Job Type
Full-time
Description
The Lending Compliance Program Manager is responsible for designing, implementing and maintaining a comprehensive lending compliance management system (CMS) for the credit union. This role will establish the foundational framework for compliance oversight across all consumer and mortgage lending activities, ensuring adherence to applicable federal and state regulations, regulatory guidance, internal policies and industry best practices impacting lending activities. This individual will play a critical leadership role in building a scalable, sustainable compliance ecosystem from the ground up, partnering closely with Lending, Operations, and Enterprise Risk Management (ERM), Internal Audit and Executive Management to embed lending compliance into the organization's culture and processes. This role will also assist Lending in the development, implementation, and maintenance of policies, procedures, and processes to minimize compliance risks, ensuring appropriate compliance risk oversight is in place for assigned business units and/or functions, and assisting with the implementation and execution of complex regulatory requirements that impact multiple systems, processes, and members.
Essential Functions Compliance Program Development & Governance
- Design, implement and maintain a formal Lending Compliance Management System (CMS) aligned with regulatory expectations.
- Guide the development or revision and implementation of policies, procedures, services, products, systems and controls covering all aspects of consumer and mortgage lending compliance.
- Develop a governance framework including reporting, escalation protocols, and compliance committee structures.
- Serve as the subject matter expert on lending compliance matters and regulatory expectations.
Regulatory Compliance Oversight
- Ensure compliance with all applicable regulations, including but not limited to Truth in Lending Act (TILA) / Regulation Z, Real Estate Settlement Procedures Act (RESPA) / Regulation X, Equal Credit Opportunity Act (ECOA) / Regulation B, Home Mortgage Disclosure Act (HMDA) / Regulation C, Fair Housing Act (FHA), Fair Credit Reporting Act (FCRA), Flood Disaster Protection Act, Military Lending Act (MLA), Servicemembers Civil Relief Act (SCRA) and Unfair, Deceptive or Abusive Acts or Practices (UDAAP).
- Monitor regulatory changes and assess impact to the credit union, lending products, systems and processes; lead implementation of required changes.
- Provide timely, consultative guidance to business leaders and business units on compliance requirements, emerging risks, and the execution of any necessary changes; prepare training materials for staff, as needed.
- Find solutions to potential compliance barriers for new lending products and services and provide feedback on third party vendors and systems used for these lending activities; provide suggestions for when new vendor relationships should be considered.
- Work closely with cross functional partners to support the ongoing maturation of aspects of the Fair Lending Program (e.g. advisory frameworks, risk assessment, testing, governance). Provide Fair Lending advice and possess the ability to communicate complex regulatory expectations for Fair Lending matters throughout the product life-cycle and across all products and services.
Monitoring, Testing & Quality Assurance
- Develop and execute a risk-based compliance monitoring and testing program for consumer and mortgage lending in line with department and industry standards to ensure compliance with applicable lending laws, rules and regulations.
- Establish key risk indicators (KRIs) and metrics to assess compliance performance.
- Partner with Internal Audit to ensure appropriate independent testing and validation.
- Support internal and external audits, regulatory examinations and independent reviews and assist with remediation efforts for any resulting findings or recommendations to ensure lending compliance findings have been effectively mitigated and effective actions have been taken.
- Develop and implement procedures to ensure record retention practices are aligned with policy and in accordance with regulations and laws.
- Utilize compliance reviews, risk assessments, complaint monitoring and other assigned department duties to identify potential areas of lending compliance risk.
Training & Culture
- Develop and deliver lending compliance training programs for staff, management, and leadership.
- Promote a culture of compliance and ethical lending practices across the organization.
- Provide ongoing guidance and support to business units on compliance-related matters.
Other Duties
- Possess effective communication skills when relaying critical information to colleagues and stakeholders. Reports on testing, changes, potential risk factors and data gaps.
- Assist in documenting critical processes, support the maintenance of internal team sites, and support the Compliance team in maintaining relevant policies, risk assessments, training materials, issues management and other related items.
- Collaborate with relevant stakeholders to ensure transparency into compliance risks impacting key initiatives, company growth or credit union partners.
- Build relationships with business and functional partners.
- Consider impact on Credit Union employees, members, costs, and efficiencies before providing recommendations to management on appropriate action.
- Serve as a resource and expert on assigned systems, programs and processes. Understands documentation standards, recordkeeping requirements, disclosure requirements, technology and data security related to loan origination systems and other technologies within lending.
- Responsible for managing risks specific to related job functions with an expectation to make and support risk-informed decisions and remain diligent in identifying emerging risks that could jeopardize the success of the Credit Union.
- Any other duties as assigned.
Requirements
- Bachelor's degree preferred but not required
- 7+ years of experience with a minimum of 5 years of Lending Compliance experience
- Prior experience successfully setting up a lending compliance program.
- Ability to communicate in concise written format with high degree of accuracy
- Ability to complete assigned projects simultaneously, without direct supervision, and by the assigned deadline
- Ability to manage multiple projects
- Strong analytical skills with high compliance requirements
- Knowledge and understanding of consumer lending products and laws/regulations that impact them
- Experience working with examiners, internal/external auditors, and third-party service providers
- Loan operations experience
- Must possess Lending Compliance Certificates (i.e. Compliance Officer, Mortgage Compliance Specialist, etc.)
Physical RequirementsThe physical demands described here are representative of those that must be met by an employee to successfully perform the essential functions of this job. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.
While performing the duties of this job, the employee is frequently required to sit, use hands to finger, handle or feel, reach with hands and arms, and talk or hear. The employee is occasionally required to stand, walk, bend, kneel, and reach above or at shoulder level. The employee must occasionally lift/push/pull and/or carry up to 10 pounds.