As part of Key’s second line of defense Compliance Risk Management function, the position has Compliance monitoring and testing responsibilities for all compliance aspects in the administration of Unfair, Deceptive, or abusive acts or practices (“UDAAP”). As a member of the Fair and Responsible Banking (“FARB”) team (within Compliance Risk Management [“CRM”], the incumbent will provide second line of defense testing and monitoring of UDAAP risks across Key, as well as of implementation of the UDAAP Program. CRM assesses and monitors UDAAP risks and serves as a UDAAP subject matter advisor to the first line of defense, the LOBs, and various support organizations that have UDAAP responsibilities and obligations. Specifically, this role will assist in the design and execution of testing and continuous monitoring to evaluate Key’s UDAAP compliance with regulatory requirements. Additional monitoring activities may include but not limited to assisting with the review and challenge of policies, procedures, training program content, issues management, implementation of regulatory changes, reporting routines (executive, regulatory, and governance committees), etc.
Moreover, partnering with the LOB while balancing the fiduciary oversight role are important to the Bank and, in certain situations, requires approval or denial on high-risk initiatives, products, third parties and clients. This role is expected to promote an organizational culture that encourages acknowledgement and recognition of compliance risks and places a high priority on risk management.
ESSENTIAL JOB FUNCTIONS
Serve on a team that provides an independent Second Line of Defense approach to oversee UDAAP risk-based monitoring and evaluation by independently assessing risks and issues; engage with the lines of business to help identify risks, assist with development and execution of assessments, provide input over controls and testing, advise on and monitor remediation activities.
Assists with developing a bank-wide approach to UDAAP risk management, which focuses on identifying, measuring, mitigating, monitoring, and reporting of UDAAP-related compliance.
Utilize data analysis tools and techniques to analyze, quantify, and/or assess UDAAP risks and to evaluate controls to identify potential weaknesses and/or control gaps.
Remain current on developments in applicable laws, rules, standards, guidelines, and industry best practices related to UDAAP compliance and overall UDAAP program administration.
Maintain a sound understanding of business strategy, business processes and associated risks with respect to business units who own UDAAP-related responsibilities.
Assist with monitoring and recommend improvements to business processes, which are necessary to meet regulatory changes and further mitigate UDAAP compliance risk exposure to Key.
Support the review and challenge of the new or revised policies procedures, processes, training program content, issues management, implementation of regulatory changes, executive and regulatory reporting routines, etc.
Provide information for analysis and reporting on UDAAP risks, including changes to risk profiles, risk metrics performance, control testing results, remediation plans and status, peer benchmarks, external events, and emerging risks.
Assist with supporting the LOB on UDAAP-related regulatory exam and internal audit activities.
Clearly document and communicate the results or conclusions from any UDAAP testing and monitoring performed and provide heightened awareness around significant risks and proactive identification, escalation, and remediation of control weaknesses or gap.
Develop and maintain strong, collaborative relationships with mid to senior level management, other internal clients and peers, and Audit.
Bachelor’s degree, CRCM a plus
3 to 5+ years of UDAAP Compliance experience with strong knowledge of applicable regulations, and a strong focus on risks and controls.
Knowledge of internal controls, risk assessments, and compliance testing and monitoring processes (including analytics), and applicable techniques for implementation of regulatory compliance requirements and compliance processes
Demonstrated skill in effectively communicating (verbal and written) results to a diverse audience; ability to work with all levels of management with a focus on collaboration and relationship management.
Ability to work closely with a diverse/cross-functional group and ability to work well in a team environment to achieve results
Strong critical thinking, detective, analytical, and problem-solving skills.
High ethical standards, strong critical thinking, detective, analytical, and problem-solving skills
Detail-oriented, with the ability to multi-task and work in a fast-paced, changing environment
Strong written and oral communications and interpersonal skills, ability to develop and maintain strong, collaborative relationships with all lines of defense.
Autonomous, self-motivated, and flexible with the ability to adapt quickly to change or shifting priorities in a fast-paced environment