Senior CRA and Fair Lending Analyst

How will this role impact First Command?

The FCB’s (“Bank”) Senior CRA and Fair Lending Analyst (“ Sr. Analyst”) is responsible for supporting and strengthening the Bank’s Community Reinvestment Act (CRA) and Fair Lending Compliance Programs through effective implementation, monitoring, analysis, and administration of all program components. This role ensures the Bank maintains compliance with applicable federal and state laws and regulations, and that appropriate monitoring controls are in place across all lines of business.

The Sr. Analyst will be responsible for supporting the Bank’s Community Reinvestment Act and Fair Lending Compliance Programs (“Program”) by implementation, monitoring and administration of all aspects of these Programs. This includes evaluating processes and controls, conduct analytical reviews, maintain documentation and workpapers, collaborate with stakeholders at all levels, and present findings and recommendations to management. Work performed in close partnership and oversight of the SVP, Bank Compliance Officer prior to distribution to senior leadership or other stakeholders. Additional responsibilities within the broader Compliance Program may be assigned by the SVP, Bank Compliance.

What will the employee do in this role?

• Assist and support the SVP of Bank Compliance in overseeing the Bank’s CRA, Fair Lending, and Responsible Banking Compliance Programs.
• Lead the monitoring activities to ensure compliance with CRA, Fair Lending, Responsible Banking functions with applicable laws and regulations and adherence policies and procedures across all business lines.
• Keep senior management continuously informed of Program performance relating to risk management activities and relative risk exposure.
• Analyze and communicate regulatory changes impacting the Bank’s CRA and Fair Lending Programs and communicate implications to the SVP, Bank Compliance Officer including policies, procedures, new and existing products.
• Serve as a subject matter expert (SME) and advisor to lending business lines; research issues and ensure consistent guidance across stakeholders. In addition, socialize business lines inquiries (in coordination with the SVP).
• Perform automated and manual Fair Lending data analytics to identify disparities, trends, or patterns of concern in underwriting, pricing, redlining, or steering.
• Perform Fair Lending file analysis, denial trend reviews (consumer, commercial, credit cards, mortgage broker), credit (loans and credit cards) exception analysis, and other monitoring activities.
• Maintain supporting documentation and lead enhancements in data testing and validating strategies, methodologies, and best practices.
• Prepare monthly, quarterly, semiannual Fair Lending reporting designed to identify trends and/or pattern of concern and escalate to Senior Management for further investigation.
• Perform CRA data analytics (automated or manual) of lending data to evaluate CRA performance and support ongoing monitoring.
• Maintain CRA and Fair Lending data integrity with a high degree of accuracy; oversee tracking and reporting within the RATA system.
• Ensure accuracy of generating data files, reports, and presentation materials for Senior Management, internal audit, and bank regulators.
• Identify and document small business loans subject to CRA reporting including maintaining documentation.
• Analyze, document, and maintain records of community development loans, services, investments, and volunteer hours.
• Maintain and update the Bank’s CRA Public File.
• Prepare and maintain the annual CRA Self‑Assessment and Fair Lending Risk Assessment with a high degree of accuracy, including trend and pattern analysis for Senior Management escalation.
• Prepare accurate data files, reports, dashboards, and presentation materials for Senior Management, Internal Audit, and regulators.
• Monitor loan origination volume for HMDA‑triggering events.
• Assist and maintain CRA, Fair Lending and related Compliance policies and procedures.
• Prepare reports with a high degree of accuracy related to CRA, Fair Lending, and Responsible Banking activities for the SVP, Bank Compliance Officer.
• Monitor the Bank’s loan originations volume for HMDA triggering events.
• Serve as administration for RATA and ABA Online Training including scheduling and monitoring annual employee training.
• Maintain the Bank’s Complaint tracking partnering with the Quality Management Team; analyze complaints for regulatory trends or patterns requiring escalation to the SVP, Bank Compliance Officer. In addition, present complaint trends to the Compliance Committee.
• Serve as member of the Force for Good Committee promoting community development for CRA eligibility.
• Assist with internal audit or exam request items.
• Support other compliance initiatives and projects as assigned by the SVP, Bank Compliance Officer. 
• Administer and present Programs results to Bank’s Compliance Committee and Fair Lending Meetings.

Authorities

Information Access – CRA and Fair Lending Compliance Officer has authority to access, monitor and report on sensitive Bank, customer, transaction, and employee information related to the position’s duties to ensure compliance with regulatory requirements.

Cross Functional Relationships

Internal:

• VP Compliance and Fiduciary Quality and Control 
• BSA-AML Compliance Officer
• Consumer and Professional Lending Line of Business Management including Senior Leadership
• Technology (Business Analyst)

External:

• Regulatory Agencies
• Compliance professionals at financial institutions with a view to understanding the competitive landscape, keeping abreast of compliance developments, industry developments, and new products.
• Industry associations

Skills & Qualifications

Education

• Bachelor’s degree required; equivalent experience may be considered.

Work Experience

• 3 to 5 years' CRA and Fair Lending compliance banking, or other related compliance experience preferred 
• Banking software (Jack Henry, Laser Pro, Mark IV, Loan Orginating System, and Cognos) experience preferred 
• Strong knowledge of regulatory requirements
• CRA and Fair Lending Software (Rata, CenTrax, or CRA Wiz) administration experience preferred 

Certifications 

• Relevant certification CRCM preferred

Required Knowledge, Skills, and Abilities

• Excel proficiency highly desirable; reviews frequently require independently obtaining data from various systems, selecting stratified samples for detail review, and then leveraging formulas.
• Word and Power Point proficiency required.
• Must be detail-oriented and possess strong communication and organizational skills.
• Demonstrate knowledge and understanding of the required elements of a CRA and Fair Lending compliance program.

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