Chad M Polen

Background

Chad has partnered with clients in the highly regulated financial services industry, bringing industry insights and peer perspectives to advance their compliance programs and improve risk management through design and implementation of automated compliance testing and innovative digital compliance services. Chad is an expert in optimizing enterprise-wide compliance and risk management programs and preventing and remedying supervisory and enforcement matters. He has proven track record of working side-by-side to remediate instances of customer harm and to improve the customer experience.
 
Professional and industry experience

• Developed and executed a scalable compliance testing strategy to enable integration of regulatory functionality in the design and launch of a digital bank. Key activities included assessing requirements mapping and identifying configuration and control gaps, and designing a testing program covering key deposit and savings account features including account opening, check cashing, overdrafts, fees, statement generation, etc.
  
• Designed the Compliance UAT program for the implementation of a new loan origination system. The scope included testing of system functionality related to numerous consumer protection regulations including but not limited to TRID, HMDA, ECOA, FCRA, E-Sign, Flood requirements, as well as state and federal anti-predatory lending regulations.
  
• Led the implementation of an enhanced compliance risk assessment (CRA) process across a bank’s lines of business and executed CRAs including identification of inherent risks, modifiers, and residual risks to auditable units and providing regulation-level risk ratings.
• Coordinated with the internal audit department of a top 10 bank in the development of a response to an OCC consent order. Engagement was to ensure the effectiveness of control enhancements related to areas of weakness identified in loan servicing, loss mitigation and foreclosure activities.
• Managed a conduct, culture, legal, and compliance assessment and review at a large international investment bank and a top professional services firm focused on transforming the governance and risk management programs in response to issues identified by both regulators and internal risk management.
• Led numerous compliance reviews across the consumer space to identify requirements, risks, and controls, and perform testing inclusive of UAT testing for consumer compliance regulations (ECOA, FDPA, FCRA, HMDA, RESPA, TILA, TCPA, etc.)
• Executed exam readiness reviews that identified regulatory requirements, performed deep-dive process reviews of monitoring and testing programs, and evaluated control design, effectiveness and sustainability.
• Led projects at leading P2P payment transfer companies including projects focused on the identification and mapping of applicable regulatory requirements, control design and gap assessments, test script development, and deep-dive reviews of the complaint program.
• Led the development of regulatory response and remediation plans as well as the design of a Case Management tool and custom review methodologies integrating innovative technology solutions to facilitate multiple large-scale, complex regulatory look back reviews (e.g., Flood, SCRA, CARD Act) to identify and quantify consumer harm.
• Led the development of priority solutions and the delivery of services to several top lenders in support of the Paycheck Protection Program (PPP). Solutions included capacity planning, application and forgiveness processing, technology enablement, investigations, methodology design, and quality control processes, post-production QA and remediation, and PPP methodology and program reviews.