Border Bank is seeking a Compliance Manager to join our team. This position has the flexibility to office at any of our current Border Bank locations in Fargo, North Dakota, or Badger, Baudette, Clearbrook, Coon Rapids, Greenbush, International Falls, Middle River, Roseau, or Thief River Falls, Minnesota.
The Compliance Manager will administer the Bank's enterprise-wide Compliance Management System (CMS), including regulatory change management, policies and procedures, training, compliance monitoring and testing, consumer complaint oversight, issue management, corrective action, and management and Board reporting. In addition will serve as the CRA Officer.
The Compliance Manager serves as an independent second-line risk management authority. Responsibilities include maintaining knowledge of applicable regulations, researching new and amended requirements, working with department managers to develop procedures, and training staff on changes in laws, regulations, and procedures. Responsibilities also include overall coordination of compliance examinations, audits, and responses.
Accountabilities:
Program Ownership and Responsibilities
- Maintain a documented responsibility matrix identifying whether the Compliance Manager serves as program owner, second-line oversight function, advisor, committee member, Fair Lending, UDAAP, HMDA, BSA/AML-CFT, vendor management, complaint management, privacy, and other assigned compliance programs. The Compliance Manager serves as the designated owner of the Community Reinvestment Act program.
- For assigned areas, define decision rights, reporting expectations, required competencies, succession coverage, and escalation paths.
Regulatory Change Management and Policies
- Research federal and state banking laws and regulations, review Bank policies and procedures, and evaluate compliance with applicable requirements.
- Remain abreast of new regulations and changes to existing regulations. Update the CRO, affected department leaders, and the Compliance and/or Enterprise Risk Management Committee on these changes.
- Develop, update, or maintain compliance policies assigned to this position.
- Maintain a documented regulatory change management process that includes applicability assessments, impact analysis, assigned business owners, implementation deadlines, evidence of completion, and post-implementation validation, as appropriate.
- Clearly distinguish business-line ownership of operational procedures and controls from Compliance's oversight, review, challenge, and advisory responsibilities.
Compliance Risk Assessments
- Develop and maintain risk assessments for overall Compliance, UDAAP, and Fair Lending using the Bank's risk management software.
- Assist the Risk Department in developing and maintaining other risk assessments, including product-specific assessments.
- Apply a consistent methodology that evaluates inherent risk, control design and effectiveness, residual risk, emerging risk, and required mitigation. Review assessments at least annually and when material changes occur.
Compliance Procedures and Change Management
- Work with project teams to address compliance requirements for products, services, software, delivery channels, and other material changes.
- Assist department leaders in developing procedures for products and services to promote compliance with applicable laws and regulations.
- Provide documented compliance review and approval or concurrence, as defined by Bank governance, before implementation of new or materially changed products, services, systems, vendors, marketing materials, disclosures, pricing, and customer-facing processes.
- Confirm identified compliance requirements are incorporated into business requirements, testing, implementation plans, and post-implementation reviews.
Community Reinvestment Act Program Administration
- Serve as the Bank's designated Community Reinvestment Act Officer and own administration of the CRA program in accordance with applicable laws, regulations, regulatory guidance, examination procedures, and Bank policy.
- Maintain the CRA policy, procedures, program calendar, responsibility assignments, records, and supporting documentation necessary to demonstrate ongoing compliance and examination readiness.
- Monitor regulatory developments, examination procedures, asset-size thresholds, census and demographic information, and other changes affecting the Bank's CRA obligations; coordinate timely implementation of required changes.
- Maintain and periodically evaluate the Bank's CRA assessment areas and performance context, including relevant economic, demographic, competitive, lending, and community-credit-needs information.
- Monitor and analyze CRA performance using measures applicable to the Bank's examination category, including lending activity, geographic and borrower distribution, lending inside and outside assessment areas, and community development performance.
- Identify, evaluate, document, and track qualifying community development loans, investments, donations, services, and other CRA-related activities; establish documentation standards for business units contributing information.
- Maintain the CRA public file and ensure required information is complete, accurate, current, and available within applicable regulatory timeframes.
- Oversee applicable CRA data collection, validation, reconciliation, submission, retention, and data-quality controls, and coordinate correction of identified errors or documentation gaps.
- Develop and deliver risk-based, role-specific CRA training for the Board, management, lenders, branch personnel, and other applicable employees; track completion, delinquency, and evidence of training.
- Coordinate with lending, retail banking, marketing, finance, executive management, and other business areas to identify community credit needs, CRA opportunities, performance gaps, and appropriate responsive activities.
