Loan Compliance/CRA Project Manager - Cogent Bank

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Loan Compliance/CRA Project Manager

Job Summary

The Loan Compliance/CRA Project Manager will work directly with the Bank’s CRA Officer administering all aspects of the Community Reinvestment Act Compliance Program. This position will support the CRA Officer in developing and implementing programs to ensure the Bank meets the needs of the community and attains CRA compliance goals, along with participating and maintaining relationships with community-based, charitable, housing, and non-profit organizations. This position will work as part of the team supporting the bank in mitigating compliance risk, specifically in fair lending, and performs a variety of duties with respect to loan compliance at the direction of the Chief Compliance Officer.   

Responsibilities and Duties

  • Managing the operational aspects of Cogent Bank’s CRA Program, which includes data collection, validation, compilation and analysis of the Bank’s CRA Lending, Investment and Community Services data.  In addition, this role is responsible for performing various routine and ad hoc analyses
  • Providing regulatory support and guidance pertaining to HMDA and CRA to Corporate Compliance, Consumer Banking, Commercial Banking, etc. and interfaces with senior and business line leaders.
  • Continuously updating and maintaining the Bank’s CRA Public File [regulatory requirement] including the branch notices. 
  • Monthly/Quarterly Reporting of CRA Lending activities include HMDA (when applicable), Small Business (CRA) and Community Development (CD) Loans which require monthly and quarterly data imports to CRA Wiz; producing monthly Edit Reports for the Lines of Business or Market Leaders to verify and/or correct their data; periodic performance reporting and regulatory submissions (when applicable).
  • Community Services include collecting, qualifying and maintaining a record of CD Volunteer Service Hours (bank employee/board/committee memberships) and CD Educational Activities.
  • Identifying and maintaining a record of Community Development Loans and supporting documentation
  • CRA Data Validation: Test for Community Development Lending, Small Business Loans, Geographic Distribution of loans, In/Out Ratio, provide details for quarterly CMS reports.
  • Preparing, assisting and participating in regulatory examinations and audits • Responsible for managing Annual Regulatory HMDA and CRA Submissions
  • Specific responsibilities and duties with respect to Loan Compliance include:
    • Thorough understanding of Loan Compliance Regulations: REG B, Fair Lending, Flood, UDAAP, REG Z, RESPA
    • Perform analysis of both originated and non-originated loans for fair lending concerns; prepare summary report of findings
    • Perform ongoing second reviews of denied applications for completeness, accuracy, and appropriateness;
    • HMDA LAR Review prepare filing annually when the bank reaches regulatory thresholds.
    • Implement CRA tracking program to analyze Bank’s performance for CRA.
    • Stay abreast of regulatory changes, focusing on being proactive to upcoming changes and assisting in communicating changes to lending staff.
    • Develop and maintain fair banking training materials for appropriate employees and job functions as necessary. Fair banking training would include fair lending laws and regulations and guidance for mitigating engaging in unfair and deceptive practices;
    • Prepare periodic fair lending reports for senior management, and the Board of Directors that includes significant fair banking developments, fair banking risk monitoring and testing results, and fair banking key risk indicators;
    • Assist in keeping policies and procedures up to date with changes and organized.
    • Assist in updating the fair lending risk assessment, including design and execution of launching or updating products and services;
    • Assist in the review of flood approvals to ensure proper coverage.
  • All other tasks, responsibilities or duties, as directed by management.

Qualifications and Skills

  • Candidate with advanced degrees (Bachelor’s, and/or Master’s) preferred; High School diploma or GED is required. Candidates with some combination of coursework and experience, or extensive related professional experience (minimum 5 years in related field), are eligible for consideration.
  • Strong regulatory knowledge and experience with CRA, HMDA, and Fair Lending, and understanding of loan related regulations
  • Experience with Wolters Kluwer CRA and Fair Lending, as well as Excel software
  • Excellent analytical, investigative, and mathematical skills with attention to detail and concern for data accuracy
  • Ability to meet deadlines and juggle multiple assignments
  • Impeccable attention to detail, strong organizational and analytical skills
  • Professional demeanor and strong interpersonal skills
  • Self-starter and independent thinker

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Cogent Bank is an Equal Opportunity Employer.