VP, Associate General Counsel, First Command Bank

How will this role impact First Command?

The VP, Associate General Counsel – Banking of First Command Bank (FCB) is the Bank’s legal leader and advisor on complex operational banking, regulatory, and litigation matters. This role safeguards the legal and regulatory interest of a $1 billion subsidiary of First Command Financial Services (FCFS) and enables safe growth by providing practical, solutions‑oriented counsel aligned with FCB’s strategy, risk appetite, and regulator expectations.   

This position requires deep legal and banking regulatory expertise, along with strong collaborative leadership to effectively manage FCB’s legal functions. As a strategic partner to Bank leadership, the Chief Legal Officer, and the Board, the Associate General Counsel advances FCB’s strategic objectives by supporting compliance, strengthening risk management, and enabling stable, responsible growth, all in alignment with the broader objectives of FCFS.

What will you do in this role?

Leadership & Strategic Advisory

• Serve as the Bank’s primary legal advisor on complex banking, regulatory, and enforcement matters.
• Exemplify collaborative business partnership by providing proactive business-forward legal guidance, aligned with business strategy, risk appetite, and regulatory expectations.
• Partner with the Chief Legal Officer to align legal advice on banking matters with enterprise risk appetite and governance expectations.
• Support board and committee matters related to banking and regulatory issues, as requested.

Regulatory & Banking Law Oversight

• Develop and execute legal strategy for banking regulatory matters, including examinations, inquiries, supervisory issues, and potential enforcement actions involving federal and state regulators. This role is expected to remain directly involved in regulatory strategy, written submissions, and regulator-facing and board-facing communications.
•  Interpret and apply  federal and state banking laws and regulations including consumer protection and commercial requirements, to ensure full alignment between legal requirements, operational practices, and business objectives.
• Monitor emerging regulatory developments and assess potential impact to the Bank; advise leadership on required changes and strategic implications.
• Maintain productive relationships with regulators, external counsel, and industry peers.

Legal Risk Management & Complex Matters

• Serve as the accountable legal owner for significant banking-related disputes, regulatory proceedings, investigations and pre-litigation strategy.
• Direct outside counsel strategy, , budget, fee structures, and quality of  work.
• Lead early dispute resolution and risk mitigation efforts to minimize legal exposure and business disruption.
• Issue and oversee legal opinions, escalation frameworks, and risk assessments for material transactions and initiatives.

Commercial, Contractual & Operational Support

• Negotiate, draft, and approve complex and high-impact contracts, disclosures, policies, and procedures supporting banking operations and strategic initiatives.
• Advise on legal aspects of product development, key vendor relationships, information security, privacy, and other matters directly impacting regulated banking activities.
• Ensure legal frameworks support scalable growth while maintaining compliance and sound risk controls. 

Influence, Mentorship & Collaboration\

• Provide informal mentorship and subject-matter guidance to attorneys and compliance professionals on banking-related issues.
• Act as a thought leader and escalation point for complex legal questions.
• Collaborate with Legal, Compliance, Risk, and Business partners without formal supervisory responsibility.

External Engagement & Industry Leadership

• Represent the Company in industry associations, working groups, and regulatory forums, providing insight into legal and regulatory trends impacting the Bank.
• Benchmark practices against peer institutions and recommend enhancements to policies, controls, and governance structures.

Supervisory/Leadership Responsibility

• Exercise significant influence through expertise, judgment, and collaboration. May provide project-based direction to internal teams and outside counsel.
• Foster a culture of ethical conduct, sound judgment, and risk awareness across the organization.

 What skills and qualifications for you need? 

Education

• Bachelor’s degree from a four-year college or university (required)
• Juris Doctorate from an ABA Accredited Law School (required) 

Work Experience

• Minimum of ten (10) years of progressively responsible legal experience, with significant focus on banking law, regulatory matters, litigation, and general corporate practice.
• Demonstrated experience serving as a senior legal advisor and collaborative partner on highly complex, high-risk matters.
• Proven track record handling highly complex, sensitive, and high-risk matters within a regulated financial institution or comparable environment.
• Experience operating as a senior individual contributor with substantial autonomy and accountability. 

Certifications

• Active license and good standing with the State Bar of Texas (preferred) or any U.S. state bar (required) 

Required Knowledge, Skills and Abilities

• Exceptional written and verbal communication skills, including the ability to translate complex legal issues into clear business guidance.
• Thorough understanding of banking regulatory frameworks and compliance requirements for national banks.
• Advanced legal research, analytical, and judgment capabilities.
• Strong executive presence with the ability to influence, advise, and challenge senior leaders constructively.
• Demonstrated leadership, mentoring, and people-management skills.
• Ability to operate effectively in a fast-paced, highly regulated environment with minimal supervision.
• Strong interpersonal skills and the ability to adapt communication style to diverse internal and external stakeholders.

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