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Exchange Bank · 17 hours ago

CRA & Fair Lending Officer

Santa Rosa, CA

Full-time

Onsite

Mid, Senior Level

$105K/yr - $148K/yr

5+ years exp

Exchange Bank is focused on community reinvestment and fair lending practices. The CRA & Fair Lending Officer is responsible for developing and administering the bank's CRA Compliance Program and Fair Lending initiatives, ensuring compliance with relevant laws and regulations while promoting fair lending practices within the organization.

BankingFinanceFinancial Services

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. This should include ongoing monitoring and testing of exceptions to ensure there are not trends indicating fair lending issues exist as well as identifying exceptions that are routinely granted that should be incorporated into procedures, standards, pricing, policies, etc

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. This should include ongoing monitoring and testing of exceptions to ensure there are not trends indicating fair lending issues exist as well as identifying exceptions that are routinely granted that should be incorporated into procedures, standards, pricing, policies, etc

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

Qualification

Fair Lending lawsCRA ComplianceRisk assessmentFair Lending ProgramLoan compliance practicesMicrosoft OfficeResearch skillsInterpersonal skillsProblem-solving skillsTeamwork

Required

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