Grand Bank - Fair and Banking Officer

Fair And Responsible Banking Officer

The Fair and Responsible Banking Officer serves Grand Bank for Savings, FSB ("Grand Bank" or the "Bank") as a subject matter expert responsible for the design, implementation, and oversight of the Bank's Fair Lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) compliance program across all products, delivery channels, and customer touchpoints, including digital banking platforms and the Bank's national credit card program.

This position will lead a team of compliance professionals and has direct interaction with senior leadership and Board-level committees. This role provides second line of defense oversight to ensure the Bank delivers fair, transparent, and compliant products and services, while proactively identifying, assessing, and mitigating fair banking risks. The Officer partners with business lines, compliance, marketing, digital, payments, and credit card program teams to embed fair banking principles into product design, customer communications, and lifecycle management with a focus on ensuring fair, consistent, and equitable customer outcomes.

The position supports regulatory compliance with applicable laws and guidance, including Fair Lending laws (ECOA/Reg B, HMDA), UDAAP, Regulation E, Regulation Z, and applicable NACHA/ACH rules. Oversight spans the full product lifecycle, including product design, underwriting, model risk management, marketing, servicing, collections, and customer communications. The position reports to the Chief Compliance Officer and has authority to independently escalate issues, require corrective action, and provide credible challenge across all lines of business.

Essential Duties and Responsibilities:

• Develop, implement, and maintain an effective second line Fair and Responsible Banking (Fair Lending and UDAAP) compliance program across all Bank products and services
• Establish and maintain fair banking risk governance standards, including alignment 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
• Provide oversight of 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
• 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, for fair banking and UDAAP implications related to third-party data access and customer-permissioned sharing
• 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
• Perform ongoing monitoring, testing, and analytics to detect fair lending and UDAAP risks across products and channels
• Coordinate with the Model Risk Management (MRM) function to ensure fair lending risk is incorporated into every credit-decisioning model validation, including underwriting scorecards, risk-based pricing engines, and automated credit line increase models.
• Conduct comparative file reviews, matched pair analysis,…