The Enterprise Area of Coverage (EAC) Compliance and Operational Risk (C∨) Executive leads a team of subject matter experts on specific processes, controls, laws, rules and/or regulations that have enterprise-wide applicability, affecting two or more Front Line Units ("FLU") or Control Functions ("CF"). This role is responsible for the planning and execution of the Compliance and Operational Risk Programs ("CORM Program"), the Global Compliance Enterprise Policy ("GC Policy") and the Operational Risk Management - Enterprise Policy ("ORM Policy") for these enterprise areas of coverage (examples include Third Party, Privacy, Reg W). Using the results from the execution of these policies, this role is responsible for the second line's point of view on the enterprise's risk management practices for their area of coverage.
The EAC C∨ Executive provides strategic direction, planning and inspection of an EAC C∨ team or group of teams who are responsible for identifying, escalating and mitigating risks in a timely manner in alignment with the CRM and ORM Programs and the GC and ORM Policies. This role ensures there is consistent, proactive engagement with the FLU/CF leaders globally, working with and through the FLU/CF compliance and operational risk (C∨) officer teams to independently advise those leaders on effectively managing the operational and compliance risks related to their area of coverage. Additionally, as an expert in a specific area of coverage, the EAC C∨ Executive conducts external benchmarking, participates in industry forums and innovates on emerging trends or topics related to their area of coverage.
The EAC C∨ Executive exercises judgment, influences and constructively challenges the FLU and CF leaders with and through the C∨ officers, providing timely advice regarding regulatory requirements and expectations, and the implementation of controls to effectively mitigate Compliance and Operational Risk. Where there are centrally managed governance functions in place, the EAC Compliance and Operational Risk Executive has relationship management responsibilities, including additional reporting and communication to/with those leaders about the status of Compliance and Operational Risk management for that particular EAC. The EAC C∨ Executive is responsible for identifying and recommending standard process, control and risk definitions for like-processes related to the EAC and influences adoption enterprise-wide.
The EAC C∨ Executive is accountable for the requirements in the GC and ORM Policies, working with FLU/CF C∨ officers to complete those requirements for their areas of coverage including but not limited to the following activities:
* Create and own a global coverage plan which defines the scope and focus of the second line's risk management activities. * Set, monitor and report on enterprise risk tolerance metric(s) that are translated and connected to relevant business metrics (Key Risk Indicators). * Monitor regulatory environment in EAC and participate in industry forums to identify areas of focus and conduct benchmarking. * Create and maintain a regulatory inventory, communicate regulatory changes to and engage the FLU/CF in assessing impacts of regulatory changes. * Develop and maintain relevant compliance and operational risk policies or review relevant FLU / CF policies to ensure they reflect regulatory and operational risk requirements. * Advise and direct business leaders through the FLU/CF compliance and operational risk teams to ensure that regulatory requirements and operational risks are addressed in their respective procedures and controls so that their daily activities operate in a compliant manner. * Verify scope, frequency and integrity of the FLU/CF quality assurance activities to ensure effective ongoing inspection by the FLUs/CFs. * Apply judgment and experience to determine monitoring and testing coverage plans and related metrics. * Monitor business processes, controls, and metrics, open issues and control enhancements to drive remediation of control weaknesses by the FLU/CF. * Test the effectiveness of the FLU / CF compliance and operational risk controls. * Review and analyze internal and external losses related to their area of coverage for enterprise-wide themes; escalate concerns or loss exposures as appropriate. * Review scope and coverage of Key Risk Indicators ("KRIs") and confirm action is taken to escalate or resolve issues. * Identify, aggregate, report and escalate risks, issues and control enhancements and ensure the FLU/CF C∨ officers are aware of issues. * Identify regulatory training needs, provide subject matter expertise to support development of training curriculum, and inspect FLU/CF * Advise Risk peers and business leaders in preparations for and participation in regulatory exams and audits. Prepare and participate in EAC-specific exams and audits. * Inspect that gap closure plans and commitments made regarding actions in response to Matters Requiring Attention ("MRAs") and other actions are completed. * Plans and executes governance and management routines. * Escalate regulatory relations concerns to Regulatory Relations. * Ensure Compliance and Operational Risk "owned" issues (i.e., Internal Audit, Regulator and Self-Identified issues) are addressed appropriately and timely.
