MICHAEL CHIARELLA

***** **** ****** ******, ****, Arizona 85212

727-***-****

E-mail: ac8irs@r.postjobfree.com

PROFESSIONAL EXPERIENCE

Director of Compliance, Cascade Financial Services, Gilbert, Arizona, 6/18 to present

●Responsible for compliance with all applicable laws and regulations in Originations, reporting to General Counsel

●Created regulatory system controls in Encompass, Cascade’s Loan Origination System

●Oversee Disclosure Desk to ensure initial disclosures, redisclosures and Adverse Action Notices are compliant and meet regulatory timing requirements

●Provide ad hoc regulatory training in areas such as HMDA, OFAC, TRID and AML

●Provide regulatory guidance and advice to the business around production related issues which have an actual or potential regulatory impact

●Stood up monitoring program to ensure compliance in areas such as TRID (Loan Estimate and Closing Disclosure), RESPA, E-Sign, ECOA Adverse Action, FCRA Adverse Action and OFAC

●Create and revise Policies and Procedures such as TRID, Complaints, HMDA, ECOA Valuations Rule, CIP, Change Management, and Compliance Management System

●Stood up Change Management Program

●Created AML Risk Assessment

●Created suite of Control Reports to assist with compliance in areas such as AML, Adverse Action, Change of Circumstance, HMDA, High Cost Loans, and OFAC

●Responsible for tracking, investigation and resolution of all consumer complaints

Executive Vice President, Servicing Risk and Controls, The Money Source, Tempe, Arizona, 4/18 to 6/18

●Regulatory Executive responsible for compliance with all laws, regulations and investor requirements in the First Line of Defense for the Servicing Organization, reported to the President of Servicing

●Oversaw the creation of Master Risk Assessment for Servicing which mapped all identified controls to applicable regulatory requirements with inherent and residual risk ratings

●Oversaw the creation of an Issues Management Program Document which outlined metrics and milestones associated with the resolution of control failures and process breaks

●Created Operating Model which defined the roles and responsibilities within the various functional areas of the Servicing Risk and Controls Organization

Executive Director of Regulatory Implementation and Execution, USAA Bank, San Antonio, Texas, 1/17 to 4/18

●Stood up a regulatory organization in the First Line of Defense with 120 full time employees which was aligned with the OCC's Heightened Standards covering Originations, Servicing, Issue Management, Regulatory Affairs and Testing, reported to the President of the Mortgage Company

●Attained highest employee satisfaction score of any executive in the Mortgage Company

●Responsible for a seventeen million dollar ($17,000,000) annual budget

●Regulatory Executive responsible for managing nine (9) exams (over a four (4) year period) with the CFPB and OCC, none of which resulted in fines, civil money penalties, restitution, Consents Orders or enforcement of any kind

●Created Operating Model which defined the roles and responsibilities within the various functional areas of the Regulatory Implementation and Execution organization

●Established Advisory Program for Originations and Servicing to provide regulatory guidance to the business and to assist with the implementation of any regulatory mandates

●Lead Regulatory Executive for Home Equity Servicing Transfer of approximately 60,000 loans

●Regulatory Executive responsible implementation of the new HMDA Rules which included training, procedures, regulatory guidance and system testing

●Stood up Originations and Servicing Quality Control Teams which performed monthly testing in areas such as TRID, Bankruptcy, SCRA, Adverse Action and Loss Mitigation

●Created Home Equity and First Mortgage Servicing Manuals with checklists associated with the various chapters for testing by the Servicing Quality Control Team

●Created Master Risk Assessments for Originations and Servicing which mapped all controls to individual regulatory requirements and provided inherent and residual risk ratings (presented to CFPB and OCC)

●Responsible for the resolution of all Originations and Servicing related issues within established protocols which were tracked through the Issues Management Process

Executive Director of Compliance, USAA Bank, San Antonio, Texas, 4/14 to 1/17

●Stood up compliance organization which was responsible for all lending at USAA from a compliance standpoint which included First Mortgage and Home Equity, both from an Originations and Servicing standpoint, as well as Consumer Lending, Credit Card, and Member Debt Solutions (“MDS” Loss Mitigation Services across all products which included the Home Equity Servicing portfolio), reported to the Bank Chief Compliance Officer

●Oversaw and managed an organization of approximately sixty (60) Compliance professionals (including consultants) which provided regulatory advice and guidance, supported system testing and any ongoing remediations; reviewed and approved training materials and procedures as well as support any special projects as assigned

●Lead Regulatory Executive on successful implementation of a new Loan Origination System (Cadence) which included responsibility over compliance testing, procedures, training, controls, assessment of defect severity and ensuring compliance with all regulatory requirements

●Lead Regulatory Executive on successful implementation of TILA-RESPA Integrated Disclosures (“TRID”) which included responsibility over all regulatory guidance, peer reviews, revision of procedures, development of training materials and system testing

