CRA/Fair Lending Program Manager
Johnson Financial Group
Overview Under the direction of the Chief Compliance Officer, responsible for demonstrating knowledge of compliance rules and regulations impacting Johnson Financial Group with particular focus on Fair Lending, the Community Reinvestment Act (CRA), related statistical data for Home Mortgage Disclosure Act (HMDA), CRA, Small Business Lending, etc. (“Areas of Focus”) and leading the Company’s related compliance initiatives/program for these Areas of Focus. Is proficient at analyzing compliance risk, related costs, and impact to the company/clients. Offers knowledge, options for business solutions, and consultative services to Line of Business Partners/Corporate Support Areas (LOB/CSAs). Manages and implements companywide Compliance Management Program including conducting risk assessments, chairing the Responsible Lending and CRA Committee, reporting to the Leadership Team/Leader’s Group/Risk Management Committee and if required the Board of Director’s or designated Committee, contact/coordinator for Bank examinations, establishing LOB/CSAs compliance monitoring activities, and partnering in training programs. Directs and manages Compliance Team/Department staff assigned to Area of Focus. KEY RESPONSIBILITIES Position Specific Responsibilities Acquire and maintain a comprehensive level of general compliance knowledge, especially with respect to compliance Area of Focus, including monitoring of state and federal legislation, regulations, and rules. Have comprehensive understanding of requirements of, including but not limited to, the Equal Credit Opportunity Act (Regulation B), the Fair Housing Act, the Community Reinvestment Act, and the Home Mortgage Disclosure Act (Regulation C), and a working knowledge of banking and wealth management regulations and operations. Conduct and manage risk impact assessments/analyses (from a compliance position, but also a general business position) for regulatory issues (new and old). Lead/Oversee the implementation of new rulemakings, including the 1071 small business data rule and the new CRA Modernization rule. Develop strategy and plans, manage timelines, and collaborate with LOB partners as needed. Chair Responsible Lending and CRA Committee - manage companywide initiatives and responsible for ongoing monitoring of the program for applicable changes and updates as required. Maintain strong internal partnerships (as outlined in the Company’s Compliance Management Program) including but not limited to; communication of pertinent information, performing risk assessments, assisting with the development of strategies, assisting with the drafting of written procedures, and if required, active support of training efforts. Ensures timely responses to all inquiries for compliance assistance and/or rule interruption. Manages the execution of the Company’s Fair Lending and CRA Compliance Management Program, including policy development, risk assessment and documentation, LOB compliance monitoring programs, and the preparation of materials for reporting to senior management and the Board of Directors. Fair Lending/CRA Management: Conduct Fair Lending reviews and reports results to Responsible Lending and CRA Committee, Maintain all Fair Lending and CRA Program procedures, documentation, and activity records, Review and adopt new technology and/or data management techniques to efficiently compile and report required data, Collect and analyze CRA information/data (including government required lending data), Prepare CRA Assessment Area analysis and related management reports. Use specialty software to accurately compile, Geocode, and manage HMDA and CRA data that is provided by lending LOB/Functional Area. Provide sample testing of HMDA and CRA data information back to loan files/records to ensure data is complete and accurate. Compile community development lending, service and investment activity and supporting documentation. Manage and monitor all activities related to responsible lending and CRA, generate management reports, data maps, and dashboards as required or needed. Oversee the annual CRA/HMDA data reviews and ensure all reports are accurate and submitted to the government on time. All other duties as assigned, including having general knowledge of all disciplines of bank and wealth management compliance and ability to step in and support the Compliance Team on any related issues. JOB REQUIREMENTS – EDUCATION, KNOWLEDGE AND SKILLS Bachelor’s degree in finance or a related field required with 3-5 years’ Compliance experience with experience managing bank or financial service industry CRA/FL compliance program preferred. Manages CRA/FL Compliance Officers and/or Compliance Specialists. Project Management capabilities – lead companywide initiatives and related committees within JFG’s Compliance Management Program. Strong interpersonal, communications, and presentation skills – including presentations to the Board of Directors. Strong organizational, analytical and data management skills. Demonstrated proficiency at statistical analysis preferredProject Management capabilities – lead companywide initiatives and related committees within JFG’s Compliance Management Program. Highly proficient in the use of Microsoft Applications (Word, Excel, PowerPoint, SharePoint).
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