Risk Management

Bruce L. Custer

Chandler, AZ

E-mail: ********@***********.***

LinkedIn: www.linkedin.com/in/brucecuster

SUMMARY

Extensive background in operations, compliance and risk management within diverse facets of the banking industry that deliver strong results aligned with the business risk appetite. Areas of key strengths include:

RISK ASSESSMENT – Twenty+ years of auditing/compliance/risk experience in operational, financial, and compliance assigned areas/functions.

PROCESS ENHANCEMENT – Innate ability to analyze operational functions/processes to reduce risk while facilitating efficiency and understanding goals and implementing improvements to reach objectives.

PROJECT MANAGEMENT – Experience with ensuring multiple, diverse projects are managed simultaneously, within budget and schedule. Possess excellent problem-solving capabilities with proven ability to interrelate effectively with management, employees, clients, and to facilitate appropriate action/remediation plans, and address needs or problems on a daily and strategic basis.

ANALYTICAL SKILLS – Substantial proficiency in Microsoft Word, Visio, Excel, and Power Point business operations that facilitates the collation of data into concise executive summaries. Possess excellent writing and communication skills.

CLIENT MANAGEMENT: Three decades of operational management experience partnering with line of business management, vendors, pharmaceutical reps, and consumers.

WORK HISTORY

USAA -- Chandler, Arizona

Business Risk and Controls Advisor Senior (September 2019 – Current)

Primary Focus: Chief of Staff Issues Management

oAnalyzing, validating, and monitoring Line of Business issue status to identify/assess gaps and concerns

oFacilitating Weekly Issue Management Sync Meetings with the First and Second Lines of Defense to ensure proper identification and assessment of current and potential risks, and to keep the focus on regulatory and compliance-related issues

oFacilitating lines of business requests for new issues, corrective actions, risk acceptances, due-date extensions, and maintaining strong adherence to issue and system of record Service Level Objectives

oPerforming Quality Assurance audit reviews for all complaints correspondences sent to the CEO

oParticipating in Product and Risk Compliance Inventory (PRCI) activities

oParticipating in Risk and Control Self-Assessment (RCSA) activities

oPerforming Quality Assurance audits on complaints received by the CEO

WELLS FARGO BANK, N.A. -- Chandler, Arizona

Operational Risk Consultant (April 2019 – September 2019)

Primary Focus: Enterprise Technology Issues Management

oAnalyzing, validating, and monitoring divisional issue status to identify/assess gaps and concerns

oFacilitating divisional requests for new issues, corrective actions, risk acceptances, and due-date extensions

EARLY WARNING SERVICES -- Scottsdale, Arizona

Operational Risk Manager (July 2017 – April 2019)

Primary Focus: Performing validation of identified operational and compliance risk controls to ensure they have adequate governance, evidence of execution, and appropriate monitoring and escalation.

oIndependently identify risk through undefined processes or ways that are not pre-determined

oDocument validation results, prepare work papers to evidence validation methods, and draft final reports for customers summarizing validation results

oEnsure issues are properly reported to business areas and remediated appropriately

oPerform and support detailed data analysis to include trending and issue identification

oIdentify emerging risks, process improvements, or areas for increased training through the analysis of results

oResponsible for building and maintaining relationships with business partners while adhering to the highest ethical standards required for independent validation

oManage work across organizational lines to achieve results and manage competing priorities.

oSupport procedure reviews and document updates

MUFG UNION BANK -- Tempe, Arizona

Vice President; Retail Senior Operational Risk Specialist (June 2016 – July 2017)

