Payments Compliance Advisory Lead: BaaS
The Payments Compliance Advisory Lead: BaaS within the Second Line of Defense (2LOD) is responsible for providing leadership, vision, and regulatory compliance subject matter direction to the Payments division of Comerica Bank. The Payments Compliance Advisory Lead must possess strong working knowledge of FedNow, Instant payments APIs, Virtual Account Management and Banking as a Service (BaaS). Providing this leadership, vision and direction requires the position to have a deep understanding of Regulatory requirements as it relates to consumer-facing banking products. This position will provide ongoing guidance as well as lead and manage major implementation processes, beginning with reading, interpreting, and developing an in-depth knowledge and understanding of the regulation and ending with a successful implementation across all impacted business units. They will be required to closely interact with the Line of Business and key stakeholders, including Legal, Internal Audit, Business Management and Control functions to understand the legal obilgations associated with new products and features, and be embedded with Product partners undersanding their strategy and vision. This individual assists business units with their ability to detect, assess, and respond to emerging risk, and maintain a comprehensive compliance risk and control framework.
Position Responsibilities
Regulatory Compliance and Business Partnership
- Provide advice and guidance on the Comerica Payments Rails and BaaS Strategy and related activities by possessing strong working knowledge of the applicable rules and regulations such as Reg E, Reg CC, Reg DD, Reg Z, EFTA, UDAAP, and related rules and guidance (e.g., FRB Supervision and Regulation Letters, CFPB bulletins, OCC Comptroller handbooks; OCC bulletins; FFIEC Guidance; etc.).
- Provide advice and guidance on FedNow, Instant payments APIs, and Virtual Account Management risks; working with the Line of Business to ensure all risks are approprately documnted and mititgated.
- Ensure BaaS offerings provide clear and accurate information about fees, terms, and conditions associated with BaaS services.
Serve as compliance Subject Matter Expert on regulations within assigned area of responsibility. - Provide ongoing leadership and coaching to business management and functional partners to assist with Compliance and Risk and Control Assessments by using a risk mindset; participate in process walkthroughs and documentation of key controls, analyze, and escalate potential gaps in control design or coverage to Compliance Advisory leadership team.
- Partner with Line of Business, Compliance, Risk and third parties to ensure all processes and procedures are in compliance with applicable policies and regulations.
- Acitvely participate in business unit meetings, committees, and providing support and guidance on compliance and regulatory matters.
- Collaborate with other departments on implementation of any new or changed, laws, rules, regulations, and products or services.
- Review and appropriately challenge marketing collateral, and customer-facing documents for appropriate disclosures and to ensure compliance with applicable regulations.
Risk Awareness
- Manage and maintain enterprise-wide policies, standards, and procedures designed to achieve compliance with applicable laws, rules, and regulations.
- Participate in industry forums to understand and implement best practices as appropriate.
- Evaluate and advise on new/revised products and services from a compliance risk perspective to assigned business units.
- Assist in leading corporate-wide implementation efforts of new or revised regulatory requirements.
Testing, Audits and Exams
- Collaborate with Compliance Testing Team to define the appropriate scope of compliance reviews by providing guidance regarding emerging risks and new or revised regulatory changes that may impact the business.
- Partner with business units to lead regulatory exams, internal and external audits, and enterprise-level reviews; manage audits and exams on a proactive project basis to ensure that responses submitted are appropriate and accurate and adequately address the request.
- Assist business units with responses, as necessary.
- Read, analyze, and develop an in-depth understanding of the regulation to determine requirements/mandates.
Training
- In partnership with the HR Talent Development department, advise business partners on special training needs and assist in the creation and revision of training materials and tools.
- In partnership with the HR Talent Development department, lead development, implementation, and monitor necessary training programs for the team and risk compliance liaisons to ensure they understand the Compliance Risk Framework and their responsibilities within the framework.
Position Qualifications
- Bachelor's degree (preferably in Business, Finance, or related field) from an accredited university, or in lieu of a bachelor's degree, a High School Diploma or GED and 6 years of Risk Management or other related experience in the Financial Services Industry
- 6 years Experience in regulatory compliance or related Legal experience
- 5 years Experience in Financial Services industry
- 3 years Experience working with lines of business in interpreting and applying relevant rules, laws, and regulations to the business
Licenses & Certifications
- Preferred: Certified Regulatory Compliance Manager (CRCM)
Work Best Category: Category C - Days in the office will either be designated days or will vary week to week from 2-5 days
Hours: 8:00am - 5:00pm Monday - Friday
Salary: To Be Determined Based on Individual Experience
About Comerica We know our employees are critical to our overall success and we are dedicated to investing in their future. One of the ways we do this is to offer a comprehensive Total Rewards package designed to recognize and reward individual performance, as well support health, well-being, development and security for our colleagues and their family. Total Rewards consists of cash compensation, development and flexible benefit programs designed to meet individual needs today and in the future. Your salary will be commensurate with your work experience and our programs are reviewed regularly to ensure each remain competitive. We are proud to offer benefits such as health and welfare programs, strong retirement benefits, and generous paid time off programs. You and your eligible family members, including domestic partners and their children, can participate in medical, dental, and vision benefits, 401(k) and pension, income protection benefits such as life insurance, AD&D, and supplemental health programs to offset unexpected health care expenses. We also have a variety of time off programs for things like vacation, sick time, disability, and parental leave. Eligibility for some programs varies based on employment status and tenure.
Upon offer, Comerica conducts a comprehensive background and fingerprint check.
NMLS certification requirement: where applicable, a favorable background check screening, credit check, fingerprint check, and NMLS certification is required in accordance with the SAFE Act.
Comerica Incorporated (NYSE: CMA) is a financial services company headquartered in Dallas, Texas, and strategically aligned into three major business segments; the Commercial Bank, the Retail Bank, and Wealth Management. Comerica's colleagues focus on relationships, and helping people and businesses be successful. In addition to Texas, Comerica Bank locations can be found in Arizona, California, Florida and Michigan, with select businesses operating in several other states, as well as in Canada and Mexico.
Comerica is proud to be an Equal Opportunity Employer - veterans/individuals with disabilities, committed to workplace diversity.
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