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Manager, Compliance Testing
Farmington Hills, MI
Job Description
Manager, BRCO Third-Party Risk
The Business Risk and Control Officers (BRCOs) play a pivotal role in guiding the business to identify and understand risk exposures and the controls needed which are integral to reducing risk and safeguarding our customers and colleagues. BRCOs are critical to the success of the Risk Management Lifecyle and play a role in Planning, Identifying, Assessing, Mitigating, Monitoring, and Reporting. BRCOs are members of the First Line of Defense (1LOD) who:
- Provide leadership and coaching to the 1LOD to proactively identify and effectively manage risks.
- Translate and educate 1LOD to enable and drive business relevant implementation of Second Line of Defense (2LOD) risk management frameworks, policies, taxonomies, and inventories.
- Review, validate, and test 1LOD activities to ensure adequate control design and effective control operation.
- Provide credible challenge to 1LOD colleagues, ensuring safeguard and risk mitigation measures are upheld in decision making and adherence to 2LOD frameworks and policies prior to 2LOD review.
- Drive two-way collaboration across 1LOD and 2LOD; liaise between 1LOD and 2LOD to drive engagement throughout the risk management lifecycle.
- Collaborate and coordinate across the organization to help navigate and mitigate horizontal risk promoting resilience and ensuring safety and soundness.
- Document, aggregate and report risk in accordance with the risk management lifecycle.
The Manager, Business Risk and Control Office (BRCO) Third-Party Risk for Line of Business will be responsible for leading a team to partner with 1LOD to ensure adherence to supplier management and third-party risk policies and procedures. Understands the third parties we use, how we use them and what safeguards our third parties have in place. Drives the oversight and governance activities, as required by 2LOD, of third parties engaged for the line business.
Position Responsibilities:
- Advises and guides 1LOD performing the Third-Party risk processes performed on new and existing Third Parties using a risk-based approach for review requirements and frequency.
- Analyzes process elements include planning, due diligence and third-party selection, contract negotiation, ongoing monitoring, termination/off-boarding.
- Provides guidance and works with 1LOD to identify, measure, control, monitor, and report on Third-Party risks in accordance with corporate risk policies.
- Facilitates and executes Third-Party due diligence activities, including relevant risk assessments to ensure adherence to the enterprise Third Party Risk Management policy.
Business Partnership
- Provides leadership and coaching to 1LOD to proactively identify and effectively manage risks.
- Translates and educates 1LOD to enable and drive business relevant implementation of Second Line of Defense (2LOD) risk management frameworks, policies, taxonomies, and inventories.
- Drives two-way collaboration across 1LOD and 2LOD; liaise between 1LOD and 2LOD to drive engagement throughout the risk management lifecycle.
- Drives a strong enterprise risk culture by fostering rigor and discipline focused on risk and compliance awareness, ethical business practices, transparency, and escalation.
- Learns continuously about the line of business to strengthen subject matter expertise and provide more valuable application of risk guidance.
- Collaborates with and supports other BRCO team members to ensure a robust and comprehensive implementation of 2LOD frameworks within 1LOD.
HR and Financial Management
- Selects, motivate, and retain high performing talent, cultivating a spirit of teamwork and continuous improvement with shared goals and objectives.
- Supports the development and growth of direct reports through on-going direction, coaching and performance management.
- Manages expenses and budget associated with the team and the work managed.
Position Qualifications:
- Bachelor's degree from an accredited university or a High School Diploma or GED and 6 years of Risk Management or other related experience in the Financial Services Industry
- 8 years of experience in Risk Management, Compliance, Audit, or related field
- Experience in Third-Party Risk Management
- Experience in advising, providing subject matter expertise, and credibly challenging colleagues in a risk and control environment
- Experience managing risk for non-vendor and vendor third party risk programs, including but not limited to prepaid card, partner distributed models, BIN sponsorship, and banking-as-a-service programs
- Strong understanding of various risk types/pillars, risk management, controls, and compliance concepts and frameworks
- Project support/project management skills - ability to provide direction, track progress and ensure alignment with program requirements
- Proficient in risk management software, MS Office Suite, and other related technology tools
- Strongly Preferred: Experience managing or leading a team
- Strongly Preferred: 6 years of experience in Financial Services industry and/or knowledge of Line of Business products, services, and business processes
- Preferred: Experience in developing and/or managing supplier contracts
A successful candidate will have the following knowledge and/or skills:
- Demonstrated knowledge of banking industry products, services, and workflows.
