The Senior Compliance Testing Manager – Consumer Protection reports to the Compliance Testing Director within M&T Bank’s Compliance Risk Management Department and is responsible for the development, implementation, and oversight of the Bank’s independent testing program over consumer protection, including Fair Lending/Fair & Responsible Banking, UDAP/UDAAP, and other consumer protection related risks. This position is responsible for managing and leading compliance testing engagements utilizing a risk-based approach in line with department and industry standards, and expectations to ensure the Bank’s compliance with applicable laws, rules & regulations.
The Sr. Compliance Testing Manager will all also oversee performance of Issue Validation procedures to ensure compliance findings have been effectively mitigated, as well as providing effective challenge over actions taken by the organization to address any regulatory feedback received in the form of MRA/MRIAs.
As a member of the Senior Management Team, this leadership role assists in the development and support of the department’s strategic vision including supporting the development of the annual testing plan, continued enhancements to testing methodology, ongoing stakeholder engagement, talent management, and overall promotion of the Compliance Testing Group within the organization. This position requires interaction with senior levels of management as well as regulators.
This position requires both subject matter expertise and working knowledge of applicable federal and state laws, regulations, rules, and guidance related to UDAP/UDAAP, fair lending/fair banking, and consumer protection principles, as well as working knowledge of lending products, services, and business operations. Successful candidates will be able to effectively build cross-functional relationships throughout the organization and collaborate across many lines of business as well as Legal, Risk, Internal Audit and Compliance partners to anticipate, manage, escalate, and remediate potential risks.
Position Responsibilities:Responsible for the implementation, maintenance, and oversight of the Consumer Protection testing team, and identifying potential risks through independent reviews.
Work cross-departmentally to optimize the compliance testing program activities, including iterative development of the program in collaboration with the UDAP/UDAAP Program Office and the Fair Lending Officer.
Oversee the team responsible for planning and execution of Issue Validation testing, including multiple simultaneous testing engagements.
Provide effective challenge over the actions taken by Bank management to address Regulatory Examination Findings (e.g. MRIA, MRA) and ensure appropriate documentation is present to evidence the actions taken.
Coordinate efforts across business partners including Internal Audit, Regulatory Affairs, and Business line management to ensure effective challenge processes are aligned and completed within committed timelines.
Perform compliance testing in accordance with department and professional standards.
Manage all phases of testing, including multiple simultaneous testing engagements across multiple testing portfolios, ensuring that testing engagements are completed within established timeframes and/or provide early escalation to anticipated delays to management.
Lead special projects that may arise to support compliance objectives.
Support the annual risk assessment and testing plan development processes to determine testing coverage.
Review and communicate substantive testing findings and control execution weaknesses to all levels of compliance and business unit management.
Lead and moderate collaborative testing team discussions with all levels of management where judgment and opinions are effectively challenged.
Review and finalize tiering of test findings prior to communication to respective impacted and interested parties.
Encourage integrated testing approaches with the data & systems team, and make suggestions on testing approaches to improve the efficiency and effectiveness of testing procedures.
Provide advisory and consulting services to Bank Management on risk and control matters.
Maintain a comprehensive working knowledge of regulatory requirements to ensure an appropriate level of testing.
Provide feedback to team members regarding assessments of business unit process and controls and respective risk focused input on effectiveness and efficiency of testing approach.
Assist the Director of Compliance Testing with special projects and department wide initiatives.
Oversee budget for travel and training.
Adhere to applicable compliance/operational risk controls in accordance with Company or regulatory standards and policies.
Understand and adhere to the Company’s risk and regulatory standards, policies and controls in accordance with the Company’s Risk Appetite. Identify risk-related findings needing escalation to a Manager.
Promote an environment that supports diversity and reflects the M&T Bank brand.
Maintain M&T internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators as applicable.
Exercise usual authority of a manager concerning staffing, performance appraisals, promotions, salary recommendations, performance management and terminations.
Nature and Scope:The position works under general supervision of the Director of Compliance Testing, and is required to exercise independent judgment and discretion.
The position collaborates extensively with (a) Corporate Compliance subject matter deputies (PCMs) to gain an appropriate understanding of applicable regulatory requirements, (b) business unit staff and PCMs to understand work flows and processes, and (c) Internal Audit as a resource for review and coordination of testing plans and methods.
The position interacts with external contacts including Bank Supervisors/Examiners, attorneys, and peers at other institutions. Builds strong partnerships with business stakeholders and other compliance team members.
Manage a team of Testing Managers and Analysts.
Bachelor's Degree in related field.
10 years’ experience in compliance, legal, audit, risk or other relevant function,
OR in lieu of degree,
A combined minimum of 14 years higher education and/or work experience, including 10 years of relevant work experience in compliance, legal, audit, risk or another relevant function
Minimum of 5 years managerial or supervisory experience
Demonstrated leadership and coaching experience.
Ability to read and understand laws, regulations, and common law applicable to subject matter.
Ability to thrive in a collaborative, team-oriented environment.
Must have banking and compliance knowledge, the ability to exercise sound judgment, and to observe the highest degree of confidentiality in the handling of information received in the course of their responsibilities.
Sound understanding of financial services functions.
Possess regulatory subject matter expertise for the respective portfolio being managed.
Strong interpersonal skills, with the ability to effectively communicate both orally and in writing to senior level management with an approachable style.
Possess strong project management skills, making sound decisions, and exhibiting initiative and critical thinking.
Strong proficiency with spreadsheet, presentation, and word processing software.
Possess effective negotiation skills.
Education/Experience Preferred:MBA or Master's Degree in an appropriate field
Some familiarity with, and the ability to quickly learn, the organizations, operations, systems, and practices throughout all business units within M&T Bank Corporation.
Skill to diplomatically deal with and respond to requests from bank examiners.
Related certifications (CPA, CIA, CISA, CAMS, CRCM or similar certifications)