Grand Bank - Fair and Responsible Banking Officer

Job Summary Grand Bank for Savings, FSB ("Grand Bank" or "the Bank") is seeking a Fair and Responsible Banking Officer to serve as the subject‑matter expert on FairLending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) compliance across all products, delivery channels, and customer touchpoints. The Officer will lead a team of compliance professionals, provide second‑line defense oversight, and partner with business lines, compliance, marketing, digital, payments, and credit card program teams to embed fair‑banking principles into product design, customer communications, and lifecycle management. Essential Duties and Responsibilities Fair Banking Program Oversight: Develop, implement, and maintain an effective second‑line Fair and Responsible Banking (Fair Lending and UDAAP) compliance program across all Bank products and services. Establish and maintain fair banking risk governance standards, including alignment with the Bank’s risk appetite and escalation frameworks. Provide independent review, challenge, and oversight of business line activities to ensure fair treatment of customers and compliance with applicable regulations. Conduct enterprise‑wide fair banking risk assessments, incorporating deposit, digital banking, ACH/payment flows, and credit card products. Coordinate with the CRA Officer to align fair banking risk assessments with CRA objectives and equitable credit access. Digital Banking, ACH, and Payments Oversight: Oversee fair banking risks within digital banking platforms, including account origination, servicing, disclosures, and customer experience. Review and challenge ACH and payment‑related practices for compliance with NACHA rules, Regulation E, and UDAAP expectations. Monitor customer journeys across digital channels to identify potential disparate treatment or unfair practices. Partner with operations and technology teams to ensure fair and compliant design of automated decision‑making, workflows, and customer communications. Monitor and manage the Bank's overdraft program, reviewing program parameters, fee structures, and customer impact metrics. Review automated decisioning models, algorithms, and credit policies for fair lending and UDAAP risk. Monitor developments in consumer financial data rights and emerging open banking frameworks for fair banking implications. Oversee error resolution processes, including ACH disputes and unauthorized transactions, to ensure fair outcomes. Credit Card Program Governance: Provide fair lending and UDAAP oversight for the Bank’s national credit card program across underwriting, line assignment, pricing, fees, marketing, and servicing practices. Review credit card disclosures, marketing materials, and lifecycle communications for compliance with Regulation Z, UDAAP, and card network expectations. Analyze credit card portfolio performance for potential disparate impact or unfair practices. Support oversight of third‑party processors, issuing platforms, and marketing partners to ensure alignment with fair banking requirements. Oversee credit card marketing, pre‑screen, and solicitation practices for compliance with fair lending and UDAAP expectations. Provide oversight of credit card collections, hardship programs, and loss mitigation strategies for fair lending and UDAAP risk. Monitoring, Testing, and Analytics: Perform ongoing monitoring, testing, and analytics to detect fair lending and UDAAP risks across products and channels. Coordinate with the Model Risk Management (MRM) function to incorporate fair lending risk into every credit‑decisioning model validation. Conduct comparative file reviews, matched‑pair analysis, and peer benchmarking. Oversee complaint monitoring, categorization, and root cause analysis across all channels, ensuring timely escalation and remediation of systemic issues. Support HMDA data integrity, analysis, and reporting, including preparation of management‑level insights and recommendations. Support implementation of small business lending data collection requirements under ECOA Section 1071, including oversight of data integrity and reporting. Develop and maintain data‑driven monitoring frameworks, dashboards, and key risk indicators to proactively identify fair banking risk trends. Advisory and Business Line Support: Serve as a trusted advisor to business lines on new products, initiatives, and strategic changes, ensuring early identification and mitigation of fair banking risks. Review and approve marketing materials, customer communications, and product changes for fair lending and UDAAP compliance. Provide guidance on remediation strategies for identified risks, including corrective action plans. Governance, Training, and Reporting: Develop and deliver fair banking training tailored to business lines, including digital, payments, and credit card teams. Provide fair banking oversight of third‑party relationships, including fintech partners, marketing firms, digital platform providers, and payment processors. Prepare clear, concise reporting for senior management and Board committees on fair banking risks, trends, and program effectiveness. Assist in regulatory examinations and audits, coordinating requests, responses, and remediation efforts. Maintain current knowledge of regulatory developments, enforcement actions, and industry best practices. Minimum Qualifications (Knowledge, Skills, and Abilities) Bachelor’s degree or equivalent experience. 7+ years of progressive experience in fair banking compliance, fair lending, or CRA, with at least 3 years in a leadership or officer‑level role. Experience working in or alongside a second‑line defense risk management or compliance function. Experience launching or supporting a national credit card program. Prior interaction with OCC or FDIC examinations; familiarity with CFPB rulemaking, enforcement actions, and supervisory priorities. Demonstrated experience with digital banking platforms, ACH/NACHA rules, and/or payments ecosystems. Experience supporting or overseeing credit card programs, including knowledge of Regulation Z and card lifecycle processes. Strong knowledge of Fair Lending laws (ECOA/Reg B, HMDA), UDAAP, Regulation E, and applicable regulatory guidance. Familiarity with MRM frameworks (SR 11‑7 or OCC equivalent), including documentation and governance expectations for automated decision‑making models. Experience with statistical fair lending testing methodologies (regression analysis, matched‑pair analysis, marginal effects analysis). CRCM strongly preferred; candidates without the designation should have a clear path to certification or a comparable advanced compliance credential (e.g., CAMS, CCEP). Strong analytical skills, including ability to interpret data, identify trends, and assess risk across multiple products and channels. Excellent written and verbal communication skills, with the ability to present complex topics to leadership. Proven ability to operate independently, manage multiple priorities, and influence cross‑functional stakeholders. High level of integrity, professionalism, and attention to detail. Benefits 401(k) and Profit Sharing Health Insurance Dental Coverage Plan Vision Coverage Plan Disability Insurance Life Insurance Paid Time Off Community Service PTO Match (Bank approved) Tuition Reimbursement Incentive Eligible Physical Demands and Work Environment The physical demands described here are representative of the demands that must be met by an employee to successfully perform the essential functions of this position. Reasonable accommodations may be made to enable individuals with disabilities to perform the functions. While performing the duties of this position, the employee is regularly required to speak or hear, use hands or fingers, handle or feel objects, tools, or controls, stand, walk, sit, and reach with hands and arms, and occasionally lift and/or move objects up to 25 pounds. Visual acuity requirements include close, distance, and the ability to adjust focus. The noise level in the work environment is usually low to moderate. NOTE: This job description in no way states or implies that these are the only duties to be performed by the employee(s) incumbent in this position. Employees will be required to follow any other job‑related instructions and to perform any other job‑related duties requested by any person authorized to give instructions or assignments. All duties and responsibilities are essential functions and requirements and are subject to possible modification to reasonably accommodate individuals with disabilities. To perform this job successfully, the incumbent will possess the skills, aptitudes, and abilities to perform each duty proficiently. Some requirements may exclude individuals who pose a direct threat or significant risk to the health or safety of themselves or others. The requirements listed in this document are the minimum levels of knowledge, skills, or abilities. This document does not create an employment contract, implied or otherwise, other than an “at will” relationship. We are proud to be an equal opportunity workplace dedicated to pursuing and hiring a diverse, talented, and engaged team. Equal Housing Lender / Member FDIC #J-18808-Ljbffr