Primary Focus: Enhancing and evolving the Business Environment & Internal Control Factors:

oPerformed control and issue validation testing

oPartnered with subject matter experts to update/revise process flows and Product & Service self-assessments per required schedule ensured an end-to-end view of cross-organizational process risks and controls and looked for opportunities to consolidate/streamline similar processes

oEvaluated risk levels with respect to the Operational Risk Management Risk Radar, business strategies, internal loss experience, external loss data, identified issues and other risk metrics, in addition to documenting the evaluation in the risk rating rationales (inherent risk vs. residual risk)

oAnalyzed the Risk & Control Self-Assessment (RCSA) data to look for change opportunities and to drive change in the business where controls need improvement leveraged the RCSA where process change occurred to ensure the right controls are in place

oCompleted the summary risk reports and ensured report content was accurate and risk ratings are supported by controls and other data

oDocumented action plans for high-risk issues monitored and reported on past due and repeat issues

oMaintained key risk metric (KRM) inventories for all business-specific high inherent risks evaluated and reported on threshold breaches evaluated KRMs against large losses/risk events for validity of the KRM with respect to the risk

oResponded timely and took corrective actions in response to Quality Assurance comments as needed

oWorked with line of business management to enhance or change controls where needed based upon the root cause analysis and followed through to ensure corrective actions were taken to address that root cause

oParticipated in weekly/monthly meetings to provide essential input on areas of emerging and increasing risk

oTracked/analyzed/mitigated internal Losses and aligning with processes/risks/controls

oTracked/analyzed/mitigated external losses for pertinence to line of business processes

BANK OF AMERICA / COUNTRYWIDE (2002-2016)

BANK OF AMERICA -- Chandler, Arizona

Assistant Vice President – Operational Risk (August 2010 – May 2016)

Primary Focus: Risk Control Self-Assessment, Work Area Privacy Assessments, Quality Assurance Testing, Appraiser Independence Reporting. Primary Responsibilities included (but not limited to):

oMaintained effective relationships with key business partners and provided excellent customer service

oIndependently analyzed, validated, and monitored management data and reports to identify/assess key risks, controls, action plans and ensured that they are within established risk appetite thresholds

oIdentifying 54 risks over 33 lines of businesses in 2014 and helped implement Go-to-Green plans

oParticipated in the approval of strategies, business processes, and change initiatives

oDesigned and assisted in the implementation of a risk framework that ensured appropriate policies, procedures and controls were in place for all business units

oMonitored, validated, and challenged the effectiveness of business controls, processes, and performance through routine and random testing

oEnsured the implementation of quality resolutions for sustainable line of business remediation

oReduced privacy compliance error rates from 5.98% (red) to under 3% (green) in 2015

oCreated strategies to manage, organize, solidify, and bring consistency/cohesion to fragmented areas

oPartnered with line of business work streams to ensure accuracy/accountability

oMentored and imparted leadership qualities to senior analysts for cascading affect

oImparted better cognitive/analytical strategies to team members to prepare them for the next level

oUtilized professional writing skills to enhance monthly executive reporting/”All-Hands Calls” requisites

oEffectively interfaced cross-functionally with team to accomplish deliverables timely and accurately

oPlaying an integral role in the processing/completion of requests for the OCC Consent Letter, the Sidley Austin Legal Counsel Project (Reg AB), the Investor Disclosure Project (Dodd Frank), CIT Issue 100***-****** (Adverse Action Letters), the Patrick Hedges Investor Relations request, and various other high-priority company projects.

oRecommending and creating a repository for all process maps/key controls received from the LMT LOBs pertaining to the list of Business Process Non-negotiable Rules

oAssisting in the identification of quality control and quality assurance processes associated with the LOBs

oAssisting in the identification of any metrics or measurements used to ensure the timely testing and overall effectiveness of the key controls

oMaintaining effective relationships with key business partners and provide good customer service

oIndependently analyzing, validating, and monitoring management data and reports to identify/assess key risks, controls, action plans and ensuring that they are within established risk appetite thresholds

oParticipating in the approval of strategies, business processes, and change initiatives

oDesigning and assisting in the implementation of a risk framework that ensures appropriate policies, procedures and controls are in place for all business units

oMonitoring, validating, and challenging the effectiveness of business controls, processes, and performance through routine and random testing

oEnsuring the implementation of quality resolutions to ensure sustainable line of business remediation

oCreating strategies to manage, organize, solidify, and bring consistency/cohesion to fragmented areas

oLiaising and collaborating with line of business work streams to ensure accuracy/accountability

oMentoring and imparting leadership qualities to senior analysts for cascading affect

oImparting better cognitive/analytical strategies to team members to prepare them for the next level

oUtilizing professional writing skills to enhance monthly executive reporting

oEmploying interpersonal interface to assist team in accomplishing deliverables timely and accurately

