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VP/CRA & Fair Banking Officer

Golden Valley, MN, USA | MidWestOne Financial Group, Inc.

  • Industry:
    Banking / Investment Banking
  • Position Type:
  • Functions:
    Financial Services Professional
    General Management
  • Experience:
    7-10 years
Job Description:
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The CRA and Fair Banking Officer is responsible for the strategic leadership and management of MidWestOne Bank’s CRA, Fair Lending, Fair Banking and UDAAP risk programs. Successful management includes engagement of team members to achieve strategic goals and framework sufficient for the size and complexity of a growing organization. This position will support the Senior Compliance Officer- Compliance Management in the execution of the compliance management program (CMS) in all aspects of consumer harm, CRA, fair lending, fair banking laws and UDAAP regulations. This position will analyze trends and emerging risk and recommend corresponding mitigation solutions.


Key Responsibilities

Strategic leadership of programs including the following:

Regulatory change management

Emerging risk identification

Program development road map

Policy and procedure development and ongoing maintenance

Assessment area goals - monitoring, tracking and reporting

Recommend change to products, services, and delivery channel to ensure the Bank has products to service all customer demographics including Low-to-Moderate (“LMI”) and Majority Minority (“MM”) applicants and/or customers.

Coordinate and deliver program specific training

Committee leadership and sub-committee task force

Management and board reporting responsibilities

Maintain strong industry networking

Provide regulatory oversight and guidance for the Home Mortgage Disclosure Act (HMDA) and Community Reinvestment Act (CRA) data collection.

Manage and develop partnerships with organizations that serve various underserved groups, including but not limited to, LMI and MM throughout all the bank’s assessment areas.

New and existing vendor risk assessment

Analysis of program performance

Monitor and testing of program elements

Program software administration and development

Periodic risk assessment

Enterprise-wide performance context

Data analysis including

Regression analysis

Statistical correlation

Peer benchmarking

Demographic and geographic analysis

lending patterns, community development investments and community development services.

Branch strategy – acquisition, opening and closures

Analysis of products and processes

Change Management – product and pricing

Complaint analysis

Fairness analysis

Lead FL, CRA, HMDA and UDAAP audits and regulatory examinations, including advance preparation and follow up on findings and development of written responses.

Business-line Engagement

Communication of risk and needed action plans

Coordination of community outreach

Creation and consulting on AA plan development and action items

Marketing coverage - fair lending and CRA

Change Management - Coordinate with lending lines of business to evaluate proposed business changes, including new or modified products/services, new or modified policies, procedures, processes, or systems


General Requirements  

Bachelor's degree

8-10 years of experience with CRA and Fair Lending program development/management in a mid-size or larger bank examined under CRA large bank criteria or state or federal regulatory agency

Experience with multiple assessment area and multi-state CRA and Fair Lending program management

Experience in large bank CRA examination management with ability to independently supply documentation, evidence, and substantiation of CRA and Fair Lending activities to auditors, examiners, and bank employees.

Proven and progressive experience in financial services compliance, including direct accountability for CRA and Fair Lending compliance functions

Experience with a major metropolitan MSA within the CRA Assessment area, preferred

Certified Regulatory Compliance Manager (CRCM) or ability to obtain within 12 months of hire

Ability to travel - approximately 10%

Management experience preferred

Minimum Knowledge and Skills 

Working knowledge and analysis experience with CRA and/or fair lending software/RegTech solutions and regulatory requirements

Ability to manage and mitigate regulatory risk within the bank’s risk appetite.

Comprehensive understanding of Federal and state laws, regulations, and requirements pertaining to CRA, fair lending, UDAAP and consumer protection, including industry best practices

Knowledge of bank products and services with an emphasis on lending and underwriting requirements, specifically as it relates to LMI and MM individuals and neighborhoods.

Demonstrated ability to provide actionable intelligence to Sr. Management, Board of Directors and business line management to meet regulatory expectation while simultaneously meeting bank goals and objectives.

Extensive experience and familiarity with non-profit community development organizations and qualification factors for CRA.

Ability to think intuitively and strategically so that the department is enabled to anticipate, plan, and effectively execute to mitigate risk.

Ability to take decisive action and to motivate and develop others.

Must be able to evaluate and solve problems from multiple perspectives.

Advanced understanding of Fair Lending, CRA, and UDAAP regulatory guidance, expectations, and examination standards

Must be proactive in identifying potential concerns and have a sense of urgency in execution, remediation, follow-up, and final resolution.

High degree of self-motivation and ability to work independently

Attentive to deadlines and details. Ability to manage multiple complex projects simultaneously with effective delegation and time management.

Must have proven proficiency with Microsoft Office applications



Strong collaboration/cooperation skills. Ability to negotiate and collaborate with others, initiate action, adapt to change, make complex decisions, and accept challenging assignments. Responds appropriately to demanding situations and takes ownership of mistakes

Facilitation skills in both training and meeting environments.

Proven project management skills and experience leading cross-functional compliance initiatives.

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