Grand Bank - Fair and Responsible Banking Officer

Fair and Responsible Banking Officer

The Fair and Responsible Banking Officer serves as the Grand Bank for Savings, FSB (“Grand Bank” or the “Bank”) subject‑matter expert responsible for designing, implementing, and overseeing the Bank’s Fair Lending and UDAAP compliance program across all products, delivery channels, and customer touchpoints, including digital banking platforms and the national credit‑card program. This role leads a team of compliance professionals and directly interacts with senior leadership and Board‑level committees.

The Officer provides second‑line oversight to ensure the Bank delivers fair, transparent, and compliant products and services while proactively identifying, assessing, and mitigating fair banking risks. Partnering with business lines, compliance, marketing, digital, payments, and credit card teams, the Officer embeds fair banking principles into product design, customer communications, and lifecycle management to achieve equitable customer outcomes.

• Develop, implement, and maintain an effective second‑line Fair and Responsible Banking compliance program across all Bank products and services.
• Establish and maintain fair banking risk governance standards, aligned with the Bank’s risk appetite and escalation frameworks.
• Provide independent review, challenge, and oversight of business line activities to ensure fair treatment of customers and compliance with applicable regulations.
• Conduct enterprise‑wide fair banking risk assessments, incorporating deposit, digital banking, ACH/payment flows, and credit card products.
• Coordinate with the CRA Officer to align fair banking risk assessments with CRA program objectives and equitable access to credit and services.

• Oversee fair banking risks within digital banking platforms, including account origination, servicing, disclosures, and customer experience.
• Review and challenge ACH and payment‑related practices for compliance with NACHA rules, Regulation E, and UDAAP expectations.
• Monitor customer journeys across digital channels to identify potential disparate treatment or unfair, deceptive, or abusive practices.
• Partner with operations and technology teams to ensure fair and compliant design of automated decisioning, workflows, and customer communications.
• Monitor and manage the bank’s overdraft program to ensure compliance with applicable regulations, internal policies, and fair lending principles, including periodic review of program parameters, fee structures, and customer impact metrics.
• Review automated decisioning models, algorithms, and credit policies for fair lending and UDAAP risk.
• Monitor developments in consumer financial data rights, including obligations under Section 1033 of the Dodd‑Frank Act and emerging open banking frameworks.
• Provide oversight of error resolution processes (including ACH disputes and unauthorized transactions) to ensure consistent and fair customer outcomes.

• Provide fair lending and UDAAP oversight for the Bank’s national credit card program, including underwriting, line assignment, credit line management, pricing, fees, marketing, and servicing practices.
• Review credit card disclosures, marketing materials, and lifecycle communications for compliance with Regulation Z, UDAAP, and card network expectations.
• Analyze credit card portfolio performance, including approvals/denials, line management, fees, and customer outcomes for potential disparate impact or unfair practices.
• Support oversight of third‑party processors, issuing platforms, and marketing partners to ensure alignment with fair banking requirements.
• Oversee credit card marketing, pre‑screen, and solicitation practices for compliance with fair lending and UDAAP expectations.
• Provide oversight of credit card collections, hardship programs, and loss mitigation strategies for fair lending and UDAAP risk.

• Perform ongoing monitoring, testing, and analytics to detect fair lending and UDAAP risks across products and channels.
• Coordinate with the Model Risk Management function to ensure fair lending risk is…