Consumer Compliance and CRA Manager

Amerant Bank•Miramar, FL

About The Position

Senior-level officer responsible for developing, implementing, and administering all aspects of the Consumer Compliance Program and the Community Reinvestment Act (CRA) program. The role provides strategic and tactical leadership for consumer compliance risk mitigation, establishes program governance, oversees compliance risk assessments and testing, and works with the board of directors, executive management, business units, and regulatory authorities. The position directs consumer compliance monitoring, training, policy development, product and marketing reviews, corrective action, regulatory examination preparation, complaint analysis, and merger and acquisition due diligence. It also supervises the bank’s Fair Lending program, including risk assessment, analytics, testing, reporting, and HMDA data integrity activities. The manager leads and develops a team of compliance professionals and identifies and recommends actions to manage compliance risks to the bank’s earnings or capital.

Requirements

  • Bachelor’s degree required.
  • At least 10 years of related experience, including experience working closely with regulatory agencies.
  • Prior experience managing a department and team of professionals.
  • Extensive knowledge of consumer compliance regulations and the ability to create an effective and efficient compliance management system.
  • Knowledge of regulatory requirements, loan and retail operations and documentation, banking products, the Community Reinvestment Act, demographics, and statistical analysis.
  • Technical experience with Lotus Notes, internet use, advanced MS Word, MS Excel, and MS PowerPoint, MS Project Level II, and MS Visio Level I.

Nice To Haves

  • An advanced degree, such as a juris doctor.
  • Bachelor’s degree in Business Administration or Liberal Arts.
  • Certified Regulatory Compliance Manager (CRCM) or another professional certification.
  • Related experience in compliance-focused Internal Audit, Risk, Loan Review, or work with a regulatory agency.
  • Contacts with community leaders and nonprofit organizations.
  • Service on community boards of directors or committees.
  • Auditing skills.

Responsibilities

  • Develop, communicate, and implement the strategic vision for consumer compliance risk mitigation in support of bank priorities and business initiatives.
  • Develop and maintain Consumer Compliance Program governance, including independent interaction with the board of directors, executive management, and regulatory authorities; set agendas and key topics for Compliance Governance Committees.
  • Develop, implement, and maintain enterprise-wide and departmental policies for managing compliance risk; supervise the Compliance Risk Assessment and Policy Unit; set the bank’s compliance risk appetite.
  • Review and approve new or revised products, processes, channels, delivery systems, advertisements, and marketing campaigns, and ensure appropriate risk mitigants are established.
  • Maintain expertise in compliance regulations, regulatory issuances and examination materials, industry trends, and best practices; monitor regulatory changes, analyze their impact, and update testing processes as needed.
  • Conduct risk assessments of functions under direct testing supervision to determine review frequency and develop the risk-based Annual Plan; adjust and direct implementation of the plan and ensure the quality of work.
  • Direct and control compliance testing to mitigate regulatory exposure and ensure compliance with federal and state regulations and organizational policies and procedures; approve and validate corrective action plans.
  • Develop the annual compliance training needs assessment, ensure its execution, develop and oversee training programs, maintain records, and present training to the Board of Directors and Senior Management.
  • Lead consumer compliance due diligence and integration teams for mergers and acquisitions; analyze merger targets and report results to the Consumer Compliance Committee, Board of Directors, and Senior Management.
  • Identify, evaluate, and report current or prospective compliance risks to Senior Management and the Consumer Compliance Committee.
  • Lead and direct staff, including hiring, coaching, evaluation, corrective action, and training of consumer compliance monitoring staff.
  • Ensure complaint cases are reviewed; investigate potential regulatory issues, determine root causes, coordinate corrections, and follow up on corrective action.
  • Lead consumer compliance officers in preparing for and supporting examinations by the OCC, Federal Reserve, and State of Florida; provide information to supervisory authorities and ensure corrective actions are completed, reported, and delivered within required time frames.
  • Identify, evaluate, and monitor risks to earnings or capital arising from violations or nonconformance, and recommend actions to the respective Risk Management Committee to assess, reduce, eliminate, or control those risks.
  • Engage with the business and Enterprise Data Management Office to identify and help remediate data-related issues, including data quality, classification, and descriptions.
  • Supervise the Fair Lending program and ensure completion of analysis, testing, risk assessment, and reporting activities.
  • Analyze approved and denied loans using data analytics and HMDA-reportable loan data; review pricing and underwriting exceptions through comparative file testing; conduct peer-bank and redlining analyses.
  • Oversee or perform the annual Fair Lending Risk Assessment and present it to the Board Audit, Executive, and Consumer Compliance Committees; monitor regulatory and industry materials concerning Fair Lending.
  • Ensure quarterly HMDA Data Integrity reviews and quarterly reporting of loan pricing and underwriting exceptions to the Consumer Compliance Committee.
  • Ensure the HMDA LAR is transmitted annually by March 1.
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