The Fair Credit Reporting Act (FCRA) Regulatory Compliance Program Lead will report to the Director of Enterprise Regulatory Programs and be responsible for the oversight and ongoing execution of the FCRA Regulatory Compliance Program. The Program Lead will also be responsible for overseeing related Red Flag/Identity Theft risks. Primary function responsibilities include: overseeing business line activity that impacts FCRA compliance; analyzing risk assessments and monitoring and testing results; reviewing policies and procedures; assisting in the implementation of corrective actions; providing staff training / guidance, as appropriate; partnering with the Law Division to review/discuss regulatory interpretation of FCRA requirements and related Policy impacts; and serving as the central point of contact for FCRA-focused audits and examinations. This individual will serve as the team's FCRA subject matter expert and will coordinate and provide advisory services to multiple business lines and functions across the institution. Detailed responsibilities include, but are not limited to the following:
- Provide centralized oversight activities designed to mitigate risk related to fair credit reporting compliance.
- Responsible for ongoing oversight of FCRA Compliance across the institution to ensure consistency, where appropriate, and for sustaining a risk-based Compliance Program that is comprehensive and meets regulatory expectations.
- Researches / responds to questions, relative to FCRA, from business line partners and Compliance Risk Management Specialists.
- Owns and maintains FCRA-specific authoritative documents (e.g., FCRA Policy & associated Guidelines) and Program-specific documentation (e.g., Program Summary and Annual Plan).
- Advises business risk and compliance to establish and maintain a solid compliance control and risk framework for FCRA.
- Provides FCRA-specific input for ongoing risk assessments, and for products and services across multiple business lines.
- Researches and analyzes new / proposed laws and regulations to identify potential policy, procedure and/or system changes needed to facilitate compliance.
- Partners with business lines in the implementation of regulatory reform / rule change initiatives.
- In collaboration with Business Line Compliance Risk Management Specialists, advises on new products / marketing materials, and other forms of communications, for regulatory compliance / adherence to enterprise compliance standards.
- Regularly reviews applicable state / federal laws and regulatory compliance issues through reading and researching applicable publications, news service articles, and external training.
- Works closely with other key functions such as Legal, Risk Management, Testing, and Audit functions to ensure coverage is comprehensive and consistent, across the institution and that issues are appropriately addressed on a timely basis.
- Keeps senior and executive management fully informed of monitoring findings and/or trends or systemic issues identified through monitoring, testing and other oversight activities via the delivery of management reporting.
- Identifies / investigates activity that can be indicative of compliance problems and communicates / escalates as necessary, including recommending practical solutions to address concerns.
- Oversees FCRA-related compliance issues throughout the issue management life cycle. This would include: ascertaining root cause; assisting in the development of corrective action plans; and monitoring, tracking & reporting issue status until the issues have been closed and validated by the appropriate parties.
- Develops the content, and coordinates the implementation and delivery of annual compliance training related to the requirements of the Fair Credit Reporting Act.
- As necessary, provides support to project teams to implement required corrective action, resolve deviations from established procedures, or to implement new procedures.
- Coordinates and oversees regulatory exams and internal audits that are FCRA-focused.
- Maintains a collaborative environment, sharing ideas and assisting peers.
- Promotes a high performance, goal-oriented, team environment.
- Exercises sound judgment and ensures integrity of confidential information.
- Deals with change and handles stressful situations in a professional manner.
- Bachelor's degree, or equivalent work experience
- Ten or more years of experience in an applicable risk management environment
- Applicable certifications
- Subject matter expert in the following regulatory area – Fair Credit Reporting Act (FCRA).
- Advanced degree.
- Compliance or Audit certifications (CRCM, CRMA, CIA, etc.) are preferred.
- Must have experience working in a financial institution, regulatory agency, or a financial services consulting company.
- Advanced knowledge of Risk/Compliance/Audit competencies.
- A comprehensive understanding of the banking industry; and knowledge of consumer business line operations, products & services, systems, and associated risks and controls.
- The ability to communicate effectively with all levels of management and external parties.
- Excellent project management and organizational skills. Ability to plan out and document a course of action to effectively achieve goals. Utilizes resources efficiently and effectively and carries out systematic reviews of progress.
- Must be proactive in identifying potential concerns and following-up to resolve such issues.
- Strong documentation and reporting skills are required.
- Strong analytical, problem-solving and negotiation skills.
- Must demonstrate the ability to effectively facilitate meetings and train personnel on key compliance and regulatory issues.
- Ability and desire to mentor and develop junior members of the team.
- Proficient with Microsoft Office products.
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