Under the general supervision of the CFO, the position is responsible for the Credit Union’s overall compliance for BSA, Savings, Loans and Operations with applicable rules, regulations, and statutory requirements. This is accomplished through development and implementation of a Compliance Program and performance of the primary duties and responsibilities listed below. While implementing or recommending action to ensure compliance, the Compliance Officer should be conscious of streamlining efforts, cost effectiveness, safety and soundness and proper maintenance of the internal control structures.
- Monitor and analyze developing trends and changes to regulatory compliance laws, rules and regulations and advise management of the operational impact of such issues.
- Facilitate implementation of new regulatory requirements as well as changes required to comply with regulatory amendments.
- As the chairperson of the Credit Union’s Compliance Committee, provide guidance regarding new and proposed regulatory changes within the allowable timeframes established by regulatory agencies
- Assist Credit Union staff in facilitating appropriate procedural changes to maintain regulatory compliance, as necessary.
- Function as primary liaison with Federal and State examiners during compliance-related examinations.
- Ensure that compliance issues are addressed with internal and external auditors within an acceptable time frame. Monitor and address any outstanding audit/ examination findings.
Policy, Program and Product Oversight:
- Develop, participate in, and review internal policies and policy changes for regulatory compliance with applicable savings, lending, and operational requirements.
- Review revisions to Credit Union forms, disclosures advertisements, website, and other materials to ensure compliance with applicable laws, rules, and regulations. Provide and recommend amendments when necessary.
- Participate in new product development projects.
a) Research and define regulatory requirements for new products, services, and processes, identify new and/or undocumented compliance risks for Credit Union operations as a result of their introduction.
- Review system-programming changes to the extent of compliance with applicable regulatory requirements.
a) Provide department heads with guidance and assistance as related to compliance requirements during system conversions, upgrades or proposed system, forms / disclosure, and service changes.
- Performs compliance monitoring through transaction testing and reporting. Assists in preparing compliance reports with identified findings and recommendations and presents findings to Senior Management – (CFO/CLO). Develops, monitors, and implements lending compliance procedures as needed.
- Identifies defective controls and provides preventative measures to ensure compliance with applicable lending compliance regulations. Partners with the lending department to mitigate identified compliance risks.
- Administers all functions of Fannie Mae, Freddie Mac, and Ginnie Mae pre- and post-closing secondary market quality control reviews. Provides reports, uploads loan files, reviews quality control findings, and collects management responses to QC findings. Performs additional quality control reviews and ensures the quality control program meets secondary market quality control requirements.
- Responsible for CRA and HMDA. Reviews loan application data for accuracy in reporting consistent with HMDA and CRA requirements. Includes file sampling, testing, monitoring, and reporting. Conducts required HMDA testing and prepares quarterly reports for management review highlighting any identified trends. Reviews the HMDA worksheet and confirms data entered is accurate. Uploads data to HMDA and CRA LARS, reviews for any inconsistencies, and ensures accurate timely filing of HMDA and CRA submissions.
- Reviews and monitors the loan denial process, ensuring compliance with Adverse Action requirements for the Credit Union and regulators.
- Reports, at least quarterly, to the Audit Committee on current quarterly audit results, any findings, corrective actions, and status of prior open issues.
- Develop, maintain, review and update risk assessments in areas of (but not limited to) Fair Lending, BSA, AML Management and OFAC Program Oversight, Remote Deposit Capture, Internet Banking, Online Account Access and Business Account Products and Services.
- Prepare risk assessment reports as required for new or proposed products or programs.
a) Provide written reports regarding risk to current products and programs to applicable management staff, Executive and Senior Management staff and Directors.
- Assist management to develop and maintain a Compliance Training Program which effectively address the requirements of applicable laws and regulations, Credit Union policies and procedures and employee responsibilities.
- Assist management in coordinating and conducting compliance training for all applicable employees, including but not limited to, new-hires, existing employees, and Directors.
- Develop and maintain a current internal and online library of compliance resources and provide assistance to all areas of Credit Union staff when needed.
- Conduct research of individual regulatory-related matters as requested by Senior Management, Management staff or internal or external auditors as it pertains to Credit Union policies and or procedures or impending changes. Provide written response, including guidance and if applicable recommendations of action within an appropriate time frame.
To perform this job successfully, an individual must be able to perform each essential duty satisfactorily, and comply with all Federal, State, NCUA and secondary market Regulations, internal Credit Union policies and procedures. The qualifications below are representative of the knowledge, skill, and/or ability required. Reasonable accommodations may be made to enable individuals with disabilities to perform essential functions.
The position requires the ability to read and interpret documents, along with the ability to write routine reports and correspondence. The incumbent must possess the ability to speak effectively in one-on-one groups or large groups and the ability to respond to inquiries or complaints in a professional manner.
The incumbent should possess the ability to work with mathematical concepts such as probability and statistical inference. He/she should also be able to apply concepts such as fractions, percentages, ratios, and proportions to Credit Union situations. Must be proficient with Excel reporting and using formulaic functions for data analysis, trend analysis, reporting, and presentation.
Must have the ability to define problems, collect data, establish facts, and draw valid conclusions. Ability to interpret a variety of complex instructions furnished in written, oral, diagram, or schedule form.
The position requires strong experience with Loan Origination systems, ancillary loan systems, Credit Union Core operating systems, and Microsoft Word, Excel, and PowerPoint.
- Bachelor’s degree or equivalent experience.
- Compliance certification and/or experience in compliance is preferred.
- Minimum of five years’ experience in banking compliance or regulatory roles.
- Extensive knowledge of (but not limited to) applicable State and Federal regulatory requirements in areas of Regulation D (Truth in Savings), Regulation CC (Expedited Funds Availability Act) Bank Secrecy Acy, Patriot Act, OFAC, Regulation C (HMDA),Regulation E (Electronic Funds Transfer), Privacy Act, FACT Act (Red Flags / Identity Theft) Fair Credit Reporting Act, Fair Lending, Regulation Z ( Truth in Lending) and Regulation B (Equal Credit Opportunity Act).
- Ability to exercise sound business judgment.
- Prepare for exams and audits. Ensure deficiencies in audits and exams are corrected.
- Maintain a safe and productive work environment while promoting a team effort among staff.
- Ensure Credit Union confidentiality.
- Outstanding verbal and written communication skills.
Working Conditions and Physical Effort
The work environment characteristics described here are representative of those a compliance officer encounters while performing the essential functions of this job.
- Regular physical exertion required to lift up to 20 lbs.
- Work performed is typically sedentary with occasional periods of walking and standing. May also require stooping, kneeling, and crouching.
- Utilizes finger dexterity to perform computer options.
- Must be capable of effective oral communication via writing, telephone or fax, and face to face.
- Travel between locations and attend meetings.
Mental & Visual Demands
- Mental concentration required to work with numbers and spreadsheets.
- Work requires visual effort of significant duration to review documents and interact with others.
Work Environment and Hazards
- Work environment is in a typical office setting free from noise and hazards.