Job Description
COMPL ADVISORY FAIR & RESP BNK The Fair Lending and Responsible Banking Advisory Lead within the Second Line of Defense (2LOD) is responsible for providing leadership and vision for Fair Lending and UDAAP regulatory compliance subject matter direction to the various divisions of Comerica Bank. Providing this leadership, vision and direction requires the position to actively seek and proactively recognize new Fair Lending and UDAAP laws and regulations that will impact the business units. This position will provide ongoing guidance as well as lead and manage major implementation processes, beginning with reading, interpreting and developing an in-depth knowledge and understanding of Fair Lending and UDAAP regulation and ending with a successful implementation across all impacted business units. They will be required to closely interact with the Line of Business and key stakeholders, including Legal, Internal Audit, Business Management and Control functions. This individual assists business units with their ability to detect, assess, and respond to emerging risk, and maintain a comprehensive Fair Lending and UDAAP compliance risk and control framework. Position Responsibilities: Fair Lending and Responsible Banking Regulatory Compliance and Business Partnership Provide advice and guidance on Comerica business lines and related activities by possessing strong working knowledge of the applicable rules and regulations such as Reg B/ECOA, Fair Housing Act, UDAAP, and related rules and guidance (e.g., FRB Supervision and Regulation Letters, CFPB bulletins, OCC Comptroller handbooks; OCC bulletins; FFIEC Guidance; etc.). Serve as compliance Subject Matter Expert on Fair Lending and UDAAP regulations within assigned area of responsibility. Provide ongoing leadership and coaching to business management and functional partners to assist with Fair Lending and UDAAP Compliance and Risk and Control Assessments by using a risk mindset; participate in process walkthroughs and documentation of key controls, analyze, and escalate potential gaps in control design or coverage to Fair Lending and Responsible Banking Advisory leadership team. In collaboration with the Fair Lending and Responsible Banking Advisory Manager participate in the development and implementation of Fair Lending and UDAAP Risk Assessments developed within the 2LOD to identify potential Fair Lending and Responsible Banking risks, assess the adequacy of controls, and determine residual risk to Comerica, among other considerations. Partner with Line of Business, Compliance, Risk and third parties to ensure all processes and procedures are in compliance with Fair Lending and UDAAP applicable policies and regulations. Acitvely participate in business unit meetings, committees, and providing support and guidance on with Fair Lending and UDAAP compliance and regulatory matters. Collaborate with other departments on implementation of any new or changed, laws, rules, regulations, and products or services related to Fair Lending and UDAAP. Review and appropriately challenge marketing collateral, strategies, and customer-facing documents to ensure compliance with applicable with Fair Lending and UDAAP regulations. Review and appropriately assess risk in escalated high-risk complaints related to a potential Fair Lending and/or UDAAP concern. Risk Awareness Manage and maintain enterprise-wide policies, standards, and procedures designed to achieve Fair Lending and UDAAP compliance with applicable laws, rules, and regulations. Participate in industry forums to understand and implement best practices as appropriate. Evaluate and advise on new/revised products and services from a with Fair Lending and UDAAP compliance risk perspective to assigned business units. Assist in leading corporate-wide implementation efforts of new or revised Fair Lending and UDAAP regulatory requirements. Testing, Audits and Exams Collaborate with Fair Lending and Responsible Banking Testing Team to define the appropriate scope of Fair Lending and UDAAP reviews by providing guidance regarding emerging risks and new or revised regulatory changes that may impact the business. Partner with business units to lead Fair Lending and UDAAP regulatory exams, internal and external audits, and enterprise-level reviews; manage audits and exams on a proactive project basis to ensure that responses submitted are appropriate and accurate and adequately address the request. Assist business units with responses, as necessary. Provides credible challenge to business line colleagues on components of the compliance risk and control environment related to Fair Lending and Responsible Banking, including HMDA and CRA. Read, analyze, and develop an in-depth understanding of the regulation to determine requirements/mandates. Training In partnership with the HR Talent Development department, advise business partners on special Fair Lending and UDAAP training needs and assist in the creation and revision of Fair Lending and UDAAP training materials and tools. In partnership with the HR Talent Development department, lead development, implementation, and monitor necessary Fair Lending and UDAAP training programs for the team and risk compliance liaisons to ensure they understand the Fair Lending and UDAAP Compliance Risk Framework and their responsibilities within the framework. Other duties as assigned.
Qualifications
Position Qualifications:
Bachelor's Degree from an accredited university in Business, Finance, or related field OR in lieu of a bachelor's degree, a High School Diploma or GED and 6 years of Risk Management or other related experience in the Financial Services Industry
6 years of experience in Fair Lending and/or UDAAP regulatory compliance or related Legal experience
5 years of experience in Financial Services industry
3 years of experience working with lines of business in interpreting and applying relevant Fair Lending and UDAAP rules, laws, and regulations to the business
Licenses & Certifications:
Certified Regulatory Compliance Manager (CRCM) preferred
About Comerica
We know our employees are critical to our overall success and we are dedicated to investing in their future. One of the ways we do this is to offer a comprehensive Total Rewards package designed to recognize and reward individual performance, as well support health, well-being, development and security for our colleagues and their family. Total Rewards consists of cash compensation, development and flexible benefit programs designed to meet individual needs today and in the future. Your salary will be commensurate with your work experience and our programs are reviewed regularly to ensure each remain competitive. We are proud to offer benefits such as health and welfare programs, strong retirement benefits, and generous paid time off programs. You and your eligible family members, including domestic partners and their children, can participate in medical, dental, and vision benefits, 401(k) and pension, income protection benefits such as life insurance, AD&D, and supplemental health programs to offset unexpected health care expenses. We also have a variety of time off programs for things like vacation, sick time, disability, and parental leave. Eligibility for some programs varies based on employment status and tenure.
Upon offer, Comerica conducts a comprehensive background and fingerprint check. Your fingerprints will be used to check the criminal history records of the FBI and may be subscribed in the FBI's Record of Arrest and Prosecution Background ("RAP Back") service, which provides ongoing notification to the Company of any updates to your criminal history.
NMLS certification requirement: where applicable, a favorable background check screening, credit check, fingerprint check, and NMLS certification is required in accordance with the SAFE Act.
Comerica Incorporated (NYSE: CMA) is a financial services company headquartered in Dallas, Texas, and strategically aligned into three major business segments; the Commercial Bank, the Retail Bank, and Wealth Management. Comerica's colleagues focus on relationships, and helping people and businesses be successful. In addition to Texas, Comerica Bank locations can be found in Arizona, California, Florida and Michigan, with select businesses operating in several other states, as well as in Canada and Mexico.
Comerica is proud to be an Equal Opportunity Employer-disability/veteran
