SUMMARY OBJECTIVE:
The Compliance Officer is responsible for developing, implementing, and overseeing the institution's regulatory compliance program, with a primary focus on Community Reinvestment Act (CRA) and Home Mortgage Disclosure Act (HMDA) obligations. This role ensures the institution meets all applicable federal and state consumer protection and fair lending requirements, maintains accurate mortgage data reporting, and demonstrates a satisfactory record of serving the credit needs of its entire community, including low- and moderate-income individuals and geographies.
ESSENTIAL FUNCTIONS:
CRA Program Management
• Oversee the institution's CRA program in accordance with 12 CFR Part 345 (FDIC) and 12 CFR Part 228 (Federal Reserve)
• Monitor and evaluate the institution's CRA performance across lending, investment, and service tests
• Maintain and update the CRA Public File in accordance with regulatory requirements
• Delineate and review facility-based and retail lending assessment areas annually
• Coordinate community development lending, investment, and service activities to support CRA performance
• Track and document community development loans, investments, and services, including impact indicators such as support for persistent poverty counties, LMI individuals, MDIs, CDFIs, and affordable housing initiatives
• Prepare for and manage CRA examinations conducted by the appropriate federal banking regulator
• Monitor CRA ratings and ensure corrective action plans are in place for any "Needs to Improve" or "Substantial Noncompliance" findings
• Collect and report annual facility-based and retail lending assessment area data to the appropriate regulator by April 1 each year
HMDA Program Management
• Oversee the institution's HMDA compliance program in accordance with 12 CFR Part 1003 (Regulation C)
• Ensure accurate and timely collection, recording, and reporting of the Loan Application Register (LAR)
• Certify and submit the annual LAR to the appropriate federal agency by March 1 following each calendar year
• For institutions meeting the quarterly reporting threshold (60,000 covered loans/applications), ensure quarterly LAR submissions within 60 calendar days after each quarter-end
• Maintain LAR records for a minimum of three years following submission
• Ensure all required data fields are accurately captured, including Legal Entity Identifier (LEI), Federal Taxpayer Identification Number, and contact information
• Conduct periodic HMDA data integrity reviews and self-assessments to prevent inaccurate reporting
• Coordinate with mortgage lending staff to ensure proper data collection at the point of application
Fair Lending & Consumer Compliance
• Develop and maintain a fair lending compliance program to identify and mitigate potential disparities in lending practices
• Monitor lending patterns for potential ECOA, Fair Housing Act, and Regulation B compliance issues
• Conduct periodic fair lending risk assessments and file reviews
• Analyze HMDA data for potential disparate impact or disparate treatment concerns
• Coordinate with legal counsel and senior management on fair lending findings and remediation
Compliance Program Oversight
• Develop, implement, and maintain written compliance policies and procedures
• Conduct and coordinate compliance training for all applicable staff, including mortgage originators, underwriters, and community development personnel
• Perform compliance monitoring and testing across consumer protection regulations
• Prepare and present compliance reports to senior management and the Board of Directors
• Manage regulatory examination preparation and responses
• Track regulatory changes and assess their impact on institution operations and policies
• Serve as the primary point of contact for regulatory agencies on CRA and HMDA matters
Please note this job description is not designed to cover or contain a comprehensive listing of activities, duties or responsibilities that are required of the employee for this job. Duties, responsibilities, and activities may change at any time with or without notice.
SUPERVISORY RESPONSIBILITY:
This position requires no supervision of employees.
WORK ENVIRONMENT:
This job operates in a professional office environment. This role routinely uses standard office equipment such as computers, phones, photocopiers, filing cabinets and fax machines.
PHYSICAL DEMANDS:
The employee is frequently required to: 1) Type or otherwise work with fingers; 2) Talk expressing or exchanging ideas by means of the spoken word. Those activities in which they must convey detailed or important spoken instructions to other workers or clients accurately, loudly, or quickly; 3) Hearing – perceiving the nature of sounds at normal speaking levels with/without correction. Ability to receive detailed information through oral communication and make the discriminations in sound; 4) Specific vision abilities required by this job include: viewing a computer monitor; extensive reading.
Sedentary work may require occasionally lifting of up to 10 pounds and/or move up to 25 pounds. This work involves sitting most of the time with walking and sitting.
TRAVEL:
No travel is required for this position except for possible training and conferences.
COMPETENCIES:
1. Communication Proficiency
2. Strong Computer Skills
3. Analytical Skills
4. Deadline Oriented
5. Organizational Skills
6. Independent Judgment
7. Ethical Conduct
REQUIRED/ PREFERRED EDUCATION AND EXPERIENCE:
A bachelor’s degree with five (5) years of bank related experience is required. In lieu of a bachelor’s degree, a high school education/GED with eight (8) years of bank related experience. Banking experience in Compliance, Audit or Operations is preferred. Database program experience is required.