Job Description and RequirementsThe
Fair Credit Reporting Act Director is responsible for the strategic oversight, governance, and performance of the credit union's Fair Credit Reporting Act (FCRA) and Servicemembers' Civil Relief Act (SCRA) programs. FCRA oversight includes data furnishing and credit accuracy functions. This role ensures the accuracy, integrity, and completeness of consumer reporting data, alignment with regulatory requirements, and integration with the organization's Compliance Management System (CMS). The FCRA Director is accountable for program effectiveness, risk management, enterprise-level issue resolution related to credit reporting activities, and other duties as assigned.
Essential Functions and Responsibilities:- Provide accountable leadership and oversight for the SCRA, FCRA, and data furnishing programs, including Metro 2/American Standard Code for Information Interchange (ASCII) reporting, credit accuracy, disputes, corrections, and reporting alignment.
- Establish and maintain policies, procedures, governance structures, strategy, objectives, and performance expectations to support SCRA, FCRA, Regulation V, CMS, and enterprise risk management alignment.
- Oversee data furnishing accuracy, completeness, integrity, and validation for information furnished to consumer reporting agencies, including alignment between furnished data and dispute investigation outcomes.
- Design, implement, and evaluate controls for credit reporting accuracy and integrity, ensuring controls are risk-based, effective, and aligned with regulatory expectations.
- Oversee enterprise-level SCRA and FCRA issue management, including prioritization, root cause analysis, remediation strategies, backlog monitoring, timelines, and risk exposure.
- Serve as primary contact for regulators, auditors, and third-party vendors on SCRA and FCRA matters; interpret SCRA, FCRA, Regulation V, ASCII, Consumer Data Industry Association (CDIA), and Consumer Reporting Resource Guide (CRRG) requirements; and support timely responses to inquiries, exams, and complaints.
- Provide executive reporting on program performance, risks, remediation status, emerging trends, control effectiveness, FCRA compliance, and data integrity.
- Provide compliance oversight for decisions within authority, ensuring due diligence is completed before projects, products, or process changes are implemented.
- Oversee compliance-related administration and implementation of software and technology supporting department productivity and operations.
- Lead Credit Accuracy and FCRA Program Managers, Team Leads and supporting staff, by defining roles, managing performance, supporting workforce planning, and providing resources, training, coaching, and development.
- All other duties as assigned (note: essential functions and responsibilities may change or new ones may be assigned at any time with or without notice).
Requirements:- Master's Degree
- Minimum of 7 years combined financial institution and compliance experience OR 13 years combined financial institution and compliance experience in lieu of degree
- Minimum of 3 years management experience
- Experience with compliance reporting, data analytics and compliance issue management
- Broad knowledge of the ASCII, CDIA, CRRG, Metro 2 reporting, and SCRA
- Ability to conduct thorough research, interpret and understand laws and regulations and provide practical recommendations and solutions
- Excellent communication and interpersonal skills; as well as influencing abilities
- Excellent organization and time management skills; accustomed to working with deadlines
- Strong leadership, staff management and project management skills
- Strong problem solving, critical thinking, and change management skills
- Ability to leverage advanced business/analytical knowledge to lead discussions with cross-functional teams to understand highly complex business objectives and influence solution strategies
- Ability to work independently given minimal direction; self-motivated with desire to be a team player in a constructive environment
Preferred:- Experience with BSA, ECOA, Fair Lending, FCRA, FDCPA, MLA, OFAC, SCRA, and TILA
- FCRA Certificate for Data Furnishers, or similar FCRA compliance certification
- Experience with financial institutions larger than $10 billion in assets and exposure to oversight by the Consumer Financial Protection Bureau (CFPB)
