Grand Bank - Fair and Responsible Banking Officer

About the role

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.

Essential Duties and Responsibilities

• 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
• 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
• Provide oversight of credit card marketing, prescreen, and solicitation practices for compliance with fair lending and UDAAP expectations
• Oversee 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
• 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
• Aid 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

• 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
• Prior interaction with OCC or FDIC examinations; familiarity with CFPB rulemaking, enforcement actions, and supervisory priorities
• 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
• Strong knowledge of Fair Lending laws (ECOA/Reg B, HMDA), UDAAP, Regulation E, and applicable regulatory guidance
• 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 integrity, professionalism, and attention to detail