Compliance Officer - CRA (Community Reinvestment Act) Oversight

Location:

For Those Who Work At Home - Various, Ohio 44144

JOB BRIEF

As part of Key’s second line of defense Compliance Risk Management function, the position has Compliance monitoring and testing responsibilities for all compliance aspects in the administration of KeyBank’s goals and objectives related to the Community Reinvestment Act (“CRA”) and Dodd-Frank Act Section 1071 Small Business Lending.  As a member of the Fair and Responsible Banking (“FARB”) team (within Compliance Risk Management [“CRM”], the incumbent will provide second line of defense testing and monitoring of CRA/1071 risks across Key, as well as of the CRA Policy/FARB Policy and its implementation of the CRA Program/FARB Program.  CRM assesses and monitors CRA/FARB risks and serves as a CRA/FARB subject matter advisor to the the first line of defense, the LOBs, and various support organizations that have CRA/FARB responsibilities and obligations. Specifically, this role will assist in the design and execution of testing and continuous monitoring to evaluate Key’s CRA/1071 compliance with regulatory requirements including assurance with respect to the accuracy of Key’s CRA/1071 regulatory reporting data.  Additional monitoring activities may include but not limited to assisting with the review and challenge of policies, procedures, training program content, issues management, implementation of regulatory changes, reporting routines (executive, regulatory, and governance committees), etc.

This role is expected to promote an organizational culture that encourages acknowledgement and recognition of compliance risks and places a high priority on risk management. The role will report directly to the FARB Compliance Director – CRA Oversight and 1071 Implementation, who reports to the FARB Compliance Executive. 

ESSENTIAL JOB FUNCTIONS

• Serve on a team that provides an independent Second Line of Defense approach to oversee CRA/FARB risk-based monitoring and evaluation by independently assessing risks and issues; engage with the lines of business (Corporate Center and various specific LOBs) to help identify risks, assist with development and execution of assessments, provide input over controls and testing, advise on and monitor remediation activities.
• Assists with developing a bank-wide approach to CRA/FARB risk management, which focuses on identifying, measuring, mitigating, monitoring, and reporting of CRA/FARB-related compliance risks.  Assist with conducting Second Line of Defense “review and challenge” activities and escalation, employing independent testing, as appropriate.
• Utilize data analysis tools and techniques to analyze, quantify, and/or assess CRA/FARB risks and to evaluate controls to identify potential weaknesses and/or control gaps.
• Remain current on developments in applicable laws, rules, standards, guidelines, and industry best practices related to CRA/FARB compliance and overall CRA/FARB program administration.
• Maintain a sound understanding of business strategy, business processes and associated risks with respect to business units who own CRA/FARB-related responsibilities.
• Assist with monitoring and recommend improvements to business processes, which are necessary to meet regulatory changes and further mitigate CRA/FARB compliance risk exposure to Key.
• Support the review and challenge of the new or revised policies procedures, processes, training program content, issues management, implementation of regulatory changes, executive and regulatory reporting routines, etc.
• Provide information for analysis and reporting on CRA/FARB risks, including changes to risk profiles, risk metrics performance, control testing results, remediation plans and status, peer benchmarks, external events, and emerging risks.
• Assist with supporting the LOB on CRA/FARB-related regulatory exam and internal audit activities.
• Clearly document and communicate the results or conclusions from any CRA/FARB testing and monitoring performed and provide heightened awareness around significant risks and proactive identification, escalation, and remediation of control weaknesses or gap.
• Develop and maintain strong, collaborative relationships with mid to senior level management, other internal clients and peers, and Audit.

REQUIRED QUALIFICATIONS

• Bachelor’s Degree required
• 3 to 5+ years of CRA and/or FARB Compliance Program administration or Compliance experience with strong knowledge of applicable regulations, and a strong focus on risks and controls.
• Knowledge of internal controls, risk assessments, and compliance testing and monitoring processes (including analytics), and applicable techniques for implementation of regulatory compliance requirements and compliance processes.
• Demonstrated skill in