Director of Compliance Testing

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Job Description

The Compliance Testing Program is a critical component of an effective Compliance Management System (“CMS”). This position is responsible for developing, maintaining, and executing a robust risk-based second line of defense Compliance Testing Program, the primary purpose of which is to identify, detect, and correct noncompliance. Additionally, the position is responsible for managing, organizing, planning, and conducting various reviews and/or testing of any applicable components of the Bank’s regulatory risk inventory. The Director of Compliance Testing will regularly interface and collaborate with first line of defense business/operating units, and other groups within the Compliance Risk Management Team (i.e., Financial Crimes Risk Management, Compliance Risk Data & Analytics, Compliance Advisory Services, and Fair and Responsible Banking) and other support functions including Legal, Risk, Third Party Risk Management, as well as the Bank’s affiliates and subsidiaries.

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Primary Duties and Responsibilities

Responsible for performing complex regulatory research, analysis and testing on behalf of the Compliance Risk Management Team (“CRMT”) and the Chief Compliance Officer (“CCO”); assessing regulatory risks and adequacy of operating policies, procedures, processes, and controls. The Director of Compliance Testing:

• Understands and adheres to a comprehensive risk based compliance testing program in coordination with the CCO
• Supervises a team of Compliance Testing Specialists to complete testing responsibilities as designed by the CRMT and CCO
• Creates and maintains a centralized inventory of all compliance risk controls; ensuring each compliance risk element on the Compliance Risk Assessment is mapped to a compliance control
• Independently conducts compliance testing engagements addressing the Bank’s inventory of risks and regulations
• Measures compliance with laws and regulations by completing testing, assessing internal controls, assessing the operating environment, and reviewing policies and procedures to ensure compliance with federal and state regulations – as well as the Bank’s enterprise-wide Compliance Program
• Collaborates with the CCO in designing, executing and documenting transaction testing plans for Financial Crimes Risk Management, deposit, lending, and all other compliance requirements
• Ensures test steps are aligned to control design and the Bank’s operating environment
• Reviews and approves audit work papers prepared by Compliance Testing Specialists to ensure accuracy, completeness, and logical support for conclusions reached

• Ensures statistical transaction sampling selection methods are used rather than subjective/judgmental sampling methods
• Ensures the assigned Compliance Testing Specialist has a strong understanding and expertise in the regulations to which they are assigned
• Ensures the Compliance Testing Program incorporates an assessment of first line of defense turnover/staff stability
• Ensures the Compliance Testing Program incorporates recent or planned system changes and/or regulatory changes
• For all planned testing engagements, establishes a testing resource allocation (by hours)

• Provides timely, constructive feedback on work paper documentation and coaches Compliance Testing Specialists on ways to improve quality and efficiency
• Remains current on changes to audit and testing standards, regulations, and industry developments and communicates relevant updates to the Compliance Testing Specialists
• Plans and manages compliance testing engagements from kick-off through report issuance, including resource allocation, scheduling, and budget monitoring
• Monitors management's corrective actions to ensure compliance risks are mitigated or transferred effectively to remain within the Board-approved compliance risk tolerance

• As it relates to issue tracking and remediation, ensures that Compliance Testing tracks all issues in AuditBoard; validating remediation and retaining related artifacts and evidence, retesting compliance controls, where applicable, and escalating overdue or ineffective remediation to executive management monthly
• Ensures that each testing engagement includes an opening conference with impacted first line of defense partners, a walk-through of procedures and processes to ensure a complete understanding of the operating environment, informal discussion of testing findings, distribution of the draft report, a closing conference with auditees, and final report distribution
• If the first line business or operating unit has not created process maps for key compliance requirements, assists in the creation and validation of such
• Prepares quarterly compliance testing dashboard reflecting testing-specific KRIs and KPIs
• Develops and maintains a strategy for Compliance Testing Specialist development and education which includes individual and group knowledge gap assessments; maintaining a written learning and development plan for each member of the Compliance Testing Group (including self)

• Utilizes Bank-approved Artificial Intelligence (“AI”) tools to improve efficiency and accuracy in the compliance testing space
• Assists with regulatory examinations, independent compliance audits, and second line compliance testing engagements

• Reads, analyzes, and interprets financial reports, legal documents, governmental regulations, and professional publications

• Consults on various enterprise-wide projects and initiatives relative to compliance and regulatory risks
• Communicates effectively with colleagues on the CRMT, first line of defense business partners, executive management, internal and external auditors, and regulators
• Adheres to Bank policy, procedure, and regulatory requirements
• Adheres to all deadlines and time periods, manage workflow to the specified deadlines, and complete responsibilities in a satisfactory manner
• Maintains a strict level of confidentiality
• Performs any other assignments as directed by the CCO

Supervisory Responsibilities                                                       

Directly supervises a team of Compliance Testing Specialists to complete testing responsibilities as designed by the CRMT and CCO. Carries out supervisory responsibilities in accordance with the organization's policies and applicable laws.  Responsibilities may include training employees; planning, assigning, and directing work; appraising performance in conjunction with other Compliance Risk Management Team leadership; addressing complaints and resolving problems.

Competencies

To perform the job successfully, an individual should demonstrate the following competencies:

Analytical and Design - Ability to assess risk; detail oriented, analytical, and critical thinking skills; strong problem solving and analytical skills required to succeed in this job; Strong technical troubleshooting skills and ability to  perform simultaneous complex projects.

