Grand Bank - Fair and Responsible Banking Officer

Fair and Responsible Banking Officer
Job Summary: The Fair and Responsible Banking Officer serves as Grand Bank for Savings, FSB (“Grand Bank” or the “Bank”) subject matter expert responsible for the design, implementation, and oversight of the Bank’s Fair Lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) compliance program across all products, delivery channels, and customer touchpoints, including digital banking platforms and the Bank’s national credit card program. This position will lead a team of compliance professionals and has direct interaction with senior leadership and Board-level committees.
This role provides second line of defense oversight to ensure the Bank delivers fair, transparent, and compliant products and services, while proactively identifying, assessing, and mitigating fair banking risks. The Officer partners with business lines, compliance, marketing, digital, payments, and credit card program teams to embed fair banking principles into product design, customer communications, and lifecycle management with a focus on ensuring fair, consistent, and equitable customer outcomes.
The position supports regulatory compliance with applicable laws and guidance, including Fair Lending laws (ECOA/Reg B, HMDA), UDAAP, Regulation E, Regulation Z, and applicable NACHA/ACH rules. Oversight spans the full product lifecycle, including product design, underwriting, model risk management, marketing, servicing, collections, and customer communications. The position reports to the Chief Compliance Officer and has authority to independently escalate issues, require corrective action, and provide credible challenge across all lines of business.
Essential Duties and Responsibilities: The essential functions include, but are not limited to the following:
Fair Banking Program Oversight:
Develop, implement, and maintain an effective second line Fair and Responsible Banking (Fair Lending and UDAAP) compliance program across all Bank products and services
Establish and maintain fair banking risk governance standards, including alignment with the Bank’s risk appetite and escalation frameworks
Provide independent review, challenge, and oversight of business line activities to ensure fair treatment of customers and compliance with applicable regulations
Conduct enterprise-wide fair banking risk assessments, incorporating deposit, digital banking, ACH/payment flows, and credit card products
Coordinate with the CRA Officer to ensure alignment between fair banking risk assessments and CRA program objectives, including equitable access to credit and services across designated assessment areas
Digital Banking, ACH, and Payments Oversight:
Provide oversight of fair banking risks within digital banking platforms, including account origination, servicing, disclosures, and customer experience
Review and challenge ACH and payment-related practices for compliance with NACHA rules, Regulation E, and UDAAP expectations
Monitor customer journeys across digital channels to identify potential disparate treatment or unfair, deceptive, or abusive practices
Partner with operations and technology teams to ensure fair and compliant design of automated decisioning, workflows, and customer communications
Monitor and manage the bank's overdraft program to ensure compliance with applicable regulations, internal policies, and fair lending principles, including periodic review of program parameters, fee structures, and customer impact metrics
Review automated decisioning models, algorithms, and credit policies for fair lending and UDAAP risk
Monitor developments in consumer financial data rights, including obligations under Section 1033 of the Dodd-Frank Act and emerging open banking frameworks, for fair banking and UDAAP implications related to third-party data access and customer-permissioned sharing
Provide oversight of error resolution processes (including ACH disputes and unauthorized transactions) to ensure consistent and fair customer outcomes
Credit Card Program Governance:
Provide fair lending and UDAAP oversight for the Bank’s national credit card program, including underwriting, line assignment, credit line management, pricing, fees, marketing, and servicing practices
Review credit card disclosures, marketing materials, and lifecycle communications for compliance with Regulation Z, UDAAP, and card network expectations
Analyze credit card portfolio performance, including approvals/denials, line management, fees, and customer outcomes for potential disparate impact or unfair practices
Support oversight of third-party processors, issuing platforms, and marketing partners to ensure alignment with fair banking requirements
Oversee credit card marketing, prescreen, and solicitation practices for compliance with fair lending and UDAAP expectations
Provide oversight of credit card collections, hardship programs, and loss mitigation strategies for fair lending and UDAAP risk
Monitoring, Testing, and Analytics:
Perform ongoing monitoring, testing, and analytics to detect fair lending and UDAAP risks across products and channels
Coordinate with the Model Risk Management (MRM) function to ensure fair lending risk is incorporated into every credit-decisioning model validation, including underwriting scorecards, risk-based pricing engines, and automated credit line increase models.
Conduct comparative file reviews, matched pair analysis, and peer benchmarking
Oversee complaint monitoring, categorization, and root cause analysis across all channels, ensuring timely identification, escalation, and remediation of systemic issues and potential UDAAP concerns
Support HMDA data integrity, analysis, and reporting, including preparation of management-level insights and recommendations
Support implementation and ongoing compliance with small business lending data collection requirements under ECOA Section 1071, including oversight of data integrity, reporting, and fair lending analysis of small business credit activity
Develop and maintain data-driven monitoring frameworks, dashboards, and key risk indicators (KRIs) to proactively identify fair banking risk trends
Advisory and Business Line Support:
Serve as a trusted advisor to business lines on new products, initiatives, and strategic changes, ensuring fair banking risks are identified and mitigated early
Review and approve marketing materials, customer communications, and product changes for fair lending and UDAAP compliance
Provide guidance on remediation strategies for identified risks, including corrective action plans
Governance, Training, and Reporting:
Develop and deliver fair banking training tailored to business lines, including digital, payments, and credit card teams
Provide fair banking oversight of third-party relationships, including fintech partners, marketing firms, digital platform providers, and payment processors
Prepare clear, concise reporting for senior management and Board committees on fair banking risks, trends, and program effectiveness
Assist in regulatory examinations and audits, including coordination of requests, responses, and remediation efforts
Maintain current knowledge of regulatory developments, enforcement actions, and industry best practices
Minimum Qualifications (Knowledge, Skills, and Abilities):
Bachelor’s degree or equivalent experience
7+ years of progressive experience in fair banking compliance, fair lending, or CRA, with at least 3 years in a leadership or officer-level role.
Experience working in or alongside a second line of defense risk management or compliance function
Experience launching or supporting a national credit card program
Prior interaction with OCC or FDIC examinations; familiarity with CFPB rulemaking, enforcement actions, and supervisory priorities
Demonstrated experience with digital banking platforms, ACH/NACHA rules, and/or payments ecosystems
Experience supporting or overseeing credit card programs, including knowledge of Regulation Z and card lifecycle processes
Strong knowledge of Fair Lending laws (ECOA/Reg B, HMDA), UDAAP, Regulation E, and applicable regulatory guidance
Familiarity with MRM frameworks (SR 11-7 or OCC equivalent), including documentation and governance expectations for automated decisioning models used in credit and customer management
Experience with statistical fair lending testing methodologies (regression analysis, matched-pair analysis, marginal effects analysis)
CRCM strongly preferred; candidates without the designation should have a clear path to certification or a comparable advanced compliance credential (e.g., CAMS, CCEP)
Strong analytical skills, including ability to interpret data, identify trends, and assess risk across multiple products and channels
Excellent written and verbal communication skills, with the ability to present complex topics to leadership
Proven ability to operate independently, manage multiple priorities, and influence cross-functional stakeholders
High level of int

Employment type
Full-Time

Work arrangement
No