Description:General Counsel Description & Duties:
This General Counsel will be responsible for managing the company's internal and external compliance policies as they relate to consumer loan origination and servicing. In addition, this person will provide guidance and input with regards to the company's broader legal needs in areas such as securitizations, contract negotiations, state licensing and correspondence, etc.
Duties may include, but are not limited to:
- Responsible for drafting and maintaining FFC's Legal and Compliance Policies; includes training, surveillance, etc. (examples below) -- work with outside counsel specializing in the development of the below
- Fair Lending Policy (ECOA, Disparate Impact, Responsibilities of Management and Compliance Department, Underwriting, Credit UWs, CRM, Servicing and Collections, Risk Assessment, Monitoring, Adverse Action Notices, Record Retention, etc.)
- ID Theft Prevention Program (Policies, Risk Assessment, Red Flags, Preventing and Mitigating, Reporting, etc.)
- Information Security Guidelines and Policies (Data, Email, Password Protection, Software Installation, Server Security, Remote Access, Wireless Policies, Desktop Policies, Data Retention and Destruction Policies)
- Servicing and Collections (FDCPA, UDAAP, Evaluations, Forms, Documentation - e.g., Demand Letters)
- AML Program (Risk Assessment and Mitigation, OFAC Compliance, KYC, BSA Reporting, Monitoring, Record Keeping, Information Sharing, Partner Requirements)
- Vendor Management Policy (for third parties) (Onboarding, Monitoring, Risk Management, Selection Protocol, Controls, Audits, Security, Reports, Licensing, Indemnification, Liability Management, etc.)
- Advertising and Management Policy (UDAAP, Monitoring Dealers or Third Parties, FCRA)
- Complaint Handling Policy (Documenting, Resolving, Escalation, Tracking, Training, etc.)
- Compliance Management System (Mission, Scope, Goals and Objectives, CMS Overview - policies, training, audits, reporting, etc.)
- Oversee state licensing, registration and reporting periodic updates. Familiar with NMLS and state licensing requirements as they relate to non-bank financial services companies
- Review and draft documentation (where applicable) related to FFC's various financing facilities, ABS, warehouse, etc.
- Offering Documents, Indentures, Indemnity Agreements, Servicing / BUS Agreements, Purchase and Sale Agreements, Trust Formation, Officer's Certs, Note Purchase Agreements, Roadshow materials, etc.)
- Participate and live and telephonic communication with Banks (lenders, whole loan purchases), Rating Agencies, external counsel
- Oversight of regulatory monitoring program through Westlaw
- Oversight of legal and compliance team
The ideal candidate:
Applicants must be reliable, dynamic, sociable and enthusiastic team players; while possessing a positive "can-do" attitude, excellent judgement and communication skills. Applicants must also have great attention to detail and ability to multi-task under the stress of deadlines with a strong desire to help the organization succeed.
Carries out supervisory responsibilities in accordance with the organization's policies and applicable laws. Responsibilities include interviewing, hiring, and training employees; planning, assigning, and directing work; appraising performance; rewarding and disciplining employees; addressing complaints and resolving problems.
Juris Doctorate degree: or 5 years related experience and/or training; or equivalent combination of education and experience. Admission in the Wisconsin bar preferred. Knowledge of Employment Law, a plus, but not required
Office environment with significant time spent sitting, typing and talking on the telephone.