Position SummaryMonitors TCF and TCF National Bank Arizona’s (TCF AZ) compliance with fair lending laws.
Determines potential risk areas and conducts periodic file reviews in accordance with FFIEC Interagency Examination Procedures.
Assists the General Counsel and Fair Lending Counsel, Compliance Officers and the Director of Corporate Compliance with appraisal of the quality of compliance management systems for fair lending activities.
Ensures standard and special purpose fair lending reports are designed to provide holding company and bank management with information to evaluate fair lending performance.
Oversees corrective action taken by management to address fair lending deficiencies, including assisting management with implementation of corrective action when necessary and conducting follow-up reviews to determine the adequacy and effectiveness of action taken.
Ensures fair lending risks identifiable through date analysis are reported to executive management and the Board of Directors (BOD) of TCF and TCF National Bank Arizona.
(TCF AZ).
Major Areas of AccountabilityA.
Develops methodology for determining potential risk areas identifiable through fair lending data analysis.
Identifies and incorporates all relevant sources of date to ensure a comprehensive analysis of fair lending risk.
Ensures management maintains fair lending data collection and reporting systems for HMDA reporting.
Prepares annual Fair Lending Plan and review schedule.
B.
Establishes the frequency and content of standard reports generated and distributed by the Fair Lending Analyst for purposes of evaluating the bank’s Fair Lending performance.
C.
Performs risk analysis using Fair Lending Wiz or other software designed to analyze data for fair lending purposes to determine which TCF entity product, loan type, and/or geography should receive a fair lending review.
Schedules and performs fair lending reviews (including underwriting and pricing comparative file reviews or regression analysis) of TCF lending entity to determine the level of compliance with fair lending laws.
Performs risk analysis on non-data related fair lending issues using FFIEC examination procedures.
D.
Maintains orderly and detailed workpapers, assists management with the determination of the cause(s) of violations or exceptions, recommends corrective action, conducts exit meetings with management and drafts reports of compliance findings to senior management.
E.
In conjunction with the General Counsel and the Director of Corporate Compliance, analyze and communicate to bank management the impact of fair lending laws and regulations on the bank’s operations, including policies, procedures, new and existing products, forms, advertising, and promotional materials, etc. Coordinate meetings to discuss the impact, define necessary action, and assign responsibilities to management.
F.
Prepares periodic fair lending reports to senior management and the board of directors encompassing significant fair lending activities, including monitoring and testing results.
Provides weekly status reports to the TCFFC General Counsel and Director of Corporate Compliance regarding fair lending activities, including the status of fair lending reviews in progress and those completedG Assists the Director of Corporate Compliance in coordinating regulatory fair lending compliance examinations.
May serve as liaison with regulatory agency staff, and review/prepare responses to fair lending compliance reports of examination.
Follow-up to ensure appropriate corrective action is taken to address examination criticism.
H.
Assists TCF and TCF AZ management with the development and maintenance of a Fair Lending Policy and/or program.
Coordinates the annual review and updates to fair lending-related policies and procedures that are part of the bank’s Compliance or Fair Lending Program for adoption by the Board of Directors.
I.
Monitors fair lending activities, including the results of compliance reviews of fair lending laws, of the Bank.
Ensures the Bank implements the minimum standards outlined by the Fair Lending Policy with respect to fair lending objectives including training of personnel.
Monitors consumer complaints for fair lending concerns.
J.
Maintains current awareness of legislative developments and a working knowledge of state and federal laws and regulations as they relate to fair lending.
Reviews all fair lending compliance-related information promptly and distributes publications on fair lending regulatory issues and training opportunities to affected personnel.
K.
Researches fair lending issues and provides interpretations or clarifications to bank, subsidiary or affiliate personnel, with assistance from the General Counsel and the Director of Corporate Compliance, as necessary.
L.
Oversees all activities of the Fair Lending Specialist and Fair lending Analyst.
Develops and motivates direct reports to ensure achievement of their accountabilities in a timely and effective mannerM Maintains a library of fair lending resources, including master files for all compliance-related topics.
Minimum QualificationsEducation Required: * A four-year college degree or equivalent job-related experiencePreferred: *College level statistics courseWork Experience/Skills Required: * At least five years of consumer compliance experience in a Fair Lending related position and/or with consumer compliance auditing or monitoring/review experience.
* Knowledge of banking, the internal structure of a bank, elements of bank operations and services.
Understanding of consumer protection and public interest laws and regulation, and bank supervisory compliance examination procedures.
* Excellent written and verbal communication skills.
Excellent project management skills.
* Computer aptitude with particular emphasis on word processing, spreadsheet programs and database management.
* Solid interpersonal skills necessary to interact with bank employees, management, and regulatory examiners.
Organizational skills needed to handle work in an efficient manner.
High degree of initiative and strong ability to meet principal accountabilities with limited direction and oversight.
* Ability to travel (10%) required.
Preferred: *Experience as a regulator.
* Previous lending or underwriting experience.
Supervisory Responsibilities* Supervises the CRA/Fair Lending Specialist and Fair Lending Analyst https://recruiter.
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