Fair Banking Officer

At Liberty, we are proud to integrate our Diversity, Equity, and Inclusion (DE&I) throughout all functions and areas of the Bank to maximize our impact and exceed goals. We believe deepening our DE&I strategies in the workplace and communities we serve creates a much better place to work for our teammates and a safe place where our customers are connected and supported. We take pride in promoting a socially responsible and sustainable future through initiatives and investment. 

SUMMARY OF THE JOB: 

The Fair Banking Officer is expected to provide subject matter expertise and interpretation of fair and responsible banking laws, including the Equal Credit Opportunity Act (ECOA), Fair Housing Act (FHA), Unfair, Deceptive or Abusive Acts or Practices (UDAAP) and other related regulatory guidance. The Fair Banking Officer works directly with business lines and other corporate functions to help ensure compliance with applicable laws and regulations and identify, assess, and manage fair and responsible banking risk associated with the products and services offered by the Bank. 

ESSENTIAL FUNCTIONS:

The Fair Banking Officer is responsible for leading the development and implementation of the Bank’s Fair Lending Program and maintaining a robust methodology for measuring, monitoring, and risk reporting. The Fair Banking Officer analyzes loan application and origination activities to document fair lending risks and the Bank’s mitigating controls. The Fair Banking Officer will periodically compile reports to Management, the Board of Directors, and other stakeholders for analysis and tracking purposes. 

This position plans, organizes and controls the Bank’s Day to day operational compliance activities as it relates to Fair Lending and collaborates with stakeholders in the overall administration of these directives for the Bank. The Fair Banking Officer advises Bank staff, Senior Management, and the Board of Directors of emerging Fair Lending risks, issues, and consults the Bank in the establishment of controls to mitigate risks.

The Fair Banking Officer will also be expected to build effective relationships with all respective stakeholders (e.g., Lending Officers, CRA Officer, Compliance Officer, industry, and regulatory authorities), and participate in various Committees, audits, and examinations.

PRINCIPAL ACCOUNTABILITIES:

• Monitor the Bank’s compliance with Fair Lending laws by conducting a Fair Lending risk assessment and performing a statistical analysis of lending activity to identify fair lending risks, including redlining risk factors.
• Assist lending staff in compiling and analyzing Fair Lending compliance metrics in context of the Bank’s lending practices and relationship to fair and responsible banking laws and regulations to identify factors that may contribute to an elevated risk profile.
• Maintain current knowledge of lending products, programs, operations, systems, and controls.
• Review, analyze, and make recommendations regarding the geographic distribution of loan products, deposit products, and service delivery systems.
• Perform ongoing second reviews of non-originated applications for completeness, accuracy, and appropriateness. 
• Coordinate with lending lines of business to evaluate proposed business changes, including new or modified products/services, new or modified policies, procedures, processes, or systems to ensure compliance with applicable fair lending related laws and regulations; Collaborate with other departments to direct, investigate and independently resolve Fair Lending and/or UDAAP concerns in a timely manner; 
• Perform ongoing reviews of consumer complaints and advertisements. Evaluate for potential trends, root cause analysis, and provide oversight of actions and responses for fair lending compliance related complaints.
• Using vendor supported software tools, evaluate statistical results of loan application and origination activity for low to moderate income and majority minority census tracts. Develop recommended strategies to increase penetration.
• Using statistical sampling techniques, perform focused file reviews to assess whether an applicant was treated in a manner consistent with articulated standards, including whether the applicant received favorable treatment compared to other similarly situated applicants.
• Summarize results of the file review and prepare analysis reports that succinctly identify the individual and aggregate risks identified during the file review.
• Participate in the review of results of file review analysis with business unit partners, including procedure and process gap analyses and develop recommended actions.
• In collaboration with the CRA Officer and other lending personnel, monitor and suggest enhancements to the Bank’s marketing/outreach, lending, service, and investment strategies to support the needs of low to moderate-income and majority minority census tracts; work with bank management to ensure all products, services and activities are compliant, profitable, and marketable.
• Develop, monitor, and report Key Risk Indicators (KRIs) to ensure that Fair Lending compliance risks are adequately identified, assessed, monitored, and controlled.
• Prepare periodic fair lending reports for Senior Management, the Board of Directors, and other stakeholders that includes significant fair lending developments, fair lending risk monitoring and testing results, and fair lending KRIs. 
• Keep abreast of business policies, related laws and regulations guidance, and other legal and regulatory developments which directly affect business practices in place to promote fair lending activities.
• Develop and maintain fair lending training materials for employees, Officers, and Directors, as applicable to individual roles and responsibilities. Fair lending training would include fair lending laws and regulations and guidance for mitigating engaging in unfair and deceptive practices.
• Assist in the coordination of regulatory compliance exams and audits as necessary; and 
• Other duties as assigned.

MINIMUM REQUIREMENTS:

• A bachelor’s degree in business administration or related field, or equivalent work experience such as experience managing fair lending compliance at a large financial institution is required. Advanced degrees (MBA, JD), and/or certifications such as Certified Regulatory Compliance Manager (CRCM) is a plus.
• At least 10-15 years’ experience in an applicable risk management environment with emphasis on fair lending compliance or financial institution examination at the federal or state level.
• Strong knowledge of consumer loan underwriting, mortgage lending operations, HMDA data aggregation and statistical analysis, and federal and state banking regulations. 
• Significant knowledge base of fair and responsible banking laws, regulations, and oversight, and related FFIEC examination standards, applicable regulatory guidance, and UDAAP litigation and enforcement actions. 
• Ability to conduct thorough analysis and provide pragmatic recommendations and solutions to problems.
• Strong oral and written communication skills with the ability to present and influence strategy at all levels in the organization.
• High level of productivity, ability to take task to completion and meet deadlines under pressure coupled with a focus on quality.
• Familiarity with corporate compliance programs, including risk assessments, testing, and monitoring, training, policy/procedure development, and implementation of new products and business processes.
• Experience with CRA and Fair Lending Wiz software preferred; and
• Strong competency in Word and Excel, PowerPoint, and Outlook.

PHYSICAL REQUIREMENTS: 

• General Office Equipment
• Keyboard Dexterity
• Prolonged Sitting

 COMPLIANCE:

Acts affirmatively in all activities under his/her control in conformance with the Bank’s Affirmative Action, Equal Employment Opportunity, and Fair Lending Programs to achieve the Bank’s goals and objectives. The Bank shall provide equal employment opportunity to all qualified persons, and continue to recruit, hire, train and evaluate persons in all jobs without regard to race, color, religion, sex, national origin, or veteran status.

Liberty Bank is an Equal Opportunity employer. It is the policy of Liberty Bank to provide equal employment opportunities to all qualified applicants without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, protected veteran or disabled status, or genetic information.

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