Compliance Specialist – Commercial Loan Originations and Servicing
Responsible for the review of commercial loan documents during the origination, pre-closing and post-closing process to ensure compliance with Reg B, CRA, BSA, HMDA and flood insurance coverage, as applicable, in accordance with regulatory requirements, Bank policies, operating procedures, audit requirements and federal regulations.
• High School/GED diploma
• Minimum three years’ experience in commercial loan and/or consumer loan origination and /or post-closing servicing as it relates to Reg B, CRA, HMDA, Flood Insurance and BSA/OFAC requirements.
• Proficiency in using Excel, Word, Outlook and other applicable software
• Self-starter and willingness to learn.
• Ability to multi-task and meet deadlines.
• Ability to adapt and apply changes in regulatory requirements to workflow.
Essential functions and responsibilities:
Commercial Loan Originations:
• Responsible for the review of the Commercial Loan Application and related documents to ensure that all compliance and Bank requirements have been met including, but not limited to the following:
- Review Commercial Loan Applications for completeness, loan purpose and amount, GMI, etc.
- Review Commercial Loan Applications with regard to Reg B ensuring compliance with Joint Intent and appropriate disclosures.
- BSA Program compliance including OFAC screening, verification of company existence, customer identification, and foreign income, assets, and collateral sources.
- Identity Theft Prevention Program as it relates to address discrepancies, fraud alerts, etc.
- Review to confirm CRA reporting requirements – small business, community development,; along with accuracy of FFIEC address and geocoding accuracy.
- Review to confirm HMDA reporting requirements as identified.
- For real estate related loans, review to confirm Flood determination was obtained timely and customer notice was delivered timely (if required) .
- Review Credit Offering and related worksheets to ensure information is consistent with Loan Application and consistent throughout as it relates to the Company (borrower), Company address, company type, collateral address and lien position, loan amount, loan purpose, repayment sources, gross revenue, CRA, and/or HMDA eligibility, and other BSA related items (such as foreign income, assets, and collateral).
Commercial Loan Pre-Closing Responsibilities:
• Responsible for reviewing documents prior to closing to ensure that all compliance and Bank requirements have been met including, but not limited to the following:
- Flood Insurance requirements, if applicable; have been met including reviewing the flood insurance calculation sheets and policy issuance.
- Appraisal requirements, if applicable, have been met including timing requirements for the secondary review and delivery of appraisals to borrowers.
- Reg B Notices, if applicable, have been issued for declines and/or counter-offers. Ensure declines are properly documented on internal tracking log for Compliance department review.
- Review declines in accordance with FCRA ensuring credit score disclosures provided accordingly.
- Review of all declines as it relates to HMDA and Reg B reporting requirements.
Commercial Loan Post-closing Responsibilities:
Responsible for the post-closing review of all loans to ensure that all compliance and Bank requirements have been met including, but not limited to the following:
- Responsible for the review, data input and quality control of all CRA reportable loans on the Bank’s Loan Application Register.
- Responsible for the review, data input and quality control of all HMDA reportable loans on the Bank’s Loan Application Register.
- Responsible for maintaining accurate records, for all loans requiring flood insurance, issuing renewal notices and ensuring all flood policies are renewed timely and for the correct coverage amount. Force placing flood insurance, when necessary, to ensure no lapse in coverage.
- BSA Program compliance including OFAC screening obtained prior to closing, ID obtained and scanned, and Record of Borrower ID was completed.
- Responsible for the review of all final loan documents, as it relates to regulatory compliance, ensuring accuracy and consistency with final approvals. Post-closing deficiencies are to be reported to department manager.
• Work with Management and Compliance on CRA Data Integrity, HMDA Data Integrity, Flood Insurance reviews, and any other Commercial Lending Compliance related reviews.
• Perform loan maintenance on CORE DNA system as required
• Perform all tasks in accordance with Bank policies, operating procedures, internal and external audit requirements and compliance and
federal regulations with an adherence to deadlines
• Complete required training by deadlines
• Regular and predictable attendance
• Perform other related duties as assigned
Success factors/job competencies:
• Ability to work well independently and with others
• High degree of accuracy and attention to detail
• Strong communication skills, written and verbal
• Organizational and time management skills
• Strong knowledge of bank services and products