S&T Bank

Fair and Responsible Banking Officer I

S&T Bank

Aug 5th, 2022
S&T Bancorp is the bank holding company for S&T Bank, which serves customers from some 60 branch offices in western Pennsylvania. Targeting individuals and local businesses, the bank offers such standard retail products as checking, savings, and money market accounts; CDs; and credit cards. Business loans, including commercial mortgages, make up about three-fourths of the company's loan portfolio; the bank also originates residential mortgages, construction loans, and consumer loans. Through subsidiaries, S&T Bank sells life, disability, and property/casualty insurance; provides investment management services; and manages the Stewart Capital Mid Cap Fund.

The company's greater dependence on commercial real estate loans (nearly half of its loan portfolio) during the recession exposed it to larger credit risks, loan charge-offs, and nonperforming loans. Although revenues remained rather steady, net income plummeted some 97% in 2009. As the economy began showing signs of recovery the following year, though, so did S&T Bancorp. A substantial drop in loan loss provisions and net charge-offs helped the company improve results. However, a smaller loan portfolio and new regulations limiting service fees cut into the company's earnings overall in 2011. Although both interest and noninterest revenues shrunk 8% that year to $209.1 million, net income grew 9% to $47.3 million (though still short of the $60.2 million it netted in 2008).

Its rebound has been not only attributable to the strengthening economy, but also to a new strategy, which was designed to return the company to higher performance levels. S&T refocused its efforts on all of its main business lines: banking, credit, insurance, and investments. The company also also began to focus on market-specific needs by creating six geographic divisions. By introducing new mobile banking products and pushing for increased electronic delivery of its services, the bank has also saved a significant amount of money.

Retaining customers and attracting new ones is another way S&T has grown deposits. The company seeks to expand organically and through acquisitions. It added some 10 offices to its network when it bought fellow western Pennsylvania bank IBT Bancorp in 2008 and added another eight branches in central Pennsylvania through the 2012 acquisition of Mainline Bancorp. S&T now plans to acquire Gateway Bank, which will add two branches in the greater Pittsburgh area.
800 Philadelphia St.
Indiana PA, United States 15701

Main Office:800 Philadelphia Street, Indiana, PA 15701

(Multiple Locations Available)

Work Days and Expected Hours:

Monday – Friday:8:00 AM – 5:00 PM

(Additional hours as necessary to meet the objectives of the department)

Function:This position requires compliance responsibility and subject matter expertise in the areas of HMDA, ECOA and Regulation B, FHA, and UDAAP, and general knowledge of SCRA, FDCPA, FCRA and Truth in Lending. The Fair and Responsible Banking Officer is responsible for the Fair and Responsible Banking Program development and implementation, including compliance training and monitoring and testing in the areas of Fair Lending and UDAAP. The Fair and Responsible Banking Officer will conduct reviews of data, consumer complaints, and supporting program documentation to effectively identify trends and perform root cause analysis. The ideal candidate will have experience with risk assessments, mitigating controls, and the development of management reporting, in addition to subject matter expertise in fair lending laws and regulations. Successful management includes engagement of team members to achieve strategic goals and framework sufficient for the size and complexity of a growing organization. This position will support the CRA & Fair Lending Officer in the execution of the Bank’s strategic goals and regulatory compliance requirements.

Duties and Responsibilities:

  • Provides strategic leadership of programs including the following:
    • Regulatory change management
    • Emerging risk identification
    • Program development road map
    • Policy and procedure development and ongoing maintenance
    • Recommend change to products, services, and delivery channel to ensure the Bank has products to service all customer demographics and minority populations (i.e., Majority Minority (“MM”), Women-Owned Business applicants and/or customers).
    • Assess, develop and provide fair lending training to meet individual business unit and corporate requirements.
    • Committee participation and sub-committees as needed
    • Creation of management and board reporting
    • Maintain strong industry networking
    • Provide regulatory oversight and guidance for the Home Mortgage Disclosure Act (HMDA) data collection.
    • New and existing vendor risk assessment
    • Reply and aid business unit questions and situations on fair lending risks
  • Analyzes program performance.
    • Monitors and tests program elements for evidence of redlining; perform monitoring for steering, discrimination, and unfair, deceptive or abusive acts or practices.
    • Designs the tests components, data preparation, fair lending model development, and documentation in order to investigate potential fair lending risk.
    • Determines appropriate course of action based on comparative file review results, including root cause analysis of any violations.
    • Assesses fair lending risks by preparing periodic fair lending risk assessments of the bank and applicable business units.
    • Assists in the coordination of internal audit and regulatory examinations, including advance preparation and follow-up on open compliance issues and observations, and develop written responses as needed.
    • Administers fair lending statistical reviews and understand results including:
      • Regression analysis
      • Statistical correlation
      • Match-pair analysis
      • Pricing and Underwriting Exception reporting and analysis
    • Assesses residual compliance risk and document findings related to vulnerabilities. Create action plans with appropriate measures to lower residual risk to an acceptable level.
    • Analyzes products and processes:
      • Change Management – product and pricing
      • Complaint analysis
      • Fairness analysis
    • Acts as liaison with lines of business for:
      • Communication of risk and needed action plans
      • Creation and consulting on any action items
      • Marketing coverage – fair lending
      • Change Management – Coordinate with lending lines of business to evaluate proposed business changes, including new or modified products/services, new or modified policies, procedures, processes, or systems

Physical Demands:

Approximately 90% of the day is spent operating a keypad device. The primary parts of the body involved in performing these tasks are fingers, thumbs and hands. Must be able to occasionally lift and/or move up to 20 lbs. Use of electronic equipment is required 100% and use of a mouse, if requested, 80% of the business day. Specific vision requirements include close vision of 18”-20” for computer work. 100% of the business day requires sitting straight. Reasonable accommodations may be made to enable individuals with disabilities to perform essential function.

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