Problem Solving - Identifies and resolves problems in a timely manner; Gathers and analyzes information skillfully; Communicates well in group problem solving situations; Uses reason even when dealing with emotional topics.

Interpersonal Skills/Customer Service - Focuses on solving conflict, not blaming or criticizing; Maintains confidentiality; Remains open to others' ideas and tries new things; Manages difficult or emotional customer situations; Responds to requests for service and assistance; Meets commitments.

Oral and Written Communication - Speaks clearly and persuasively in positive or negative situations; Listens and gets clarification; Responds well to questions; Demonstrates group presentation skills; Participates in meetings; Writes clearly and informatively; Edits work for spelling and grammar; Varies writing style to meet needs; Able to read and interpret written information.

Teamwork - Ability to work in a collaborative environment, as well as independently; Balances team and individual responsibilities; Exhibits objectivity and openness to others' views; Gives and welcomes feedback; Contributes to building a positive team spirit; Puts success of team above own interests; Supports everyone's efforts to succeed.

Organizational Support - Follows policies and procedures; Completes administrative tasks correctly and on time; Supports organization's goals and values; Benefits organization through outside activities; Supports affirmative action and respects diversity; Embraces trusted advisor role.

Judgment and Motivation - Displays willingness to make decisions; Exhibits sound and accurate judgment; Supports and explains reasoning for decisions; Includes appropriate people in decision-making process; Makes timely decisions; Demonstrates persistence and overcomes obstacles.

Planning/Organizing - Ability to multi-task and set priorities; Prioritizes and plans work activities; Uses time efficiently; Establishes goals and objectives.

Professionalism - Ability to deal with all levels of personnel in a courteous and effective manner; Approaches others in a tactful manner; Reacts well under pressure; Treats others with respect and consideration regardless of their status or position.

Quantity - Ability to work under pressure on multiple tasks concurrently and meet deadlines in a fast-past work environment with interruptions and changing priorities.

Adaptability - Adapts to changes in the work environment; Manages competing demands; Changes approach or method to provide the best fit to the situation; Able to deal with frequent change, delays, or unexpected events.

Attendance/Punctuality and Dependability - Is consistently at work and on time; Ensures work responsibilities are covered when absent; Arrives at meetings and appointments on time; Follows instructions, responds to management direction; Takes responsibility for own actions and that of all members of the Compliance Risk Testing Team; Commits to long hours of work when necessary to reach goals.

Qualifications

To perform this job successfully, expert-level knowledge of regulatory Compliance Risk Management and related laws and regulations. Incumbent must be able to perform each essential duty satisfactorily. The requirements listed below are representative of the knowledge, skill, and/or ability required. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.

Education and/or Experience                                                     

A Bachelor's or Master’s degree from four-year college or university preferred, or, alternatively, 15 years senior-level compliance management experience; Prior compliance experience at a large/regional bank subject to direct CFPB oversight and supervision preferred; Expert-level familiarity with federal and state banking regulations preferred; Certified Regulatory Compliance Manager (“CRCM”) preferred, or similar compliance certification.  Experience working as an examiner or compliance consultant may be taken into consideration when determining prior senior-level compliance requirements have been met.

Work Location

This position may be performed remotely, provided that candidates reside within a one-hour commute of an Origin Bank location.

Computer Skills                                                               

To perform this job successfully, an individual should have working knowledge of Microsoft Office Suite, including Outlook, Word, Excel, Power Point, Teams, Publisher, One Note, Power BI, and Vizio.  Ability to learn bank-specific software such as Audit Board, IBS, AccuSystems, nCino, Encompass, Kadince, Verafin, RiskExec, JIRA, or comparable software.  Ability to use basic office machines.

Bank Culture/Customer Service Skills

Ability and judgment to interact and communicate appropriately with other employees, customers, and supervisor.  Ability to serve customers, both internal and external, (community/public) in a manner that will reflect superior customer relations and enhance the overall marketing effort of Origin Bank.

Physical Demands  

While performing the duties of this job, the employee is frequently required to stand; walk; sit; use hands to finger, handle, or feel and talk or hear.  The employee is occasionally required to reach with hands and arms; climb or balance and stoop, kneel, crouch, or crawl.  The employee must frequently lift and/or move up to 10 pounds and occasionally lift and/or move up to 25 pounds.  Specific vision abilities required by this job include close vision, distance vision and ability to adjust focus.

Mental Demands  

Incumbent in this position must be able to accommodate reading documents or instruments, detailed work, problem solving, customer contact, reasoning, math, language, presumptions, verbal and written communication, analytical reasoning, stress, multiple concurrent tasks, and constant interruptions.

Work Environment  

The noise level in the work environment is usually moderate.

This job description reflects management's assignment of essential functions.  It does not prescribe or restrict the tasks that may be assigned.  Origin Bank shall, in its discretion, modify or adjust the position to meet the bank’s changing needs.  This job description is not a contract and may be adjusted as deemed appropriate in the bank’s sole discretion. 

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Remote positions are intended to be filled in states within our footprint, which includes: Alabama, Florida, Louisiana, Mississippi, and Texas. Any exception to this policy requires further regulatory review and approval by management.

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Equal Opportunity Employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, pregnancy, genetic information, disability, status as a protected veteran, or any other protected category under applicable federal, state, and local laws. Know Your Rights