This position is in the U.S. Bancorp Fair and Responsible Banking Division (FRBD) and provides oversight of fair and responsible banking issues throughout the Company. The Fair and Responsible Banking Issue Specialist should have an expert level understanding of unfair, deceptive or abusive acts or practices (UDAAP) and fair lending (anti-discrimination) laws and regulations. The position will work directly with Business Line Issue Owners and Chief Risk Officer Groups in the evaluation and determination of issues, and ensure timely and appropriate resolution, including customer remediation. This position will also oversee issue classification within the system of record to facilitate accurate reporting and transparency of identified issues. This position will interact directly with senior managers and other key stakeholders of various levels within the organization, including Corporate Compliance, Operational Risk Management, and the Law Division and will require an advanced level of communication, relationship building, negotiation and writing skills.
1. Evaluate issues identified by business lines, second line of defense functions, audit and regulators (“issue sources”) and determine whether the issue involves risk of noncompliance with fair and responsible banking laws and regulations, or deficiencies in expected controls to mitigate risk. Document the evaluation and determination to provide transparency and support for decisions. Work with business lines, the Law Division, and other stakeholders as needed to perform the evaluation.
2. Provide guidance and credible challenge to issue sources on issue classification, including the associated risk category, authoritative source, issue severity, and control category. Monitor to ensure issue sources input accurate classifications in the system of record to facilitate correct and transparent reporting.
3. Provide guidance and credible challenge to business line resolution plans, customer remediation, and expected completion dates to ensure complete and timely resolution of fair and responsible banking issues.
4. Provide guidance and credible challenge to root cause determinations and perform horizontal analysis of root cause across the enterprise.
5. Monitor fair and responsible banking issues through closure to ensure complete and timely resolution, and continued accuracy of issue classifications.
6. Provide periodic reporting to management from issue identification through closure, including reporting via Quarterly Management Letters and senior management committees.
- Bachelor's degree, or equivalent work experience
- Seven to ten years of applicable experience
- Expert understanding of fair and responsible banking laws and regulations, including UDAAP, the Equal Credit Opportunity Act, the Fair Housing Act, and related federal bank agency standards, regulatory guidance, and litigation and enforcement actions
- Excellent verbal, written and analytical skills
- Excellent relationship management and negotiation skills
- Experience providing guidance on complex regulatory matters, enforcing requirements, negotiating desired outcomes, and reporting issues and trends to management
- Advanced understanding of consumer financial products, services, systems and associated risks/controls
- Detail oriented and organized
- Ability to work independently and with employees and management in remote locations or multiple time zones
- Proficient computer skills, especially Microsoft Office applications, and experience with Archer eGRC platform or other Governance, Risk, and Compliance systems
- Professional Certification, such as Certified Regulatory Compliance Manager (CRCM), Juris Doctor (JD) or certified audit professional
- Knowledge of applicable U.S. Bancorp policies, procedures, products and business lines
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