The EAC Compliance and Operational Risk Executive ensures consistent quality of activities, processes and outputs by establishing effective review of practices across the team. This role provides leadership direction to attract, assess, develop, motivate and retain a successful team. In rare instances, this role may be an individual contributor. Responsibilities include: * Serving as a subject-matter expert on fair lending. Maintaining a current and relevant knowledge of the rapidly changing fair lending environment and emerging risk areas. Applying expertise to evaluate the fair lending risk in programs, practices or business decisions, recommend best practices to mitigate risk, and provide real-time advice to the businesses and other stakeholders. * Developing and maintaining a thorough understanding of subject businesses - products, processes, internal controls, and gap identification. * Providing fair lending oversight for high risk businesses, including ongoing direction and support. This includes fair lending monitoring and statistical testing activities, annual comprehensive risk assessments, and quarterly risk reports. * Serving on senior management governance and other forums and advising on fair lending risk associated with business strategies and initiatives, statistical models, marketing campaigns, business processes and the internal control structure. * Working with businesses, Risk, Legal and Compliance partners to identify and promptly remediate fair lending risks, and issues, including escalating issues as necessary. * Cultivating strong partnerships with FLU and Legal stakeholders across the Company and collaborating effectively to execute fair lending responsibilities. Earning credibility and respect as a "go to" resource. * Serving in a Fair Lending exam management role by responding to regulatory requests and serving as a point of contact with regulatory agencies on fair lending matters. * Developing content and overseeing execution of enterprise web-based fair lending training and video training programs. * Designing and leading special fair lending projects including horizontal reviews to identify and mitigate risk * Developing, mentoring and supervising junior Fair Lending Team members. Required Skills: * Bachelor's Degree required, advanced degree or experience in accounting/auditing desired * 5+ years broad fair lending experience at a large bank or professional services firm across multiple consumer and business credit products:
Up-to-Date Fair Lending and Business Knowledge - thorough and current knowledge of fair lending requirements (laws, rules, regulations, regulatory guidance and best practices), anti-discrimination principles and enforcement actions since the 1990s that have established fair lending requirements/expectations over the past 20 years and continue to rapidly evolve
Ability to swiftly interpret and apply concepts in LRRs and past enforcement actions to business strategies and proposals
Strong mathematical aptitude and aptitude for statistical concepts including statistical modeling, regression analysis and database management, all of which are required to measure fair lending compliance.
Deep knowledge of mortgage, credit card, indirect auto, small business and commercial and wealth management products and operations.
* Success as a leader and manager of people including talent development and driving employee satisfaction. Track record of success in leadership including establishing a vision, setting direction, inspecting work product of the group along the way, and delivering superior work products. * Communications - Strong written and verbal communication skills, presentation skills, and ability to confidently interact with and influence senior executives including senior executive and board level committees. * Management/Consulting - influencing effectively in a matrixed organization, rapidly and accurately advising management on complex matters, acting with courage and conviction in contentious situations, superior organizational and project management skills, prioritizing and managing monitoring and testing plans, bank and departmental initiatives, working independently, and supervising junior staff members. * Risk Management - Ability to quickly and thoroughly understand business processes within each phase of the credit lifecycle (marketing and solicitation, application and origination, account maintenance, and loss mitigation), identify potential fair lending risks and mitigating internal controls, and identifying any gaps. Establishing the fair lending risk framework including risk assessments and determining scope of the nature, timing and extent of fair lending testing commensurate to the level of risk. Proficiency in developing and presenting crisp fair lending risk assessments for business executives, enabling them to make informed decisions about risk on specific initiatives. * Regulatory Examinations - experience with interactions with regulators in fair lending exams
1st shift (United States of America)
Hours Per Week:
Internal Number: 21013356
About Bank of America
Bank of America is one of the world’s leading financial institutions, serving individual consumers, small and middle-market businesses, and large corporations with a full range of banking, investing, asset management and other financial and risk management products and services. The company offers industry-leading support to approximately 3 million small business households through a suite of innovative, easy-to-use online products and services. Bank of America is a global leader in wealth management, corporate and investment banking and trading across a broad range of asset classes, serving corporations, governments, institutions and individuals around the world.