- Provide periodic CRA reporting to management, the Enterprise Risk Management Committee, and the Board addressing performance trends, assessment-area results, community development activities, data quality, training, complaints or public comments, emerging risks, identified gaps, and corrective actions.
- Coordinate CRA examination preparation, document production, examiner requests, management responses, and remediation of findings or recommendations.
- Monitor CRA-related complaints and public comments, evaluate trends and potential impact, coordinate appropriate responses, and escalate matters that could adversely affect CRA performance or regulatory applications.
- Evaluate and communicate the potential CRA impact of new branches, branch relocations or closures, mergers, acquisitions, products, delivery channels, and other significant strategic decisions.
Training
- Maintain a risk-based, role-specific training program; track completion and delinquency; evaluate effectiveness; and report material gaps to management.
- Periodically, provide training to Bank staff to support awareness and understanding of regulations affecting their functions and changes in regulatory requirements.
- Manage and monitor compliance training through the Bank's online education platform and recommend appropriate courses.
Compliance Monitoring and Testing
- Develop and maintain a risk-based compliance monitoring and testing plan that defines scope, frequency, sampling, documentation standards, issue ratings, reporting, and follow-up validation.
- Lead, coordinate and review compliance monitoring reports and complete workpapers supporting conclusions.
- Communicate findings to department leaders and work with them to improve procedures and correct identified issues.
Consumer Complaint Management
- Oversee the compliance aspects of the Bank's complaint management program, including consistent intake and classification, timely response, regulatory escalation, trend analysis, root-cause evaluation, identification of potential consumer harm, and reporting to management and the Board.
- Coordinate with business owners to ensure complaint themes and control weaknesses result in appropriate corrective action and updates to policies, procedures, products, training, or monitoring.
Issue Management and Corrective Action
- Maintain a centralized inventory of compliance findings, violations, complaints requiring remediation, and examination or audit issues, including risk rating, root cause, accountable owner, target date, status, and supporting evidence.
- Monitor remediation, escalate overdue or materially deficient actions, assess potential consumer harm, and validate corrective action before closure.
Third-Party Compliance Risk
- Provide risk-based compliance oversight of service providers and fintech partners throughout due diligence, contracting, implementation, ongoing monitoring, issue remediation, renewal, and termination.
- Assess whether third-party products and services comply with applicable consumer protection requirements and Bank policies and escalate material deficiencies.
Compliance Advisory and Helpdesk Support
- Provide prompt, documented responses to general compliance questions and escalate significant or novel matters to the CRO or legal counsel, as appropriate.
Audits and Examinations
- Assist the Bank's Internal Audit function with collection of information for external audits and regulatory examinations.
- Coordinate compliance examination readiness, information requests, management responses, corrective action plans, and status reporting while preserving Internal Audit's independence.
Reporting and Governance
- Work with the Board of Directors, Compliance Committee and Enterprise Risk Management Committee to oversee consultants employed by the Bank, including scope, reporting procedures, scheduling, and review activity.
- Report to the Board of Directors at least annually and promptly escalate significant compliance violations, consumer harm, regulatory criticism, or overdue high-risk corrective actions.
- Board and management reports should address regulatory developments, compliance risk assessment results, monitoring and testing, complaints and trends, violations and consumer harm, open and overdue corrective actions, training completion, examination and audit results, emerging risks, and resource adequacy.
- Establish and direct a Compliance Team, including meeting schedules, agendas, minutes, decisions, and action-item follow-up.
Education and Requirements:
- Bachelor's degree or significant related experience.
- 4+ years of banking compliance experience, preferably within a community bank.
- Professional certification such as CRCM, CCBCO, or an equivalent recognized banking compliance credential is preferred; continued professional education is expected.
- Demonstrated experience administering a CMS, leading regulatory examinations, managing corrective actions, and presenting to executive management or the Board is preferred.
- Proficiency with compliance management systems, data analysis, dashboards, regulatory research platforms, and standard office technology.
Border Bank Employee Benefits
Border Bank offers a comprehensive benefits package designed to support your health, financial well-being, and work-life balance:
- Paid Time Off & Paid Holidays
- Paid Parental Leave & Childbirth Recovery Leave
- Health, Dental & Vision Insurance
- Flexible Spending Account (FSA)
- Health Savings Account (HSA)
- 401(k) with Employer Match
- Bank-Paid Life Insurance & Long-Term Disability
- Supplemental Insurance Options (Accidental Injury, Heart & Stroke, Cancer, Intensive Care, Hospital Indemnity, Critical Illness, Life, and Short-Term Disability Insurance)
- Employee Assistance Program (EAP)
- Wellness Dollars
- Civic & Recreational Benefit
- Education Assistance