Chief Compliance Officer

February 19, 2021
San Antonio, TX
Job Type


The Chief Compliance Officer (CCO) sets the overall vision and approach for managing Compliance Risk enterprise- wide and bank-wide. This executive oversees and directs compliance programs across the enterprise, including programs such as insurance, investment, banking, AML/OFAC, IT/ cyber, and anti-corruption compliance, and ensures an independent and objective view in the evaluation of compliance across the enterprise. In addition, the CCO provides overall direction to the Compliance department whose key purpose is to provide sound, independent advice and to demonstrate integrity, independent, and professional judgment in protecting the interests of COMPANY.

The CCO is responsible for reporting significant compliance matters to the Board, the Risk Council Committee, Enterprise Compliance and Operational Risk Committee, Bank Compliance Committee (BCC), Operational Risk Committee, and any designated committees of any COMPANY affiliate for which it is determined necessary for achieving effective oversight of the compliance function.

The CCO shall have access to all departments and documentation and be given the necessary resources to carry out his or her responsibilities, including input into compliance specific performance evaluations, compensation, and budgets. The CCO shall have direct access to the Board when escalating critical compliance risks. Further, the CCO shall have the appropriate authority to implement his or her duties and to implement corrective action upon discovering actual or possible compliance-related violations.

Job Requirements

Managerial Responsibilities

  • Manages a diverse team of 600+ Compliance and AML employees.
  • Leads design and implementation of COMPANY’s compliance strategy, taking into account COMPANY’s business strategy and complex regulations and nuanced supervisory expectations, including how they apply in a matrixed commercial environment.
  • Role models COMPANY’s mission, core values, culture and desired behaviors – including a culture of compliance risk management and integrity.
  • Develops talent in the compliance department to deliver performance and results – including the identification, development and retention of talent with requisite compliance and/or ethics capabilities as well as providing leadership and overseeing performance management and staff development activities.
  • Supervises and drives operational planning of the compliance and ethics department – including core business processes and technologies.
  • Oversees funding, budgeting and execution of compliance initiatives and projects across the businesses and legal entities.
  • Holds self and others accountable for meeting commitments by setting and clearly communicating expectations and roles and responsibilities relative to compliance.

Technical and Risk Responsibilities           

  • Ensures that COMPANY and its employees comply with applicable international, federal, state, and local laws and regulations.
  • Promotes an organizational culture focused on effective compliance risk management and adherence to sound internal controls, including standards of conduct for employees at all levels of the company.
  • Confirms that all of COMPANY’s compliance programs (e.g. Enterprise, Insurance, Investment, Banking, AML/OFAC, IT/ Cyber, Anti-corruption, Regulatory Affairs and Testing) are properly structured, cover the appropriate risks, are effectively managed and adequately resourced.
  • Ensures the timely and accurate identification, assessment, measurement and management of all significant or material compliance risks to COMPANY across the enterprise.
  • Confirms that material compliance matters across COMPANY receive appropriate escalation and management attention (e.g. to senior management, LRRC, Risk Council, etc.) in order to achieve effective oversight of the Program related to regulatory actions, the results of compliance assessments and adherence to regulatory internal control and compliance reporting requirements.
  • Oversees the development of corrective action and mitigation plans in response to identified compliance risks or vulnerabilities.
  • Drives development and continuous improvement of core compliance infrastructure such as management oversight, policies, procedures, controls, testing, training, monitoring, reporting, issue management, and recordkeeping.
  • Develops, communicates, and reinforces COMPANY’s compliance-related risk tolerance and risk appetite statements.
  • Effectively challenges the business and leadership team on key decisions with a focus on compliance risk impact.
  • Actively engages front line units to ensure compliance risks are addressed in a timely manner and in alignment with risk appetite/profile.
  • Liaises with regulatory agencies and other internal control groups on compliance related issues -- takes accountability for responding to Matters Requiring Attention (MRAs) issued by supervisory bodies.

Governance Committees

Interacts with or participates in enterprise governance committees, such as:

  • COMPANY Board Risk Committee
  • Enterprise Compliance and Operational Risk Committee
  • Operational Risk Committee


  • Bachelor’s degree is required.
  • Advanced degree such as MBA or JD is preferred.


  • A minimum of 15 years of Compliance experience in a financial institution with a proven track record leading comparable operations and programs is required.
  • A minimum of 10 years of people leadership experience in building, managing and/or developing high-performing teams is required.
  • A minimum of 10 years of relevant experience in a large financial institution ($100 billion +), including 5+ years post-Dodd Frank, in a supervisory role within a compliance department directly interacting with regulators or experience as a regulator (e.g. Commissioned Bank Examiner) is required.

Regulatory Understanding*

Demonstrated understanding of the full spectrum of regulatory actions, including examinations and other supervisory engagement and processes, such as:

  • Dodd-Frank Act
  • Home Owners’ Loan Act
  • Fair Lending laws
  • Texas Insurance Code
  • New York Insurance Law

Federal regulations and supervisory guidance:

  • 12 CFR Part 238 (Regulation LL)
  • 12 CFR Part 252 (Regulation YY)
  • 12 CFR Part 223 (Regulation W)
  • 12 CFR Part 30, including Appendices A through E
  • 12 CFR 9 - Bank Fiduciary Activities
  • 12 CFR 25 -- Community Reinvestment Act
  • 12 CFR Part 46 (Annual Stress Test)

Federal Reserve Supervisory Guidance Documents: 

  • SR 12-17 (Consolidated Supervision Framework for Large Financial Institutions)
  • SR 08-08 (Compliance Risk Management Programs)
  • SR 14-9 (Incorporation of Federal Reserve Policies into the Savings and Loan Holding Company Supervision Program and related applicable guidance)
  • Bank Holding Company Examination Manual
  • Federal Reserve proposals concerning Board effectiveness and core principles of effective senior management, management of business lines, and independent risk management and controls
  • OCC Supervisory Guidance Documents:  Large Bank Supervision Handbook; Corporate and Risk Governance Handbook; and key OCC bulletins (Model Risk Governance; Model Risk Management; New Products and Services Risk Management; Third Party Risk Management)
  • FFIEC: BSA/AML Manual; IT/Cyber Handbooks
  • CFPB: Consumer Protection Regulations; UDAAP

*Regulatory understanding is for illustrative purposes. Roles would need an understanding of all federal and state laws and regulatory guidance applicable to the organization and responsibilities of the role.

Note: The above statements are intended to describe the general nature and level of work being performed by employees in this position. They are not intended to be an exhaustive list of all duties, responsibilities and qualifications of employees assigned this job.


Industry certification such as Certified Regulatory Compliance Manager (CRCM) certification is preferred.



COMPANY has an effective process for assessing market data and establishing ranges to ensure we remain competitive. You are paid within the salary range based on your experience and market position. The salary range for this position is $271,900 - $489,600.

Employees may be eligible for pay incentives based on overall corporate and individual performance or at the discretion of the COMPANY Board of Directors.

Long Term Incentive Plan: Cash payment for Executive level roles only, representing a cash payment which is both time and performance based.

Stipend: As an EMG Member, you will receive an annual stipend (amounts determined by level) which will be paid in quarterly installments.

Medical Stipend: As a Senior Officer (SVPs and above), you will receive an Annual Medical Stipend for you and your Spouse

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