Role Summary: The Fair Lending Specialist primary responsibilities is to work with the VCI business units to develop, implement and maintain an appropriate oversight structure and related tools & techniques to ensure Fair Lending and UDAAP risks are managed appropriately. The role supports the Director, Consumer Risk to strategically expand and enhance the analytic monitoring in support of the VCI's Fair Lending Program. This critical role within the VCI Risk Management Team, supports and provides statistical analysis and reporting for fair lending risk across all of VCI's Consumer Business Units. The incumbent will work closely with key business stakeholders and compliance in the development, execution and implementation of fair lending models and analysis, and requires demonstrated knowledge of predictive model development as well as data manipulation and its governance in support of fair lending analyses addressing risk across all aspects of the auto retail finance and lease processes from marketing to servicing including underwriting, pricing, collection practices, and collateral liquidations.
This role can be based out of our Herndon, VA or Libertyville, IL office. Role Responsibilities: Main responsibility – Fair Lending Analysis - 60% of time
- Monitor the VCI's compliance with Fair Lending laws by utilizing SAS and other analytical tools to analyze lending activities and identify risks.
- Statistical analyses will be performed to determine risk associated with underwriting, pricing, and servicing.
- Perform regression testing, identify matched pairs, and conduct file reviews to monitor potential unfair treatment. SA and other statistical tools will also be used to create maps and perform peer analyses.
- Ensure fair lending reports are designed to provide VCI operations with information needed to evaluate fair lending performance.
- Interacting closely with Legal & Compliance; Finance; and Sales (including the field force, as needed). Will also work with IT and Data Governance to ensure accurate reporting, monitoring, and corrective action (where required) is undertaken.
- Make regular and special reports (as necessary) to the Fair Lending Subcommittee and/or the Retail Credit Subcommittee to apprise them of fair lending risks.
- Review fair lending data analyses, compliance reports, and complaints. Support the Senior Manager Consumer Portfolio; GM Consumer Credit Risk; GM Credit and Funding; and Legal and Compliance departments in developing and implementing risk mitigation strategies, tracking and reporting progress, and validating corrective actions.
- 10% of time: Assist in conducting the Fair Lending Risk Assessment, including evaluation of inherent risk as well as the sufficiency of business unit controls to detect and prevent fair lending risk.
- Support the Director Consumer Credit Risk and Sr. Director, Originations in overseeing reviews of credit policies, loan operations processes, credit, pricing, and marketing models, new and modified lending products and services, business changes and marketing campaigns.
- Perform periodic procedure and process gap analyses, reviews or audits and other testing to identify, remediate, report or escalate findings related to fair lending and Program performance.
- Will serve as a corporate representative, if needed, in regulatory and administrative hearings.
- As a subject matter expert, provide guidance to business units on the Fair Lending-related regulations by keeping abreast of developing trends and changes in regulations relating to Fair Lending
Experience Required: 5 - 7 years of experience in a financial institution, auditing firm, or consulting firm in a Risk management, regulatory compliance or internal audit role. Experience in the following:
- Applied statistics, economics or other quantitative area, preferably in financial services or regulatory
- Data mining, trend investigation, report development and management presentation techniques
- Bachelor's degree in highly quantitative field, such as data science, business analytics, applied microeconomics, applied statistics
- Master's degree in a related area
- Analytical and conceptual thinking – using logic and reason, creative and strategic
- Demonstrated expertise in SAS (Enterprise Guide) programming.
- Communication skills – written, verbal and listening that accurately and clearly summarizes issues and present solutions in an understandable and logical manner.
- Proven ability to independently coordinate and complete projects, along with a demonstrated inclination to address difficult topics with unique problem-solving capabilities.
- Critical thinking and the ability to “connect the dots” of multiple data points across multiple business units to develop a comprehensive assessment of compliance risk
- Knowledge of consumer protection laws and regulations impacting financial institutions
- Ability to create models to perform Fair Lending analysis, monitoring and testing
- Subject matter expertise in fair lending and consumer protection laws and regulations.
- Testing, audit, or investigation experience related to fair lending or regulatory compliance
- Advanced knowledge of fair lending laws, regulations, and oversight, including ECOA, UDAAP, Regulation B, applicable regulatory guidance, and fair lending enforcement actions
- CRCM Certification (Certified Regulatory Compliance Manager)
- Minimal travel 5-15%
- Depending on where the employee is based, travel to the respective locations will be required - Portland Service Center, Auburn Hills, MI, Libertyville, IL and corporate HQ in Herndon, VA as needed.
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