Head of Consumer and Lending Compliance

About the role

This leadership role at Gemini involves overseeing the consumer compliance program for the company's innovative crypto products, including credit cards and other banking and lending offerings. The Head of Consumer and Lending Compliance will act as the primary advisor for these products, guiding their development, changes, and marketing to ensure regulatory adherence. This position demands a strategic approach to compliance within a rapidly evolving crypto environment.

The successful candidate will manage a team of compliance professionals, directing their efforts in monitoring, testing, complaint management, and third-party oversight. Regular reporting to the Board of Managers and other governance committees is a key responsibility, as is serving as the main liaison with sponsor bank partners. The role also involves responding to audits, regulatory inquiries, and overseeing risk assessments and remediation plans for consumer banking products.

Success in this position means maintaining a robust compliance management system, staying current with regulatory changes, and proactively integrating best practices into Gemini's operations. The Head of Consumer and Lending Compliance will ensure that all consumer-facing communications and vendor relationships meet compliance standards, providing expert advice to staff on relevant policy areas.

The base salary for this role in New York State ranges from $150,500 to $215,000, not including discretionary bonuses or equity.

Skills that matter here

• UDAAP: This role requires deep knowledge and application of UDAAP regulations to oversee the consumer compliance program and advise on product development.
• ECOA: Expertise in ECOA is essential for ensuring fair lending practices and managing the company's fair lending program.
• FCRA: Understanding FCRA is necessary for advising on credit-related products and managing consumer data compliance.
• TILA: This role involves applying TILA regulations to guide credit card and lending product development and compliance.
• CRCM: A CRCM certification is preferred, indicating a specialized background in regulatory compliance management relevant to this role.
• Juris Doctor: A Juris Doctor degree is preferred, suggesting a strong legal foundation beneficial for navigating complex financial regulations.

Who this role suits

• Someone with a strong background in traditional financial compliance who is ready to apply that expertise to the crypto space.
• An experienced leader capable of managing a team and providing strategic vision for a compliance management system.
• A detail-oriented professional who stays current with regulatory changes and can translate them into actionable compliance strategies.
• An individual who thrives in a fast-paced environment and can advise on innovative product development while ensuring regulatory adherence.

From the employer

• Oversee the consumer compliance program in accordance with applicable laws and regulations (e.g., UDAAP, ECOA, FCRA, TILA, etc.)
• Serve as the primary advisor to the credit card business and other horizon banking and lending products, providing guidance on new product development, product changes, and marketing initiatives
• Manage a team of compliance professionals responsible for monitoring and testing, complaint management, third party oversight, issue management, compliance reporting, and customer-facing communications, among other areas
• Provide regular reporting to the Board of Managers and other governance committees
• Serve as the primary liaison between Gemini and its sponsor bank partner
• Respond to internal and external audits, examinations, and regulatory inquiries related to credit card operations
• Oversee risk assessments for consumer banking products, identifying potential areas of risk and working cross-functionally to manage such risks
• Serve as the Fair Lending Officer overseeing the company’s fair lending program
• Ensure proper oversight of vendors and other third parties that present potential compliance or regulatory risk
• Oversee remediation plans for high priority issues to ensure timely remediation and remedy of any compliance-related issues
• Remain up-to-date on regulatory changes and landscapes, best practices and developments in the industry and ensure our implementation is both compliant and forward thinking
• Provide timely and accurate advice and guidance to the Gemini’s staff on issues arising from compliance policy areas and subject matter within the responsibility of the Compliance Department

• Bachelor's degree. CRCM or Juris Doctor preferred
• 10+ years of compliance experience in credit, banking, fintech, or other financial regulatory compliance industry and at least 4+ years of experience overseeing a consumer compliance program is a must
• Experience supporting a fast-scaling business
• Possess deep knowledge and real world application of all lending and banking laws and regulations including UDAAP, TILA, TISA, ECOA, FCRA, EFTA, MLA, SCRA, GLBA, and CAN-SPAM
• Proven track record of providing oversight and strategic vision for the entirety of a Compliance Management System (CMS)

• Competitive starting pay
• A discretionary annual bonus
• Long-term incentive in the form of a new hire equity grant
• Comprehensive health plans
• 401K with company matching
• Paid Parental Leave
• Flexible time off

Salary Range: The base salary range for this role is between $150,500 - $215,000 in the State of New York. This range is not inclusive of our discretionary bonus or equity package. When determining a candidate’s compensation, we consider a number of factors including skillset, experience, job scope, and current market data.