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Years of Experience
Date Last Verified
Fair & Responsible Banking Risk Assessment Compliance Manager The candidate reports to the U.S. Bancorp Corporate Operational Risk Managementâ€™s Fair and Responsible Banking Compliance Division and supports the Bankâ€™s Fair and Responsible Banking Program to help establish and maintain a comprehensive risk assessment process. Will provide subject matter expertise on Unfair, Deceptive and Abusive Acts and Practices (â€œUDAAPâ€); Fair Lending laws, such as Equal Credit Opportunity Act (ECOA), Fair Housing Act (FHA), and Home Mortgage Disclosure Act (HMDA); and related consumer protection laws and regulatory guidance as it applies to consumer lending and non-lending products and services. Will report to the Director of Fair and Responsible Banking Risk Assessment and will work with the other Fair and Responsible Banking teams and fair and responsible banking stakeholders of various levels within the organization, including Corporate Compliance, Legal, and Business Line personnel, including Chief Risk Officer groups, to help ensure the effective performance of the Program. Manage a team of 5 RCA Consultants, including staffing, performance management, prioritizing projects and tasks, and providing guidance and training. Develop & execute risk assessments for consumer, small business, and commercial lending and non-lending products sourced to regulatory guidance for fair lending and UDAAP. Maintain FaRB Master Control List and associated procedures by updating the requirements quarterly, in conjunction with new regulatory guidance or enterprise policies. Perform Fair and Responsible Banking risk assessments of consumer, small business, and commercial lending and non-lending products and services on an annual, semi-annual, and quarterly basis, in accordance with industry and regulatory expectations and provide credit challenge to business line responses. Assessments will evaluate fair and responsible banking risk at the product and business line level and across all product processes as defined by the Operational Risk Taxonomy Policy. Publish reports that summarize inherent risk, control effectiveness and residual fair and responsible banking risk, including summaries of key risk indicators and any identified control gaps or weaknesses. Identify control gaps based on business line responses to the annual risk assessment survey and timely enter issues into Archer/CIT in accordance with the corporate Issue Management Guidance Policy and collaborate with the Chief Risk Officer groups and business line partners to ensure appropriate and timely corrective action plans and risk mitigation strategies. Review FRBD and other sourced Archer CIT issues presenting fair and responsible banking risk for deficiencies in FaRB Master Controls, and incorporate identified deficiencies into the control effectiveness evaluations in risk assessment reports. Prepare summary of risk assessment ratings and notable control deficiencies or risk points for presentation at quarterly compliance business line heatmap meetings, FaRB Subcommittee, FaRB Quarterly Management Letter, and other executive leadership meetings or materials as needed. Assist the Director of FaRB Risk Assessments and STORM team with the development and implementation of the Archer Automation Project to get risk assessments and FaRB Master Controls loaded into Archer. Keep abreast of UDAAP and fair lending related laws and regulations, guidance and other legal and regulatory developments. Maintain and oversee review and approval of the Fair and Responsible Banking Risk Assessment General and Desktop Procedures as well as related work tools and resources. Participate in regulatory examinations and/or internal audits as requested.
Qualification and Experience
The candidate should have Bachelor's degree, or equivalent work experience. Must have 10+ years of experience in an applicable risk management environment. Applicable certifications (CRCM) is required. Juris Doctor (JD) is desired. Expert knowledge of applicable laws, regulations, financial services, and regulatory trends that impact their assigned line of business including ECOA, FHA, HMDA, UDAAP and related Consumer Financial Protection Bureau (â€œCFPBâ€) examination standards, applicable regulatory guidance, and UDAAP/Fair Lending litigation and enforcement actions is preferred. Expert knowledge of the business lineâ€™s operations, products/services, systems, and associated risks/controls is preferred. Advanced knowledge of Risk/Compliance/Audit competencies is preferred. Strong leadership and management skills of processes, projects and people is desired. Must have excellent written and verbal communication skills.
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