Job Description: Chief Compliance Officer
FLSA Classification: Full-Time Exempt
Reports to: Ejola Cook, Senior Vice President, Chief Legal Officer

Position Description and Objective

The Chief Compliance Officer provides development, direction, and oversight of the company’s compliance management system and programs.

Job Specifications: Essential Functions

Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.

The Chief Compliance Officer is responsible for identifying and assessing areas of compliance risk, to include, but not limited to:

Primary Job Duties

• Coordinate with the Chief Information Officer to conduct an information technology scan not less than semi-annually.
• Regularly review compliance policies and procedures. Recommend appropriate revisions and modifications. Advise Executive Management and the Board of Directors of potential compliance risk areas and changes in legal or regulatory mandates.
• Formalize and monitor a system to enable employees to confidentially report noncompliance without fear of retribution.
• Ensure the reporting system is adequately publicized and that allegations of noncompliance are investigated and responded to promptly. Document all steps.
• Develop or approve 3rd party compliance educational programs for employees, agents, contractors, or others working with the organization. Manage these contracts to ensure compliance and effectiveness.
• Coordinate with administrative leadership to provide a communication plan that will adequately inform staff on an ongoing basis to ensure that they have the requisite information and knowledge of regulatory issues and requirements to carry out their responsibilities in a lawful and ethical manner.
• In collaboration with human resources and legal, implement a comprehensive anti-harassment training program. Follow state and federal guidelines.
• Ensure control mechanisms are in place to reasonably determine that persons either promoted to or hired in management and certain other sensitive and/or responsible positions (to be designated) do not have a propensity to violate federal or state laws and regulations or engage in improper or unethical conduct in their designated areas of responsibility.
• Provide input and direction to human resources policies and procedures development, performance appraisals and incentive programs to ensure that improper conduct is discouraged and that support of and conformity with company compliance programs are part of any performance evaluation and every job description.
• Collaborate with Executive Management and human resources and, as appropriate, outside legal counsel, when conducting or authorizing a compliance investigation. Investigations need to follow company policies and procedures.
• Consult with the human resources department to ensure that there is an active policy in place for disciplining instances of noncompliance (including the failure to prevent, detect, or report any noncompliance) appropriate to the nature and extent of the deviation and ensure consistency in the application of disciplinary action, including termination.
• Oversee and document resolution of investigations and other issues including corrective action plans, and efforts to redress, as needed.
• Complete compliance vetting on agents and vendors. Provide training as necessary.
• Develop productive working relationships with all levels of management
• Present periodic and annual reports on compliance and risk management status to the Board of Directors and/or Executive Management.
• Report on a regular basis to the compliance/risk committee on matters involving compliance concerns. Additionally, the compliance officer at his or her discretion is expected to regularly report issues to the Board of Directors, principal, or Executive Management.
• Coordinate with the Chief Information Officer in all data security breach response programs and other crisis management teams for any non-compliance or risk issues that may develop or requires immediate multi-disciplinary action. Ensure that the Data Breach Response Team follows the FTC guidelines.
• Ensure that all vendor and agent contracts contain compliance expectations and are knowledgeable of the steps to report or file compliance concerns or misconduct.
• Represent the Compliance Committee, include developing appropriate agendas, reports, and information as directed from time to time, as needed.
• Track individual completion status of educational and compliance training on all relevant topics and policies. Evaluate the effectiveness of training based on level of compliance.
• Perform other duties as assigned by Executive Management.
• Update, at least semi-annually, all policies dealing with Safeguards Rule, Identity Theft Prevention Program (Red Flags Rule), Disposal Rule and all other applicable federal and state requirements.

Job Specifications: Education and Experience Required

• A minimum of five years of experience as a Chief Compliance Officer or a Dealership Compliance Officer.
• A minimum of a bachelor’s degree from an accredited college or university. Master’s degree preferred.
• F&I, sales, advertising, and/or dealership management experience desirable.
• Certification by AFIP and/or ADCO.
• Auditing, CPA or government regulatory experience a plus.

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