COUNTRYWIDE HOME LOANS, INC. / BANK OF AMERICA -- Chandler, Arizona

Assistant Vice President – Corporate Compliance (March 2007 – August 2010)

Primary Focus: Provided monthly metrics, analysis, remediation plans, status, and summary reports to Senior Management pertaining to QC HMDA and ECOA audits.

oMonitored the monthly quality and workload for the offshore division in India (Monthly LAR accuracy)

oWorked with QC and Divisional personnel to maintain and revise Divisional Source Document and System matrices to ensure proper protocol for audit purposes

oConstantly created new analytical monitoring tools (Excel Spreadsheets) to address new business dynamics

oManaged various projects to ensure Federal and State Regulatory compliance with Fair and Responsible lending policies and procedures

oDefined and constructed project schedules, monitoring, tracking, analysis, trending, reporting, and prevention planning to achieve compliance targets and established standards

oIdentified training deficiencies and opportunities for continuous improvement for all divisions

oDeployed new and recommended best practices/benchmarking

oAssisted in the development of training strategies, materials, and user-friendly job aids

oProactively sought initiatives for compliance awareness

oServed as a liaison between Divisional Compliance, Corporate Compliance, and Quality Control

COUNTRYWIDE HOME LOANS, INC. -- Chandler, Arizona

Compliance Assurance Manager – Full Spectrum Lending (November 2005 – March 2007)

Relocated by Countrywide in 2005 to establish a State Audit unit in Chandler, AZ.

Primary Focus: Supervised the development and implementation of cost effective compliance strategies, policies and procedures and monitored to ensure compliance.

oEnsured the detection of deficiencies or violations of applicable laws and regulations

oAs appropriate, brought compliance issues to the attention of the Senior Management

oDesigned and coordinated appropriate mitigation and remediation plans

oKept up-to-date on changes in federal and state compliance laws and regulations

oInitiated and coordinated changes necessitated by new or revised laws and regulations impacting the area of responsibility, including changes in policy and procedural manuals

oAssisted business units and/or marketing in developing new products to ensure early recognition and resolution of compliance concerns prior to implementation.

oProvided monthly metrics, analysis, remediation plans, status, and summary reports to Senior Management pertaining to QC HMDA and ECOA audits

oMonitored the monthly quality and workload for the offshore division in India (Monthly LAR accuracy)

oWorked with QC and Divisional personnel to maintain and revise Divisional Source Document and System matrices to ensure proper protocol for audit purposes

oCreated new analytical monitoring tools (Excel Spreadsheets) to address new business dynamics

oManaged various projects to ensure Federal /State regulatory compliance with policies and procedures

oDefined and constructed project schedules, monitoring, tracking, analysis, trending, reporting, and prevention planning to achieve compliance targets and established standards

oIdentified training deficiencies and opportunities for continuous improvement for all divisions

oDeployed new and recommended best practices/benchmarking

oAssisted in the development of training strategies, materials, and user-friendly job aids

oProactively sought initiatives for compliance awareness

oServed as a liaison between Divisional Compliance, Corporate Compliance, and Quality Control

COUNTRYWIDE HOME LOANS, INC. -- Pasadena, California

Senior Compliance Analyst – Full Spectrum Lending (September 2003 – November 2005)

Primary Focus: Performed loan file audits to ensure compliance with federal/state laws and regulations; assisted in the development of compliance related policies; performed trend analysis for compliance audit deficiencies; implemented and tracked the progress of State Preventative Action Plans; assisted in the testing of compliance-related system technology changes; assisted in the preparation and follow-up of Federal/State audits, pre-audits, and post-audits; and coordinated with Divisional Operations and Production teams to create compliance procedures to resolve Federal and State regulatory audit findings.

