The Fair Banking and UDAAP (“FB”) Officer will be responsible for managing and maintaining appropriately scaled and well functioning Fair and Responsible Banking and Unfair, Deceptive or Abusive Acts or Practices (“UDAAP”) programs to promote compliance with applicable fair banking and UDAAP laws, regulations and obligations throughout the Bank.
The FB Officer is responsible for the following duties:
Knowledge, Skills, Training
- Conducts qualitative risk assessments to assist the Bank in assessing and managing its fair lending and UDAAP risks,
- Conducts or oversees the development of performance analytics and comparative file reviews to test for fair lending compliance risks.
- Analyzes lending activity to identify fair lending risk associated with levels of assistance, underwriting, pricing and steering.
- Assists in the development of company policies, procedures, processes and products, as well as providing day-to-day guidance to business lines regarding consumer protection practices and fair banking and lending. Assists in implementing changes that address areas of deficiencies or risk.
- Reports findings from risk assessments and analytic analyses to senior management, board committees, the Board of Directors, internal or external auditors and regulatory examiners, as appropriate.
- Provides periodic reports on the status of fair and responsible banking and UDAAP programs to senior management, internal or external auditors and regulatory examiners.
- Oversees collection and/or reporting of HMDA data.
- Oversees development of compliance-related policies and procedures, training programs, audit plans, data analyses reports and risk assessments.
- Participates in the review, implementation and maintenance of policies, procedures, and/or programs that involve complying with the requirements of the Home Mortgage Disclosure Act (HMDA), Equal Credit Opportunity Act (ECOA), Fair Housing Act (FHA), Telemarketing and Consumer Fraud and Abuse Prevention Act, Unfair, Deceptive or Abusive Acts or Practices (UDAAP), The Dodd-Frank Act, and any other consumer protection law or regulation relating to fair and equitable treatment of consumers with respect to the Bank’s financial and lending products and services. Although the FB Officer is not the Community Reinvestment Act (CRA) officer, the FB Officer works closely with the CRA Officer on matters of overlapping interest.
- Chairs Fair and Responsible Lending Subcommittee, to coordinate fair and responsible banking compliance efforts throughout the Bank, and assist the Compliance Department and business units with implementing new regulatory requirements.
- Maintains the Fair and Responsible Lending Program and Policy documents. Presents changes and updates to relevant board committees and to the Board of Directors.
- Maintains current awareness of legislative developments and a working knowledge of state and federal laws and regulations as they relate to consumer protection and fair banking and lending.
- Coordinates and leads response to fair lending and UDAAP regulatory examinations conducted by the Bank’s regulators and auditors.
- Promotes culture of fair and responsible banking throughout the Bank, beyond lending functions.
Training and Experience
- Significant knowledge of laws, regulations and issues relating to fair and responsible lending including Home Mortgage Disclosure Act (HMDA), Equal Credit Opportunity Act (ECOA), Fair Housing Act (FHA), Telemarketing and Consumer Fraud and Abuse Prevention Act, Unfair, Deceptive or Abusive Acts or Practices (UDAAP), and Community Reinvestment Act (CRA),.
- Excellent communication skills appropriate for communications with important external constituencies including regulators, enforcement officials and community groups, as well as internal constituencies such as senior management, IT and operations personnel.
- Significant knowledge of depository banking, mortgage loan origination, interest rate and pricing, and servicing systems.
- Understanding of econometrics testing models in comparative file reviews, preferred.
- Solid understanding of Compliance Risk Management, current agency regulatory posture, and industry best practices.
- Judgment and perspective in identifying and controlling risk.
Pre-Employment Screening Includes:
- 7 – 10 years of experience working in the financial industry as a regulatory compliance officer or manager, with at least 5 years of experience related to fair lending issues.
- Bachelor’s or higher degree.
- Experience presenting and training on analytical results to diverse audiences, preferred.
- Experience in developing and implementing compliance policies, programs and procedures, including enterprise wide risk assessments.
- Assessment Screening
- Credit Check
- Criminal Background Check
- Drug Screen – after offer of employment is extended and before start date
- Past Employment Verification
- Social Security Verification
EverBank Financial and its subsidiaries provide a range of financial services including banking, investment services, lending, commercial...