Restitution Compliance Advisory Lead

Restitution Compliance Advisory Lead

The Restitution Compliance Advisory Lead within the second line of defense is responsible for developing, participating in, and executing on Compliance Oversight of the Customer Restitution Program for Comerica, relying upon a strong and deep working knowledge of Regulatory expectations, and applicable laws and regulations. This individual will report directly to the Deputy Chief Compliance Officer and work across the compliance organization and the Customer Restitution team to establish processes related to second line oversight and validation of customer restitution activities. The Restitution Compliance Advisory Lead will advise on the development and execution of a detailed Restitution Action Plan, which addresses the lookback period to be utilized in identifying impacted customers, the methodology by which restitution will be provided to impacted customers, and communication strategies for all internal and external stakeholders. The Restitution Compliance Advisory Lead will be responsible for validation activities, including ensuring the impacted population has been correctly captured and that all financial restitution amounts (as applicable) have been accurately calculated. The Restitution Compliance Advisory will offer strategic guidance on interpreting new laws, rules, and regulations; developing new policies and procedures; and remediating existing issues. Additionally, this role will help create a strong compliance culture across the Bank by assisting in the development and enhancement of compliance program pillars.

Position Responsibilities:
Restitution Management and Strategy

• Assist in the development and documentation of Restitution Compliance Advisory roles and expectations.
• Assist in the development and documentation of the Restitution Compliance Advisory Process, encompassing all aspects of Restitution Validation.
• Execute validation of Restitution populations, including all impacted customers and financial restitution calculations (as applicable) have been accurately and completely captured.
• Develop and implement a data strategy to validate Remediation plan components, including full population identification, automated testing strategies, and identification of operational efficiencies.
• Partner with first line of defense to define compliance participation and validation of Consumer remediation plans.
• Collaborate with Compliance Advisory team on execution and review of Compliance Risk Assessment (CCRA) and Risk Assessment (RCSA).
• Partner with Compliance Testing and Risk Assessment teams to review and adjust oversight to account for customer restitution lookbacks and activities and/or emerging risk.
• Escalate results to senior leadership in accordance with Comerica's policies and procedures.
• Document findings and remediation plans in accordance with Comerica's Issue Management process.
• Collaborate with colleagues including the wider Second Line of Defense Teams, First Line of Defense business units, and Third Line of Defense Audit Teams.

Regulatory Compliance

• Provide advice, guidance, and oversight to the First Line of Defense business units, and Second Line of Defense Teams by possessing strong working knowledge of the applicable Regulatory expectations, rules and regulations.
• Identify, measure, and escalate compliance risk issues to management as necessary.
• Provide restitution management and validation expertise to the lines of business on developing restitution plans and effectively managing customer impact and risk.
• Maintain up to date knowledge of changing regulatory requirements and Comerica's business model to identify changes that might impact Comerica's compliance framework and remediation plans.

Monitoring, Audits and Exams

• Assist in preparing/coordinating deliverables accurately and timely (i.e. responses, artifacts).
• Assist as needed in preparing responses to inquiries.
• Participate in other testing and monitoring activities such as KPI/KRI reporting, CCRA activities, audits, etc.
• Other duties as assigned