Title:CRA and Fair Lending Officer Department:Compliance DepartmentFLSA Status: ExemptReports to:First Vice President & Director of ComplianceGeneral Summary: This position is responsible for developing, administering and monitoring the Community Reinvestment Act (CRA) and Fair Lending programs to ensures the Bank’s compliance with all applicable CRA and fair lending laws, regulations and rules. Essential Duties and Job Responsibilities:1.Manage the oversight and enhancement of the CRA and Fair Lending Programs serving as the subject matter expert across all lines of business.2.Implement policies, procedures, and practices to ensure adherence to CRA and Fair Lending rules and regulations.3.Complete an annual review of the Bank's assessment area to ensure reasonableness of the delineation. 4.Update CRA Public File annually by April 1st. 5.Participate in and contribute to the Compliance Committee meetings.6.Ensure CRA qualified investments and donations, HMDA, small business and farm loans, flexible lending programs, community development loans and employee volunteer hours are appropriately documented for reporting. 7.Keeping abreast of emerging CRA issues and regulatory perspectives.8.Develop and coordinate CRA and fair lending training to bank staff.9.Maintenance and management of CRA recording/reporting systems.10.Prepare the Bank’s CRA Self-Assessment.11.Ongoing monitoring of and reporting on the bank’s CRA performance and compliance standing.12.Manage exam and audit requests, and interactions with state and federal examiners for CRA and Fair Lending exams. Handle first day letters, item requests and all interaction with auditors and examiners in the loan area.13.Accountable for ensuring the data integrity of CRA data for regulatory filing, including, but not limited to scrubbing sample loan files and/or setting up tools for validity and edit checks. 14.Manage exam and audit requests, and interactions with state and federal examiners on CRA and Fair Lending examinations. Handle first day letters, item requests and all interaction with auditors and examiners in the loan area. 15.Assess and investigate fair lending risks posed by business unit’s data and residual compliance risk and document findings related to vulnerabilities. Create action plans with appropriate measures to lower residual risk to an acceptable level. Present the Fair Lending Risk Assessment the Audit and Risk Committee.16.Manage the Bank’s HMDA, CRA, and Fair Lending Risk Management software vendor.17.Reviews and tracks all adverse action files including declinations and withdrawals for Fair Lending purposes including LMI information, census track data and ethnicity composition.Miscellaneous1.Assist the Compliance Department with ensuring the Bank’s compliance with all applicable federal and New York state laws, regulations and rules.OTHER RESPONSIBILITIES1.Other responsibilities as assigned by management.Confidentiality:All information handled is highly confidential.Mental Application:This position relies on established laws and regulations to make judgments. Must be able to read and interpret those laws and regulations.Responsibilities:Civil monetary penalties could be extensive and goodwill is a risk.Contacts/Internal and Public:Direct contact with bank personnel, as well as state and federal examiners.EDUCATION, CERTIFICATION, EXPERIENCE:Education:Required:Two-year banking, business, or law related degree (or equivalent job related branch/compliance experience).Preferred:Experience: Required: 8 - 10 years banking experiencePreferred: 3 - 5 years CRA and / or Bank Compliance experienceKNOWLEDGE, SKILLS, ABILITIES:Understanding of consumer protection and public interest laws and regulations. Good writing and communication skills.WORK ENVIRONMENT:•Working Conditions: Conditions are generally good with little discomfort caused by noise, heat, and dust.•Equipment Operations: Must be able to use Microsoft OfficePHYSICAL DEMANDS:1.Frequently required to sit for prolonged periods of time.2.Normal range of vision, speech and hearing abilities required.3.Mobility required greeting and assisting employees and visitors.4.Frequently required to skillfully operate a computer, telephone and other standard office equipment.5.Occasionally travel outside of work location to attend meetings and training programs.6.Occasionally lift and/or move up to 20 pounds.Special Note:External and internal applicants, as well as position incumbents, must be able to perform the essential job functions as set forth above. Orange Bank and Trust Company is committed to a policy of Equal Employment Opportunity and will not discriminate against an applicant or employee on the basis of age, sex, sexual orientation, race, color, creed, religion, ethnicity, national origin, alienage or citizenship, disability, marital status, military or veteran status or any other legally-recognized protected basis under federal, state or local laws, regulations or ordinances.Upon request, individuals with disabilities may be entitled to a reasonable accommodation. A reasonable accommodation is a change in the way things are normally done that will ensure an equal employment opportunity without imposing an undue hardship on the bank. Please inform the Human Resources Department if you need assistance completing any forms or to otherwise participate in the application process or, at the appropriate time, to perform the essential functions of the job. This job description in no way states or implies that these are the only duties to be performed by an employee. Additional functions and requirements may be assigned by supervisors as deemed appropriate, based on the employee’s knowledge, skill and ability as well as his/her mental and physical abilities.
Minimum Salary: 86,000Maximum Salary: 120,000Salary Unit: Yearly