CRA & Fair Lending Officer

Summary

This position is responsible for developing, implementing, and administering all aspects of Exchange Bank’s Community Reinvestment Act (CRA) Compliance Program, Home Mortgage Disclosure Act (HMDA), and Fair Lending and Fair Banking Program. The CRA Officer develops and implements programs to ensure the Bank meets the needs of the community and attains CRA compliance goals and acceptable federal examination ratings. This position will perform Fair Lending monitoring of the Bank’s lending portfolios, serve as the Bank’s Fair Lending subject matter expert, advise Senior Management and the Board of Directors on Fair Lending risk issues and mitigation, partner with the business unit managers to identify and correct potential Fair Lending risk issues, and ensure that employees are appropriately trained to comply with Fair Lending requirements.

This position will have the responsibility for ensuring adherence to all fair lending and banking laws and regulations and upholding ethical practices within various product lines such as mortgage, small business, auto lending, personal loans, and retail products.

• Fair Lending and Fair Banking:
  • 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.
  • 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.
• CRA Compliance:
  • 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…