CMS Analyst

F&M Bank•Archbold, OH

About The Position

Under the direction of the Chief Legal & Compliance Officer and with day-to-day guidance from the CMS Manager, the CMS Analyst supports the administration and continuous improvement of the Company’s consumer Compliance Management System (CMS). The role has primary responsibility for complaint administration, compliance training coordination, and risk-based compliance testing for assigned regulatory oversight areas. The Analyst supports all CMS elements, including policies and procedures, risk assessments, monitoring and testing, complaint management, marketing and advertising review, third-party compliance oversight, regulatory change management, issue tracking, corrective action, training, and management reporting. The position also supports enterprise oversight of GLBA and Regulation P privacy requirements, CAN-SPAM, COPPA, and UDAP/UDAAP requirements. It provides practical, timely support to business lines while maintaining appropriate independence, documentation, and escalation as part of the second-line compliance function.

Requirements

Bachelor’s degree in business, finance, accounting, risk management, law, public administration, or a related field.
At least three years of related experience in consumer compliance, bank operations, risk management, audit, complaint management, training administration, quality assurance, legal, or another highly regulated financial-services field.
Direct experience with one or more CMS functions, such as compliance testing or monitoring, complaint administration, training coordination, risk assessments, policy governance, regulatory change management, or issue tracking.
Working knowledge of consumer compliance principles, internal controls, testing methods, complaint management, root-cause analysis, corrective action, and regulatory examination expectations.
Working knowledge of GLBA and Regulation P, CAN-SPAM, COPPA, UDAP/UDAAP, privacy and information sharing, marketing compliance, and third-party compliance risk.
Ability to review transaction-level and process-level evidence, identify exceptions, document defensible conclusions, and communicate results clearly.
Strong written and verbal communication, research, analytical, organizational, and critical-thinking skills.
Ability to manage multiple assignments, meet deadlines, maintain accurate records, handle sensitive information, and follow issues through resolution.
Ability to read, analyze, and interpret business publications, professional journals, legal documents, regulatory guidance, examination materials, contracts, policies, procedures, and governmental regulations.
Ability to write reports, testing memoranda, complaint analyses, procedures, training materials, and business correspondence, and present information and respond to questions from management, employees, auditors, and examiners.
Ability to apply percentages, ratios, rates, sampling concepts, exception rates, trend analysis, risk scores, aging, and performance thresholds to compliance testing, complaints, training, and reporting.
Ability to define problems, collect and analyze relevant information, identify exceptions and root causes, assess control effectiveness and potential consumer harm, and draw well-supported conclusions.
Ability to interpret technical instructions and address abstract and concrete variables.
Ability to plan and organize work in new or changing situations, apply oneself in emergencies, and respond to new procedures.
Ability to understand duties and responsibilities, maintain necessary job knowledge and technical skills, manage workload and time, prioritize tasks, attend to detail and accuracy, seek improvement, accept feedback, and keep knowledge and skills current.

Nice To Haves

Professional certification or specialized training such as CRCM, CCEP, CIPP/US, CIA, or comparable compliance, audit, privacy, or risk-management training.
Experience with governance, risk, and compliance systems; complaint-management platforms; learning-management systems; policy-management systems; issue tracking; testing software; or data-analysis tools.
Experience preparing compliance testing workpapers, complaint trend reports, training metrics, risk assessments, or examination documentation.
A Master’s degree, Juris Doctorate (JD), or other advanced degree.

Responsibilities

Assist the CMS Manager and Chief Legal & Compliance Officer with administration, documentation, and continuous improvement of the Company’s CMS and consumer compliance program.
Administer the consumer complaint process, including intake, logging, categorization, assignment, aging, investigation follow-up, response tracking, quality review, escalation, closure documentation, and record retention.
Review complaint responses for completeness, consistency, professionalism, and compliance risk; escalate complaints involving potential legal violations, discrimination, UDAP/UDAAP, privacy, significant consumer harm, systemic issues, threatened litigation, regulators, or material reputation risk.
Analyze complaint trends and root causes across products, channels, locations, customer segments, business units, and third parties; prepare reports on recurring themes, control weaknesses, potential consumer harm, and recommended corrective action.
Coordinate the compliance training program, including training plans, needs assessments, assignments, invitations, materials, attendance and completion tracking, overdue follow-up, exceptions, acknowledgments, testing of understanding, and records retention.
Assist in developing and updating enterprise, role-based, regulation-specific, and Board compliance training; review content for accuracy and support assessments of training effectiveness.
Perform risk-based compliance testing for assigned regulatory oversight areas in accordance with approved testing plans and procedures, including defining or applying populations, samples, attributes, evidence requirements, exception criteria, and documentation standards.
Document testing work clearly and reproducibly; prepare testing memoranda covering scope, methodology, results, exceptions, potential violations or consumer harm, root causes, and recommended corrective action.
Communicate testing results to the CMS Manager and accountable business leaders; enter findings into the Bank’s issue-tracking process and monitor corrective actions, due dates, supporting evidence, validation, and closure.
Support development and maintenance of the annual risk-based compliance monitoring and testing plan using risk assessments, complaints, regulatory changes, new products, system changes, prior findings, audit and examination results, and other risk indicators.
Support enterprise and regulation-specific compliance risk assessments by gathering data, interviewing process owners, documenting controls, evaluating evidence, recording ratings and rationale, and tracking action plans.
Assist with compliance policy and procedure governance, including inventories, review calendars, drafting, routing, approvals, version control, implementation evidence, employee communication, and archival or retirement of superseded materials.
Assist with compliance review of marketing, advertising, websites, social media, commercial email, direct mail, scripts, disclosures, promotions, and other customer-facing materials; maintain review records, approvals, conditions, and re-review dates.
Support compliance oversight of third-party service providers by gathering due-diligence materials, reviewing assigned compliance documentation, monitoring complaints and performance, tracking issues, and confirming providers are incorporated into applicable compliance activities.
Provide support and research concerning GLBA and Regulation P privacy, CAN-SPAM, COPPA, and UDAP/UDAAP; assist with privacy notices and opt-out processes, information-sharing reviews, commercial email controls, online data-collection reviews, and identification of potentially unfair, deceptive, or abusive practices.
Support regulatory change management by monitoring assigned developments, documenting applicability and impact, identifying affected policies, procedures, systems, controls, training, marketing, and vendors, and tracking implementation tasks through completion.
Assist with new products, services, delivery channels, marketing initiatives, system conversions, process changes, mergers and acquisitions, and significant vendor engagements by gathering information, documenting compliance requirements, and tracking pre-implementation conditions and validation.
Prepare periodic CMS reports and dashboards covering complaints, training completion, testing status and results, findings, corrective actions, regulatory changes, marketing reviews, third-party compliance issues, and emerging risks.
Maintain accurate, complete, organized, and retrievable CMS records supporting risk assessments, testing, decisions, training, complaint handling, reporting, and corrective actions.
Provide or coordinate documentation requested for internal audit, external audit, regulatory examinations, and other reviews; assist with examination responses, finding remediation, and evidence of corrective action.
Move across functional lines within the Compliance Department to assist with lending, deposits, fair lending, CRA, BSA/AML coordination, privacy, issues management, policy and procedure development, and third-party oversight.
Perform other related duties as assigned.
Follow Bank policies, related procedures, and applicable federal and state laws, regulations, and guidance.
Comply with BSA, AML, OFAC, and USA PATRIOT Act requirements, including applicable CTR completion, Customer Identification and Customer Due Diligence, and reporting suspicious activities to the BSA Department.