Comprehensive understanding of fair lending laws including Regulation B, HMDA, Fair Housing Act, UDAAP, and state fair lending laws, as they apply to various lending products.
  • Excellent analytical, organizational, critical thinking, and presentation skills. Proficiency in creating and delivering presentations to various stakeholders.
  • Strong verbal and written communication skills, with experience in interacting with Board members and senior leadership; ability to communicate effectively and project a professional image when giving and taking information in writing, in person and over the phone.
  • Proven track record in implementing or significantly contributing to a fair lending program (or equivalent), with specific experience in mortgage, auto, personal, and/or retail credit lending.
  • Good interpersonal skills with the ability to effectively work with individuals and groups at all organization levels; ability to work independently and as part of a team.
  • Ability to take initiative and prioritize tasks; excellent time-management, problem-prevention, and problem-solving skills.
  • Ability to maintain confidentiality of sensitive information.
  • Proficiency in Microsoft office and other Windows-based systems required; and CRA Wiz or QuestSoft (or other fair lending analytic software) preferred.
  • Experience and education in meeting requirements of state and federal banking laws and regulations.

Working Conditions & Physical Requirements:

The work environment characteristics described here are representative of those an employee encounters while performing the essential functions of this job.

The employee will be situated in an office type setting in which he or she is free to move about at will. It may include some minor annoyances such as noise, odors, drafts, etc.

The employee in the course of performing this position spends time writing, typing, speaking, listening, lifting (up to 20 pounds), driving, carrying, sitting, pulling, walking, standing, squatting, kneeling and reaching.

The employee for this position may operate any or all of the following: telephone, cell phone, copy and fax machines, adding machine (calculator), scanner and image systems, personal computer and related printers, or other equipment as directed.

The physical demands described here are representative of those that must be met by an employee to successfully perform the essential functions of this job.