SVP Chief Compliance Officer
This SVP, Chief Compliance Officer (CCO) reports directly to the company’s Chief Risk Officer and is a member of the company’s Management Committee. The CCO is responsible for managing all aspects of the Corporate Compliance function to ensure the adherence to all relevant laws, regulations, and company policies. Additionally, the CCO will have responsibility for the policy and operations for the company’s AML/BSA and Sanctions programs. The CCO will lead teams responsible for maintaining the company’s framework for compliance risk management and will work closely with senior leaders across the organization to ensure effective implementation.
- Establishes strategic direction for, oversees and maintains an effective Enterprise-wide Compliance Management System (CMS) for all legal and regulatory requirements applicable to the company Financial Services including the following elements:
- Develops and maintains inventory of compliance control standards, including consumer regulatory requirements and customer commitments
- Owns Regulatory Change Management process to ensure requirements remain up to date and are communicated to process owners
- Develops and executes enterprise compliance programs, policies, standards and procedures which support the 1st Line in effectively managing Compliance Risk
- Monitors 1st Line compliance with enterprise programs, policies, standards and procedures
- Periodically conducts a Compliance Risk Assessment and performs a Compliance maturity assessment
- Oversees the development of and adherence to required compliance training for new and current employees
- Provides oversight to ensure appropriate documentation, root cause analysis, and remediation of issues with consumer Impacts, audit findings, compliance testing findings, and regulatory findings
- Oversee first line complaint management, challenging root cause analysis, ensuring issues are investigated and root causes are analyzed and addressed
- Develops and maintains effective compliance programs for Fair Lending, Third Party Compliance, UDAAP and Privacy risk management
- Develops and sets risk appetite and key risk indicators as well as reporting escalation thresholds
- Ensures clear accountability for CMS execution across the company and determines organization required, including skill and staffing needs, for Compliance team to implement and maintain the CMS
- Ensures an effective compliance culture within the company, supported by tone from the top, clear expectations, monitoring, and escalation
- Chairs the company’s Compliance Committee and oversees compliance related subcommittees. Provides regular reporting to the Corporate and Bank Boards and the company’s Risk Committee regarding the state of the Compliance program and current and emerging compliance risks. Provides guidance to senior management and Board/Audit Committee members on the most significant compliance initiatives, identified compliance deficiencies, and corrective action taken or to be taken. Is expected to identify and share emerging compliance trends and opportunities to proactively mitigate risk for the organization in the future
- Participates in regulatory and audit exams regarding compliance and leads or oversees corrective action associated with regulatory requirements or orders
- Works closely with first line leaders, Legal and Audit to ensure understanding and adherence with compliance requirements that are applicable company-wide and to their organizations. Provides guidance, as needed, to process owners to help them plan for how to operationalize new or changed legal or regulatory requirements and Compliance initiatives
- Maintains a thorough understanding of all relevant federal and state regulations and works closely with internal legal counsel and business teams to operationalize new or changing regulations into Compliance programs
- Ensures the Company is meeting all regulatory recordkeeping and reporting requirements
- As a member of the overall Risk Leadership team, actively engages in the development of the risk management strategy for the company, including achieving the company’s risk management goals of maintaining a risk aware culture, optimizing risk / reward in decision making, and developing and maintaining effective and efficient risk management program
- Technical Compliance Expertise: Hands-on, practical experience developing and delivering a comprehensive compliance program identifying, monitoring and controlling significant consumer regulatory risks (e.g., UDAAP, Fair Lending, Privacy) in a complex environment (e.g., multi-product, large scale business)
- Relevant Industry Expertise: Deep understanding of the consumer finance industry, preferably with prior experience in consumer credit cards and ideally in some other company products: deposits, mortgages, student loans and personal loans.
- Leadership and Influence: Prior experience developing, training and retaining a high-performing team of similar scale. Strong track-record of grooming successors. Good followership. Experience presenting to the Executive Leadership Team and preferably a Board
- Regulatory Credibility: Track record of enhancing compliance programs to meet the needs of a heightened regulatory landscape. Track-record of building credible relationships with major regulators (OCC, FRB, FDIC, CFPB).
- Change Management/Transformation: Proven success delivering large-scale transformation or change management projects across highly matrixed organizations, ideally experience remediating a consent order. Ability to quickly develop a strategy and drive identification of opportunities for innovation and improvement.
- Risk Management Experience: Possess broad risk management experience and a deep understanding of the roles, responsibilities and interconnectedness of the three lines of defense.
- Take Responsibility: establish clear accountability and follow up, deliver high quality work, understand and meet all legal and regulatory obligations
- Stay Ahead: have the courage to make problems visible, respond with flexibility when new information arises, balance risk and reward when making decisions
- Be a Good Partner: take an end to end perspective to achieve shared goals, resolve conflicts to create most benefit for all, honest and straightforward in all situations
- Innovate and Simplify: focus on process, standardize work, eliminate complexity, reduce costs
- Develop Others: identify and address skill needs, create opportunities for skill growth, build team