Head of Fair Lending Analytics
Who We Are
Cross River is a highly profitable, fast-growing financial technology company powering the future of financial services. Our comprehensive suite of innovative and scalable embedded payments, cards, and lending products deliver financial services for millions of businesses and consumers around the globe. Cross River is backed by leading investors and serves the world’s most essential fintech and technology companies. Together with its partners, Cross River is reshaping global finance and financial inclusion.
We are on a mission to build the infrastructure that propels access, inclusion, and the democratization of financial services. While our company has tripled in size over the last three years, our strong sense of purpose led Cross River to be named to American Banker’s list of Best Places to Work in Fintech for the last 6 years. The reason for this success is simple – our nimble and collaborative family culture lives in every member of our growing team. Together we are at the forefront of technology and innovation, and we invite passionate, collaborative, and motivated high performers to join our expanding team.
What We're Looking For
This Head of Fair Lending Analytics (FL Analytics) role reports directly to the Director of Fair Lending Compliance and is responsible for assisting with developing, implementing, and managing all aspects of the Bank’s Fair Lending Compliance Program required to maintain a satisfactory fair lending risk profile, within risk tolerance levels approved by the Board of Directors. This position assists the Bank with meeting its fair lending regulatory requirements and maintaining an appropriate Fair lending Compliance Program that is suitable for its size, complexity, and business model. The Head of Fair Lending Analytics advises the Bank’s Board of Directors, Executive Suite, oversight committees, Senior Management, and Bank personnel of emerging fair lending issues to ensure compliance directives are maintained and examination-ready guidelines are followed. The role also supports the Director to ensure department activities run smoothly and efficiently by providing leadership, training, and supervision within the department. The Head of Fair Lending Analytics establishes and maintains relationships with internal and external stakeholders, including Lending, Servicing, customer contact teams, MPL partners, Risk, Government Affairs, regulators, and industry stakeholders.
The Head of FL Analytics is tasked with developing and maintaining the Bank’s Fair Lending analytics program, ensuring that appropriate Fair Lending statistical and qualitative analyses are conducted timely to mitigate fair lending risk across various lines of business. This role, specifically, is responsible for developing a risk-based approach to fair lending analytics and establishing processes and procedures to perform periodic analysis of various Lines of businesses within the Bank to ensure compliance with Fair Lending related laws and regulations, including Fair Housing Act (FHA) and Equal Credit Opportunity Act (ECOA). Additionally, this role will partner with model risk management teams in an effort to implement appropriate fair lending controls.
- Assist the Director with implementing, and reviewing, the Bank’s Fair Lending Compliance Program, including policies and procedures, program governance, staff, and compliance with federal and state fair lending laws and regulatory guidance.
- Support the Director with an “exam ready” approach and managing fair lending examinations.
- Provide interpretations and clarifications of laws, regulations and issues relating to and including and the Equal Credit Opportunity Act (ECOA), Fair Housing Act (FHA), Home Mortgage Disclosure Act (HMDA) as well as other regulations as applicable; identifies and coordinates the implementation of new and updated regulations.
- Leads the preparation and serves as one of the Bank’s points of contact for regulatory examinations, internal audits, and reviews related to fair lending analytics.
- Assists with corrective action taken by management to address fair lending issues, including assisting with the implementation of the corrective action plan, conducting follow-up reviews to determine the adequacy and effectiveness of the action taken and, effectiveness.
- Assist with developing and maintaining effective working relationships and communications internally and with regulatory agencies, lending partners, and industry stakeholders.
- Work with business units and FinTech partners engaged in lending activities to ensure the Bank meets the credit needs of protected classes, both individuals/communities, within the Bank’s credit markets.
- Provide guidance on all fair lending related issues that arise internally at the Bank or at third-party lending and banking partners.
- Review potential fair lending complaints and proposed responses from third-party lending partners, as necessary.
- Review and enhance Cross River’s internal policies and procedure documents to reflect current regulatory requirements and associated control functions maintained to properly mitigate fair lending risks.
- Provide regular reporting to the Director on progress, team performance, at risk deadlines, material risk issues, and updates for oversight committees.
- Supervise lower-level team members, as assigned by the Director.
