CRA & Fair Lending Officer

Exchange Bank•Santa Rosa, CA

1d•$105,000 - $148,000

About The Position

This position is responsible for developing, implementing, and administering all aspects of Exchange Bank’s Community Reinvestment Act (CRA) Compliance Program, Home Mortgage Disclosure Act (HMDA), and Fair Lending and Fair Banking Program. The CRA Officer develops and implements programs to ensure the Bank meets the needs of the community and attains CRA compliance goals and acceptable federal examination ratings. This position will perform Fair Lending monitoring of the Bank’s lending portfolios, serve as the Bank’s Fair Lending subject matter expert, advise Senior Management and the Board of Directors on Fair Lending risk issues and mitigation, partner with the business unit managers to identify and correct potential Fair Lending risk issues, and ensure that employees are appropriately trained to comply with Fair Lending requirements. This position will have the responsibility for ensuring adherence to all fair lending and banking laws and regulations and upholding ethical practices within various product lines such as mortgage, small business, auto lending, personal loans, and retail products

Requirements

Comprehensive understanding of fair lending laws including Regulation B, HMDA, Fair Housing Act, UDAAP, and state fair lending laws, as they apply to various lending products.
Proven track record in implementing or significantly contributing to a fair lending program (or equivalent), with specific experience in all lending areas including but not limited to mortgage, auto, personal, and/or retail credit lending as well as retail products.
Knowledge of operating areas, functions, products, and services and the laws and regulations that apply to commercial banks as they relate to credit administration and lending activities.
Knowledge of loan compliance practices and procedures.
Knowledge of internal audit practices and perspectives.
Knowledge of risk and controls including tests for design and operating effectiveness and controls.
Good interpersonal skills with the ability to effectively work with individuals and groups at all organizational levels; ability to work independently and as part of a team.
Ability to interpret fair lending and fair banking laws and regulations.
Ability to take initiative and prioritize tasks; excellent time-management, problem-prevention, and problem-solving skills.
Ability to maintain confidentiality of sensitive information.
Proficiency in Microsoft Office and other Windows-based systems required; and CRA and Fair Lending Modules (fair lending analytic software) required
Experience and education in meeting requirements of state and federal banking laws and regulations.
Ability to work with all levels of management and bank staff
Ability to conduct thorough research, interpret and understand laws and regulations, and provide workable recommendations and solutions to problems.
Ability to work with community groups and government agencies.
A combination of education and experience equivalent to a bachelor's degree in finance, accounting or related field and 5 years of experience with regulatory compliance at a bank or financial services company
Ability to stand, bend, stoop, sit, walk, twist and turn.
Ability to lift up to 15 pounds occasionally.
Indoor office work environment with a majority of time sitting at a desk.

Responsibilities

Oversees the Bank’s Fair Lending Policy and Program throughout the organization, serving as the primary point of contact for fair lending and fair banking matters within the Bank.
Serve as the Bank’s subject matter expert in Fair Lending and Fair Banking laws and regulations.
Work collaboratively with Executive Management to identify and manage Fair Lending and Fair Banking risk across the Bank.
Conduct an annual risk assessment that evaluates the level and direction of the Bank’s Fair Lending risk in underwriting, pricing, marketing, steering, and redlining.
Develop and implement robust Fair Lending and Fair Banking risk reporting tools, including key risk indicators.
Develops and implements monitoring routines and procedures for the Fair Lending and Fair Banking Program, tailored to each product and/or relevant line of business.
Complete periodic Fair Lending and Fair Banking reviews, including ongoing comparative file reviews, marketing analysis, quality of assistance, exceptions, and redlining reviews, ensure appropriate remediation occurs, and maintain adequate work papers to support findings.
Ensure fair lending reports are designed to provide bank management with information needed to evaluate fair lending performance.
Develops and implements monitoring routines and procedures for the Fair Lending Program, tailored to each product and/or relevant line of business.
Guide management and bank staff regarding new rules.
Serve as a committee member on the Compliance Committee and CRA Committee and provide updates on Fair Lending and Fair Banking risk, provide training to the committee, and work closely with the Compliance Officer.
Administer software programs and any third-party vendor relationships for Fair Lending and Fair Banking.
Serve as the Bank’s CRA Officer.
Responsible for the review of all CRA data, including but not limited to: working with the Bank’s CFO regarding CRA qualified investments, all HMDA loan data, all CRA qualified community support donations and all employee hours donated in support of our community.
Coordinate, document and review lending, investment and service activity related to the requirements of the CRA Act.
Serves as the Bank’s principle liaison with external CRA compliance auditors, examiners and regulators.
Maintain relevant CRA reports and files such as the public CRA file including data and documentation.
Prepare, analyze and monitor the Bank’s statistics to determine adequate loan penetration of low and moderate income households and small businesses.
Work with the Bank’s various departments to develop lending, investment, and service programs that help meet the lending needs of low and moderate income households.
Design and develop a risk based action plan framework around the laws, regulations and issues relating to CRA, Fair Lending, Home Mortgage Disclosure Act (HMDA), Fair Housing Act (FHA) and other regulations as applicable.
Monitor the Bank’s CRA performance and suggest program modifications and improvements.
Oversee the bank’s compliance with the Home Mortgage Disclosure Act (HMDA), CRA, Fair Lending and Fair Housing Act (FHA) regulations and ensuring data integrity and timely submission of data to the respective regulatory agency or agencies.
Review, revise and make recommendations regarding the Bank’s policies and practices to comply with Home Mortgage Disclosure Act (HMDA), CRA, Fair Lending and Fair Housing Act (FHA).
Administer software programs and any third-party vendor relationships for CRA and Fair Lending.
Represent the Bank in appropriate forums for community outreach and lending opportunities.
Manage the Bank’s CRA database for collection of volunteer hours and donations including determination of CRA eligibility.
Assist in developing sound loan programs designed to meet the credit and housing needs of the Bank’s communities.
Assist in the development of new products to ensure that the Bank’s lending programs, deposit products and other financial services are designed to enable the Bank’s community to purchase businesses and build financial security.
Responsible for handling any verbal or written complaint(s) received that impacts the Bank’s CRA performance and issuing a response to the complaint.
Work with Learning and Development to develop formal bank-wide Fair Lending and CRA training.
Provide guidance and training to bank staff on fair lending practices and policies
Build awareness and provide training to Retail and Marketing to promote affordable products and marketing collateral.
Develop a library of Fair Lending and CRA resources.
Collect and distribute information related to the Fair Lending and other topical subjects to appropriate staff.
Provide informational assistance to loan officers, branch personnel, and management.
Perform special projects, research and other duties as assigned.