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Compliance Manager - Testing ("CMT)
Salt Lake City, UT
WebBank (the "Bank") is headquartered in Salt Lake City, Utah, and is an FDIC-insured, state-chartered industrial bank that provides customized consumer and commercial financing solutions on a nationwide basis.
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 Strategic Partner program oversight, management and risk mitigation. Similarly the Bank's Compliance Department has Strategic Partner Compliance Managers ("SPCM's) that are dedicated to overseeing and managing the compliance controls and risk mitigation strategies in place at assigned Strategic Partner programs. Working collaboratively the Strategic Partnership Group, the Compliance Department and Bank management ensure that Strategic Partner Programs are in full compliance with federal and state lending regulations as well as all WebBank credit requirements.
Job Description Summary
The Compliance Manager - Testing ("CMT") will report to the V.P. Compliance. The CMT 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 CMT will work with counterparts in the Credit Department and 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 CMT 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 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. In addition, the position will from time to time involve other testing, monitoring and quality control work outside of Bank activity related to Strategic Partnerships. In carrying out duties the CMT will collaborate with the V.P. Compliance Officer, Chief Compliance Officer, Chief Credit Officer and the Strategic Partnership Group in developing a standardized reporting format for ongoing presentation to Executive Management and the Board of Directors. In addition the CMT will participate in various committees, audits and examinations. The CMT will assist with the development and continued enhancement of bank-wide and SP Program-specific compliance policies and procedures. The CMT will perform ongoing monitoring of compliance practices to ensure SP programs are in full compliance with applicable regulations.
- Review, assess, summarize and distribute test results from 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 stays current with the approved schedule and work with the Compliance Department, Credit Department and Strategic Partnership Group to recommend revisions as needed.
- Update existing testing and monitoring procedures as necessary and implement new testing and monitoring procedures as applicable. Collaborate with SPCM's to customize testing and monitoring processes when needed based upon unique features of each product offering.
- Develop new reports and enhance existing testing and monitoring reports to ensure that test results are appropriately and transparently conveyed to management and the Board.
- 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.
- Participant in the development of the annual Testing Road Map.
- Responsibility for ongoing maintenance and updates to Testing Road Map.
- Active participant in the oversight of outstanding compliance issues until resolution.
- Conduct and/or assist in credit related compliance testing and monitoring for each Strategic Partner Program based on the monthly data download from each SP.
- Collaborate with SPCM's to complete other testing and monitoring initiatives for the SPCM's assigned SP programs.
- Collaborate with SPCM's and SP's to enhance their internal testing and monitoring programs. Identify best practices across SP's and make recommendations for enhancement of SP testing/monitoring programs.
- Complete designated compliance monitoring and testing activities.
- Inform V. P. Compliance of credit recommendations and key developments at Strategic Partner Programs and determine the compliance impact (if any) of those developments to the Bank.
- Evaluate credit application exceptions, review exception reports and communicate findings to management.
- Ensure that Strategic Partner Program business practices, pertaining to compliance policies and procedures, credit policies and 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 lending laws that may have compliance implications or that may affect the credit process. 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.
- Evaluate requested credit policy changes including strategies to adjust scorecards.
- Review fraud modules, scorecards and credit processes to determine compliance implications.
- Participate with Compliance Department, Credit Department and SP Group to evaluate loss mitigation, recovery management and servicing strategies. Ensure strategies meet regulatory and compliance expectations.
- Ensure that new product development, system initiatives and other projects adequately consider and address compliance related issues and adjust monitoring program if appropriate.
- Perform site visit reviews of Strategic Partner Programs with a primary focus on SP testing and monitoring programs and a secondary focus on adherence to credit and compliance requirements. Must be willing to travel at least one week per month.
- Conduct internal Bank, non-Strategic Partner quality control reviews, audit reviews, testing and monitoring as assigned by V.P. Compliance or the Chief Compliance Officer. This activity may include but will not be limited to review of Senior Secured Loan Participation activity, and Federal Reserve Line of Credit audits.
- Bachelors degree and minimum of 5 years of consumer credit/compliance experience or alternately a minimum of 7 years of consumer credit/compliance experience. Internal or External audit backgroup preferred.
- 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. CRCM preferred.
- 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 performance metrics as well as applicable 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. Must be able to think beyond the issue at hand and determine causes and/or impacts to issues discovered during reviews in order to take the best course of action.
- Outstanding initiative, communication skills (verbal and written), attention to detail and organizational skills required.