- Support other risk mitigation efforts of the Director on an ad hoc basis.
- Research, analyze and interpret all applicable Fair Lending and Fair Banking regulations and statues, including the Community Reinvestment Act, Home Mortgage Disclosure Act, Equal Credit Opportunity Act, and Unfair and Deceptive Acts and Practices rule and implement changes to and/or enhance existing policies and procedures.
- Coordinates, documents, and reviews lending, investment, and service activity. Creates and implements enhancements to data collection processes.
- Reviews loan data for accuracy, analyzes findings, and summarizes reports to management and the Board of Directors.
- Prepares and presents assessments to the Board of Directors and Senior Management.
- Performs Fair Lending Analytics Assessments through review of small business, small agricultural, mortgage, and consumer lending application data. Analyzes findings and reports to management and the Board of Directors.
- Advises senior management regarding compliance and/or consumer harm concerns relevant to the products and services currently offered by the Bank and any proposed changes. Reviews new or changing products and services to ensure that the Bank’s lending programs, deposit products and other financial services do not impact low-to-moderate income individuals in a negative way.
- Serves as backup for other position(s) and performs other duties, as assigned.
- Enhances career through work experience and continuing education.
- Maintains compliance with federal, state, and local laws and regulations.
- Participates and responds to examiners, audits, and third-party reviews.
- Complies with the Information Security Program and is accountable for maintaining a high level of risk and security awareness.
- Establishes a good image for the Bank by being active and visible in the community.
- Attends meetings as assigned.
- Develops a working knowledge of the Bank’s products and services to provide quality customer service while building relationships and exceeding expectations.
- Minimum of eight (8) + years’ experience in fair lending compliance capacity, with five (5) + years’ experience in a project manager or lead position. Minimum 5 years management experience preferred
- Subject matter expert in fair lending laws, associated regulatory requirements, guidance, and examination standards.
- Demonstrated ability to research, read, and interpret government regulations, technical reports, and legal documents.
- Experience in developing and managing control processes required to maintain a proactive Compliance Management System (CMS) that meets regulatory expectations.
- Strong leadership interpersonal skills; ability to build consensus across diverse teams and achieve results through the efforts of others.
- Strong information and project management skills.
- Strategic and solution-oriented mindset with development analytical ability.
- Strong planning and organizational skills, with an ability to establish strategic direction and subsequently develop and manage supporting initiatives.
- Proven ability to prioritize and manage workload and to instill a sense of urgency in other as necessary to meet deadlines and/or goals.
- Extensive knowledge of bank operations and lending processes.
- Solid technology abilities, including intermediate proficiency with Microsoft Office and fundamental experience with fair lending or CRA reporting and analysis software (e.g., RiskExec, CRA Wiz, SAS, etc.)
- Excellent presentation and communication skills, including technical writing abilities.
- Ability to respond to fair lending inquiries or complaints, regulatory agencies, lending partners, or industry stakeholders.
- Ability to competently manage and support staff.
- Bachelor’s Degree required; advanced degree in statistics or a similar discipline is preferred, or certification preferred. Degree should emphasize compliance, finance, regulatory review, accounting, law, government planning, or risk management, or an equivalent amount of relative experience.
- Proficiency in analyzing diverse business functions and processes to identify key risks and demonstrated success with implementing control improvement recommendations.
- Ability to interact with federal regulatory agencies.
- Ability to operate effectively in a fast-paced environment.
- Excellent organizational and analytical skills.
- Ability to communicate clearly and professionally with all levels of an organization.
- Excellent written and verbal communications skills.
- Effective interpersonal skills.
- Excellent time management skills and accustomed to working with deadlines.
- Certified Regulatory Compliance Manager (CRCM), Certified Internal Auditor (CIA), and/or Certified Financial Services Auditor (CFSA) designation a plus.
#LI-Hybrid #LI-Onsite #LI-Remote
Salary Range: $180,000.00 - $200,000.00
Cross River is an Equal Opportunity Employer. Cross River does not discriminate on the basis of race, religion, color, sex, gender identity, sexual orientation, age, non-disqualifying physical or mental disability, national origin, veteran status or any other basis covered by appropriate law. All employment is decided on the basis of qualifications, merit, and business need.
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