●Lead Regulatory Executive on successful implementation of Servicing Transfer which was completed in three phases in First Mortgage (250,000 loans), included end to end testing; standards and procedures reviews as well as extensive loss mitigation and SCRA testing

●Created Matrix based upon CFPB Bulletin for Serving Transfers to ensure all requirements were being met and that adequate controls to mitigate any risks associated with the transfer were in place

●Implemented two (2) Adverse Action projects, one in First Mortgage and another in all other remaining Bank products to ensure compliance with ECOA as well as FCRA and to establish consistent bank wide standards for application declines

Vice President, J.P. Morgan Chase, Tampa, Florida, 2/12 to 4/14

●Compliance Lead on successful implementation of Mortgage Express, the Mortgage Bank’s new loan origination system, reported to the Chief Compliance Officer of the Mortgage Company

●Successfully implemented all the salient provisions of Dodd Frank including but not limited to Qualified Mortgage

●Provided guidance and oversight to the project team and work stream leads to ensure compliance with state and federal truth in lending laws, including but not limited to Reg. B, RESPA and Reg. Z

●Reviewed and assessed criticality, as well as risk from both a regulatory and operational standpoint with respect to those issues/defects that are identified on loans that are in production

●Oversaw system testing in all environments for both functional and end to end test scripts to identify any defects with regulatory impacts which need to be remediated prior to code being deployed into production

Vice President Real Estate, J.P. Morgan Chase, Tampa, Florida, 10/10 to 2/12

●Prepared and maintained weekly Pipeline Report which tracked the milestone dates for approximately 140 projects to ensure accurate reporting

●Conducted kickoff calls/meetings for newly activated projects to review salient points of deal and establish baseline dates

●Reviewed leases, purchase agreements and tracked critical dates to remain compliant with legal obligations and responsibilities

●Maintained continuous and consistent level of communication with Market Directors of Real Estate and Project Managers regarding milestone dates and project/deal issues

●Identified and escalated any potential risks with projects, including but not limited to existing tenancies, transactional issues and entitlements

Senior Compliance Officer, J.P. Morgan Chase, Tampa, Florida, 11/09 to 10/10

●Managed special projects in connection with Qualified Written Requests under RESPA to ensure compliance with the Cranston Gonzalez Act

●Addressed and resolved high risk escalated customer complaints regarding default, loss mitigation, loan modifications, foreclosures, bankruptcies, Fair Lending, Fair Debt Collection Practices Act, escrow and servicing related issues

●Provided support and assistance to Home Loan Executive Office (“HLEO”) regarding responses to servicing related Attorney General complaints

●Prepared reports to assess the status of complaints in the HLEO to establish priorities, production goals and to allocate resources appropriately for maximum efficiency for the Escalated Complaints Team (“ECT”)

●Identified risk potential and conducted legal/compliance letter reviews of HLEO responses to escalated customer complaints regarding servicing related issues

Operations Section Manager, Estate Management, J.P. Morgan Chase, Tampa, Florida, 9/08 to 11/09

●Ensured compliance with Service Level Agreements, Estate Management Processing Procedures, IRS Regulations and state laws pertaining to estates.

●Ensured compliance with all applicable regulations regarding deposit, brokerage, and qualified accounts

●Reviewed and verified the sufficiency of various legal documents, including but not limited to trusts, small estate affidavits, letters testamentary, powers of attorney, adoption agreements and beneficiary designations

●Addressed and resolved escalated customer service issues involving distributions to beneficiaries and fiduciaries

Assistant Vice President, Compliance, J.P. Morgan Chase, Tampa, Florida, 2/04 to 9/08

●Conducted compliance reviews with User Acceptance Testing (“UAT”) for new loan origination system, CLOSR to ensure compliance with state and federal truth in lending laws

●Researched various legal issues and decisional law, as assigned, including but not limited to Truth in Lending Act, Regulation Z, Equal Credit Opportunity Act, Regulation B, Preemption Doctrine, Fair Lending, Fair Debt Collection Practices Act, salability of loans and due diligence issues.

●Researched and analyzed new legislation regarding state compliance, pertaining to both production and servicing issues, and advised various channels of business, including retail and correspondent, on actual or potential impact

EDUCATION AND ACADEMIC HONORS

●Juris Doctor Degree, Seton Hall University School of Law, Newark, New Jersey

●Member of the Seton Hall Law Review, Seton Hall University School of Law, (membership comprised of less than 3% of the student body)

●Published Author of Casenote entitled “Applicability of Res Ipsa Loquitur to the Commercial Landowner” in Seton Hall Law Review

●Bachelor of Science Degree in Business Administration, Seton Hall University, South Orange, New Jersey, four years of Intercollegiate Football; Recipient Most Improved Player and Player with the Greatest Will to Win (only player to win two of the three annual major awards given by the program)

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