oMonitored, tracked, and provided analysis for compliance-related issues (i.e. RESPA, Truth-in-Lending)

oProvided monthly metrics, analysis, remediation plans, status, and summary reports to Senior Management pertaining to State, Federal, and Internal QC audits

oSent weekly and monthly reports to Bonus Compensation pertaining to audit error rates, and which impact departments, teams, and individuals accordingly

oCoordinated the scheduled State, Federal, and Internal QC Examination audits with Central Compliance

oProvided monthly detail reports to Executive Management

oActed as a liaison between Central Compliance, Legal, Production, Operations, System Technology, and Senior Management to address compliance-related issues and initiate action plans for timely resolution.

oProvided support to Funding Centers regarding compliance-related inquiries

oValidated the Risk Management results for high-cost loan audits, in addition to requesting, processing, and mailing refund checks to borrowers under proper Legal Cover.

COUNTRYWIDE HOME LOANS, INC. -- Rosemead, California

Senior Auditor – Internal Audit (January 2002 – September 2003)

Primary Focus: Performed operational, financial, and compliance audits in assigned areas and assisted in developing the audit planning memorandum; revised or expanded audit program parameters provided by the Internal Audit Manager (as necessary) to complete analysis of assigned areas and functions and performed other related duties as required.

Performed audit reviews consisting of entrance conferences with clients

Conducted background investigations and interviewed appropriate personnel as necessary

Determined data requirements

Accumulated, verified, and analyzed available data

Observed and evaluated actual operating procedures and identified existing or potential problem areas

Identified causes or contributing factors relating to problems or control deficiencies

Drafted audit reports detailing findings/recommendations for review with appropriate divisional management

Finalized audit reports for Internal Audit Executive Management review and issuance

Organized and compiled final workpaper documentation for audit finding maintenance and reference

Followed through on the implementation of audit recommendations agreed upon by Management

CALIFORNIA PHARMACY -- Pasadena, California (1983-2002)

Store Manager – (October 1983 – January 2002)

Responsible for managing a four-million dollar, independently-owned and operated pharmacy.

Instrumental in increasing overall store volume 10%-20% annually from 1995-2000 (50% in 2001)

Increased in-store accounts 20% from 1995-2001

Increased average daily prescription business 10%-20% from 1995-2001 (50% in 2001)

Increased average daily delivery business 33% in 2000

Decreased loss percentage from over 12% in 1190 to less than 4% in 2001

AWARDS/RECOGNITION

GOLD AWARDS

May 2013 Conferred by Bank of America Risk Senior Vice President

Feb. 2007 Conferred by Countrywide Legal Executive Vice President

SILVER AWARD

Oct. 2002 Conferred by Countrywide Managing Director Internal Audit

MANAGER/PEER RECOGNITION

Jan 2007 - May 2018: Bank of America –28 Individual Recognition Awards (Achievement, Integrity, Core Values, etc.)

Nov 2017 – Apr 2019: Early Warning Services – 5 Individual Recognition Awards

Apr 2019: Wells Fargo – One Shared Success Award

COMMUNITY SERVICE AWARDS

2009 ReconTrust Emergency Response Team Award

2011 and 2012 Bank of America Community Volunteers Hours Honor Roll

2011 and 2012 White House President’s Volunteer Service Award

EDUCATION

Multiple-Subject Professional Clear Teaching Credential (1995) from California State Polytechnic University, Pomona.

Bachelor of Arts Degree in Liberal Studies with History Minor (1992) from California State Polytechnic University, Pomona.

Taught one year at the 1st and 6th grade level, while concurrently working full-time at the California Pharmacy.

INTERESTS

Boy Scouts of America (both sons achieved the rank of Eagle Scout)

Girl Scouts of America (Assistant and Cookie Dad)

Youth Sports Coach

Reading

Favorite pastime: GOLF!

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