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Compliance Support and Consumer Advocacy Manager ("CSCAM")
Salt Lake City, UT
WebBank (the "Bank") is headquartered in Salt Lake City, Utah, and is an FDIC-insured, state-chartered industrial bank that provides customized consumer and commercial financing solutions on a nationwide basis.
Strategic Partner Business
WebBank (the "Bank") is a leading provider of national consumer and commercial private-label and bank card financing programs. The Bank works closely with Strategic Partners ("SP's") to design, develop, implement, administer and fund customized consumer and/or commercial financing program(s). The SP's are vendor clients that administer Bank programs on behalf of the Bank with a range of product offerings that include:
- Closed-end Installment Loans (Consumer & Commercial)
- Revolving charge (Consumer & Commercial)
- Private-Label / Co-Brand / Dual-Line Cards (Consumer & Commercial)
- General Purpose Credit (Consumer & Commercial)
- Small Business Programs
The Bank has an established Strategic Partnership Group with dedicated Program Managers focused on all aspects of Strategic Partner program oversight, management and risk mitigation. Similarly the Bank's Compliance Department has Strategic Partner Compliance Managers ("SPCM's") that are dedicated to overseeing and managing the compliance controls and risk mitigation strategies in place at assigned Strategic Partner programs. Working collaboratively the Strategic Partnership Group, the Compliance Department and Bank management ensure that Strategic Partner Programs are in full compliance with federal and state lending regulations as well as all WebBank credit requirements.
Job Description Summary
The Compliance Support and Consumer Advocacy Manager ("CSCAM") will report to the V.P. Compliance. The CSCAM will be engaged in a variety of vendor management and compliance support activities with a primary focus on ensuring program fairness and customer satisfaction. The CSCAM will evaluate all program offerings with a particular focus towards considering a customer's perspective of these offerings. The CSCAM will seek to determine not only whether programs are capably designed and appropriately administered but will also evaluate programs for weaknesses that may result in customer complaints or dissatisfaction. The CSCAM will evaluate the nature and structure of product offerings and consider factors that could potentially increase the risks of unfair, deceptive, abusive acts or practices ("UDAAP"), or discrimination. The CSCAM in collaboration with the V.P. Compliance, SPCM's and Program Managers will evaluate complaints, analyze root cause issues and develop strategies to enhance program offerings and reduce or eliminate related complaints. The CSCAM will also evaluate testing, monitoring and site visit findings in order to identify potential issues. The CSCAM will collaborate with Compliance Department staff and outside Counsel to ensure program offerings are in full compliance with federal and state regulations as well as all WebBank requirements. The CSCAM will evaluate customer satisfaction surveys, marketing methods, advertising, compensation practices and sales practices to determine whether any of these areas pose potential UDAAP risk. The CSCAM will address identified risks with management and collaborate to minimize or eliminate identified risk.The CSCAM will also professionally and effectively communicate with customers, external clients, internal clients and others as directed by the V.P. Compliance.
- Review, assess, summarize and distribute SP work product pertaining to customer satisfaction on a periodic basis. This work product may include but will not be limited to such items as complaint reports, customer satisfaction surveys, fulfillment reviews and program enhancements designed to improve the customer experiences.
- Examine processes and quality measures at each Strategic Partnership that are designed to assure customer satisfaction. This may include evaluation of such areas as customer service staffing adequacy, customer information services capacity, sales compensation practices, call monitoring processes, internal procedures, quality control processes, etc.
- Based upon processes and quality measures in place at Strategic Partners and based upon industry best practices evaluate and recommend opportunities for enhancing the customer experience across programs.
- As necessary and under the direction of the V.P. Compliance, develop responses to complaints that come through various channels, including the Better Business Bureau, direct from consumers, the FDIC, etc.
- Evaluate FDIC Financial Institution Letters ("FIL's") as they become available. Distribute FIL's as applicable and maintain FIL log.
- Assist V.P. Compliance in subpoena handling.
- Evaluate all Strategic Partner Risk Assessments and collaborate with SPCM's, Program Managers and others to assist in completing the assessments.
- Key participant in the development and performance of a UDAAP risk assessment.
- Complete monthly legal action search and provide report on same as directed by V.P. Compliance.
- Contribute relevant input to Chief Compliance Officer each month for inclusion in Monthly Compliance Report to WebBank Board of Directors.
- Review all Strategic Partner marketing material to ensure clarity, transparency and regulatory compliance.
- Collaborate closely with all SPCM's and Program Managers. Identify best practices as well as concerns related to SP Programs. Communicate these practices and concerns to all and work with the Compliance Department to effectuate positive and consistent changes as applicable.
- Stay abreast of federal and state regulatory changes that may impact the Bank. Ensure those changes are communicated to and addressed by company management and consider the intended impact to the consumer which may or may not extend beyond the technical requirements.
- Provide assistance in addressing internal and external audit findings that relate to credit and/or compliance activity and help prepare responses as requested.
- Participate with Compliance Department, Credit Department and SP Group to evaluate loss mitigation, recovery management and customer servicing strategies. Ensure strategies meet regulatory and compliance expectations.
- Complete all mandatory compliance training within prescribed timeframes. Work closely with retained legal counsel and compliance personnel to interpret new and existing laws and regulations that impact SP credit and compliance processes. Communicate those interpretations to applicable personnel.
- Perform site visit reviews of Strategic Partner Programs with a primary focus on customer complaints and customer satisfaction efforts. Must be willing to travel at least one week per month.
- Bachelors degree and minimum of 5 years of consumer credit/compliance experience or alternately a minimum of 7 years of consumer credit/compliance experience.
- Strong working knowledge of consumer compliance requirements. CRCM preferred.
- Must have prior bank or financial services compliance experience. Customer service experience or customer service management experience highly desired.
- Direct experience dealing with regulators (FDIC, Utah Department of Financial Institutions) is highly desired.
- Strong background in federal and state lending laws.
- Excellent ability to analyze and interpret state and federal regulations.
- Strong self-confidence, good judgment and the ability to make sound decisions.
- Must interface effectively with other departments.
- Ability to handle a fast paced environment with minimum supervision and successfully meet established project deadline requirements.
- Strong problem solver.
- Outstanding initiative, communication skills (verbal and written), attention to detail and organizational skills required.
If you would like to apply for this position, please send your resume to: email@example.com