Strategic Partner Compliance Analyst
Strategic Partner Compliance Analyst ("SPCA")
Strategic Partner Business
WebBank (the "Bank") is a leading provider of national consumer and commercial private-label and bank card financing programs. The Bank works closely with Strategic Partners ("SP's") to design, develop, implement, administer and fund customized consumer and/or commercial financing
program(s). The SP's are vendor clients that administer Bank programs on behalf of the Bank with a range of product offerings that include:
- Closed-end Installment Loans (Consumer & Commercial)
- Revolving charge (Consumer & Commercial)
- Private-Label/Co-Brand/Dual-Line Cards (Consumer & Commercial)
- General Purpose Credit (Consumer & Commercial)
- Small Business Programs
The Bank has an established Strategic Partnership Group with dedicated Program Managers focused on all aspects of program oversight, management and risk mitigation. The Credit Department and Compliance Department work closely with the Strategic Partnership Group to ensure that Strategic Partner Programs are in full compliance with all federal and state lending regulations as well as all WebBank credit requirements.
Job Description Summary
The SPCA will report to the V.P. Compliance. The SPCA will be engaged in a variety of vendor management activities and will be primarily responsible for ensuring that the Bank's testing and monitoring procedures are implemented as designed across all Strategic Partner Programs. In addition, the SPCA will work with counterparts in the Strategic Partnership Group to ensure that the credit policy for each Strategic Partner ("SP") Program is capably designed and appropriately administered in full compliance with federal and state lending regulations as well as all WebBank requirements. The SPCA will engage in various compliance and SP credit related activities as directed by the V.P Compliance or the Chief Compliance Officer.
In collaboration with each Strategic Partner Compliance Manager ("SPCM") this position involves testing, monitoring and evaluating SP compliance with applicable law and regulatory requirements. The position also involves monitoring and reporting on the Bank's Strategic Partner related credit activity. The SPCA will collaborate with the V.P. Compliance Officer, Chief Compliance Officer, Chief Credit Officer and the Strategic Partnership Group in development of a standardized reporting format for ongoing presentation to Executive Management and the Board of Directors. In addition the SPCA will participate in various committees, audits and examinations. The SPCA will assist with the development and continued enhancement of bank-wide and SP Program-specific credit policies and procedures. The SPCA will perform ongoing monitoring of credit practices to ensure SP programs are in full compliance with applicable regulations.
- Review, assess, summarize and distribute test results for SP's (SP work product) on a monthly basis. Identify weaknesses and work with SP Program Managers and SPCM's to correct deficiencies.
- Ensure that internal testing and monitoring of SP activity is current and work with Compliance Department and Strategic Partnership Group to recommend and make revisions as needed.
- Work with V.P. Compliance and Bank Credit Department to evaluate scoring models for each SP Program to ensure that they are empirically derived, statistically sound and do not include prohibited basis factors.
- Evaluate compliance aspects of Bank credit policies for each SP Program. Collaborate with Compliance and Credit Department employees to assess SP credit policies for potential compliance related concerns and propose modifications when warranted.
- Conduct credit testing and credit related compliance testing and monitoring for each Strategic Partner Program based on monthly data download from each SP. This testing and monitoring will include but may not be limited to the following areas:
- Conformance to Bank Credit Policies
- Adverse Action Handling
- Risk Based Pricing Administration
- Credit Line Assignment Management
- Scorecard Implementation
- Collaborate with SPCM's to complete other testing and monitoring initiatives for the SPCM's assigned SP programs.
- Complete designated compliance monitoring activities.
- Inform V.P. Compliance of all credit recommendations and key credit developments at Strategic Partner Programs and determine the impact of those developments to the Bank.
- Evaluate credit application exceptions, review exception reports and communicate findings to management.
- Evaluate loan files on a regularly scheduled basis to ensure that they are compliant with applicable Bank credit policy and that they do not contain prohibited material (Ex: Drivers license).
- Ensure that Strategic Partner Program business practices, pertaining to credit policies, credit procedures, loan pricing, loan origination and loan disclosures comply with Bank requirements and applicable federal and state regulations.
- Stay abreast of federal and state regulatory changes related to consumer lending laws affecting the credit process and ensure those changes are communicated to and addressed by company management.
- Provide assistance in addressing internal and external audit findings that relate to credit and/or compliance activity and help prepare responses as requested.
- Conduct reviews of manual adjudication activity and develop/maintain appropriate reports of same.
- Participate in monthly calls with SP Program Managers and SP's to evaluate SP Program credit performance.
- Evaluate requested credit policy changes including strategies to adjust scorecards.
- Review fraud modules, scorecards and credit decision tree processes to determine compliance implications if any.
- Participate with Compliance Department, Credit Department and SP Group to evaluate loss mitigation, recovery management and servicing strategies.
- Review risk assessment write-ups and provide input as necessary pertaining to compliance and credit areas.
- Complete all mandatory compliance training within prescribed timeframes.
- Ensure that new product development, system initiatives and other projects adequately consider and address compliance related issues.
- Work closely with retained legal counsel and compliance personnel to interpret new and existing laws and regulations that impace SP credit and compliance processes. Communicate those interpretations to applicable personnel.
- Perform site visit reviews of Strategic Partner Programs with a primary focus on SP adherence to credit and compliance requirements. Must be willing to travel at least one week per month.
- Associate's degree and minimum of 3 years of consumer credit/compliance experience or alternately a minimum of 5 years of consumer credit/compliance experience.
- Strong working knowledge of consumer lending compliance requirements, particularly those that relate to credit activity (Ex: ECOA, TILA, FCRA, FACTA).
- Must have prior bank or financial services credit and compliance experience.
- Direct experience dealing with regulators (FDIC, Utah Department of Financial Institutions) is highly desired.
- Strong background in federal and state lending laws.
- Excellent ability to analyze and interpret credit performance metrics as well as state and federal regulations.
- Strong self-confidence, good judgment and the ability to make sound decisions.
- Must interface effectively with other departments.
- Ability to handle a fast paced environment with minimum supervision and successfully meet established project deadline requirements.
- Strong problem solver.
- Outstanding initiative, communications skills (verbal and written), attention to detail and organizational skills required.
If you would like to apply for this position, please send your resume to: firstname.lastname@example.org