- Strong familiarity with critical business processes and controls, as well as overall business needs and objectives, for Line of Business.
- Strong track record of driving timely and effective issue resolution in a financial services context.
- Deep expertise and ability to educate colleagues on risk management, controls, and compliance concepts, frameworks, and policies.
- Ability to establish authority, influence stakeholders, and productively debate issues (e.g., credible challenge) at all levels including without direct reporting responsibility.
- Ability to build strong relationships and engage constructively in a proactive and transparent approach with cross-functional stakeholders, to challenge status quo and drive buy-in to achieve common goals.
- Ability to clearly and effectively communicate, including ability to summarize and explain complex findings and issues to a wide range of audiences.
- Ability to apply sound judgment and appropriately escalate concerns and issues.
- Ability to demonstrate managerial courage and inspire colleagues across the organization to embrace change.
- Ability to gather, analyze and interpret large datasets from various sources.
- Strong analytical and critical thinking skills with high attention to detail and accuracy.
- Ability to manage multiple tasks and projects, prioritize work, meet deadlines, achieve goals, and work under pressure in a dynamic and complex environment.
- Self-starter, able to work independently, flexible and can navigate a complex organization.
Compliance Testing Manager
The Manager, Compliance Testing within the second line of defense is responsible for planning, developing, implementing, and managing a comprehensive risk-based compliance testing program for their area of responsibility.
Position Repsonsibilities:
Compliance Testing, Monitoring and Reporting
- Provide guidance and lead a team responsible for executing the compliance monitoring and testing plan, ensuring execution of other assigned compliance related projects, tasks, and functions as assigned.
- Manage a sustainable control testing and monitoring program, ensuring all testing requirements are met and execute on a defined timeline.
- Develop an Annual Monitoring and Testing Plan using a risk-based approach to include RCSA control testing and issue validations.
- Partner with Compliance Advisory teams on new or changing regulatory requirements, emerging risks, risk assessment results, and incorporation into the testing and monitoring program.
- Manage issue validations on a defined schedule and provide aggregate results through formal reporting.
- Analyze, aggregate, and report the results/issues/recommendations related to control testing activities to senior management.
- Drive change through the enhancement and execution of a strong testing/monitoring program and provide risk support/consulting for key partners.
- Lead the strategy to execute compliance monitoring and testing requirements and create policies and procedures for consistent execution.
Policy, Process, and Procedure Improvement
- Coordinates the development and maintenance of all testing and monitoring procedures and department process flows.
- Support the development of control testing frameworks and methodologies.
Strategy
- Participate in multiple industry forums to share, decipher and create solutions to address risk and compliance trends.
- Provide recommendations and counsel to senior management to gain support for implementation of new strategies.
- May participate in large to complex corporate and department projects representing department needs while ensuring adherence to corporate and/or department direction.
Position Qualifications:
- Bachelor's Degree from an accredited university in Business, Finance, or related field
- 10 years of experience financial services or related industry
- 8 years of experience in compliance, risk management in financial services or related industry
Licenses/ Certifications:
- Certified Regulatory Compliance Manager (CRCM)
Comerica is proud to be an Equal Opportunity Employer - veterans/individuals with disabilities, committed to workplace diversity.
Job Summary
Start Date
As soon as possible
Employment Term and Type
Regular, Full Time
Required Education
High School or Equivalent
Required Experience
6+ years
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