Manager, Compliance - Escheatment & Open Banking

Manager, Compliance – Escheatment & Credit Risk

The Manager, Compliance – Escheatment & Credit Risk sits within the Second Line of Defense (SLOD) in Fair and Responsible Practices. The role provides independent oversight of credit risk and servicing compliance; supports development and governance of the enterprise Escheatment (Unclaimed Property) framework; and delivers second-line oversight of Open Banking and consumer data-sharing activities. Responsibilities include ensuring compliance with FDCPA, FCRA, ECOA, TILA, UDAAP, unclaimed property laws, and emerging data access regulations. The role partners cross-functionally with Legal, Product, Engineering, Operations, and Data Science to strengthen risk-based governance, provide credible challenge, and translate regulatory requirements into effective controls.

Essential Responsibilities:

• Identify issues and recommend best practices for risk management within the organization.
• Lead functional projects and programs that enhance risk assessment and mitigation efforts.
• Collaborate with teams to analyze business trends and their implications for risk management.
• Contribute to process improvements that enhance the effectiveness of risk management strategies.
• Provide guidance and support to team members in executing risk management initiatives.

Minimum Qualifications:

• 5+ years relevant experience and a Bachelor's degree OR Any equivalent combination of education and experience.

Additional Responsibilities & Preferred Qualifications:

Enterprise Escheatment Program Leadership

• Support the continued development and maturation of PayPal's enterprise-wide Escheatment (Unclaimed Property) compliance framework within a SLOD governance model.
• Enhance policies, standards, and risk-based controls governing identification, dormancy tracking, due diligence outreach, reporting, and remittance of unclaimed property.
• Provide independent oversight and credible challenge of first-line escheatment processes to ensure regulatory alignment and control effectiveness.
• Conduct risk assessments to identify jurisdictional gaps and recommend remediation strategies.
• Support regulatory inquiries, audits, VDAs, and remediation initiatives.
• Deliver executive reporting on escheatment risk exposure and program maturity.

Credit Risk, Collections & Servicing Compliance Oversight

• Provide second-line oversight of collections, recoveries, servicing, and collections expansion initiatives (including new geographies, products, or third-party models).
• Assess compliance risks related to credit bureau furnishing and dispute management under FCRA.
• Provide independent oversight, regulatory guidance and credible challenge to ensure business compliance with ECOA/Reg B, TILA/Reg Z, FDCPA, UDAAP, and related consumer protection laws.
• Review controls governing adverse action notices, billing statements, dispute investigations, periodic disclosures, and credit reporting accuracy.
• Evaluate regulatory considerations associated with minor accounts and youth-related financial products, including age-based eligibility, disclosures, and reporting impacts.
• Conduct risk-based compliance assessments across the credit lifecycle, including underwriting, pricing, servicing, automated decisioning, and account management.

Open Banking & Consumer Data-Sharing Oversight

• Provide second-line compliance oversight of Open Banking and consumer-permissioned data-sharing activities across applicable jurisdictions, in coordination with SLOD Privacy and SLOD Cybersecurity.
• Assess regulatory compliance risks related to consumer data access, consent management, third-party data sharing, API governance, and transparency obligations, leveraging subject matter expertise from Privacy and Cybersecurity partners where appropriate.
• Partner with Legal, Product, and relevant SLOD functions to interpret evolving Open Banking frameworks (e.g., Section 1033 rulemaking and global data access regimes) and translate requirements into clear compliance control expectations.
• Review governance structures supporting third-party data access and customer rights (e.g., data portability, revocation of consent), ensuring alignment with established privacy and information security standards.
• Evaluate first-line monitoring and control frameworks for regulatory sufficiency, while coordinating with SLOD Privacy and Cybersecurity on data protection and security control effectiveness.
• Prepare executive-level reporting on Open Banking compliance risks, emerging regulatory developments, and cross-functional risk themes.

Preferred Qualifications

• Experience supporting or enhancing an enterprise Escheatment/Unclaimed Property compliance program.
• Experience with credit bureau reporting and FCRA compliance oversight.
• Experience supporting Open Banking, API-based financial data sharing, or consumer-permissioned data programs.
• Familiarity with U.S. Section 1033 requirements and/or global Open Banking regulatory regimes.
• Experience supporting BNPL, revolving credit, installment lending, or embedded finance products.
• Experience operating in a global, technology-enabled financial services organization.
• CRCM or comparable compliance certification.
• Experience with statistical Fair Lending testing methodologies.
• Experience overseeing AI/ML models in financial services.
• Advanced degree in Law, Business, Finance, Risk Management, Data Analytics, or related field.