Vice President - CCAR Banking Activities Controller - Finance - IHC CCAR Controls
Standard / Permanent
CIB is responsible for the corporate and investing activities of the BNP Paribas Group. CIB is divided into multiple areas, including: Asset Liability Management/Treasury, Corporate Finance, Global Equities and Commodity Derivatives, Fixed Income, Portfolio Management, Corporate Banking, and Value Preservation Group. These groups cover a wide range of products, clients, and markets across the financial services industry.
In accordance with section 165 of the Dodd-Frank Act (DFA), BNP Paribas is required to establish an Intermediate Holding Company (IHC) over its US subsidiaries. Ahead of the implementation of the IHC in 2016, an IHC Program has been established with a series of work streams to support risk-based capital and leverage standards, financial regulatory reporting, enhanced governance requirements, liquidity risk management, and other pending requirements.
The Intermediate Holding Company (“IHC”) program structured at the U.S. level across poles of activities of BNP Paribas provides guidance, supports the analysis, impact assessment and drives adjustments of the U.S. platform’s operating model due to the drastic changes introduced by the Enhanced Prudential Standards (“EPS”) for Foreign Banking Organizations (“FBOs”) finalized by the Federal Reserve in February 2014, implementing Section 165 of U.S. Dodd-Frank Act.
One of the program work stream relates to the Comprehensive Capital Analysis and Review (CCAR) process, with a dedicated sub-work stream to look at control aspects of the different CCAR components, such as:
• CCAR Governance
• Risk appetite and assessment, including identification, limits, business plan…
• Scenario-based Forecasting, including stress testing, scenario elaboration and projection
• Economic Capital and other Measures of Capital Adequacy, including aggregation and analytics
• Capital Adequacy and Contingency, including forecasting, adequacy analysis and capital allocation
• Regulatory and management reporting and disclosures, including attestation and stress test disclosures
• Data architecture and data management, including data maintenance and data quality
• Documentation, including policy, procedures, end to end review…
BNPP is seeking candidates to join the CCAR Finance Control team, which is part of the broader Finance Control team established to support the IHC Program. The CCAR Finance Control team will be responsible for coordinating the end-to-end CCAR control process, similarly to the internal control requirements specified by the FED for Financial reporting process.
The team will work closely with other business and functional areas to secure compliance with various regulations for internal control effectiveness for financial information disclosure.
Interaction will be with local or regional teams, mainly based in New York, which will run and support the CCAR process but also possibly with central Head Office teams if component of the CCAR process are run or supported from there.
The CCAR Finance Control team is responsible to design and implement the CCAR control framework at the IHC level, during the project phase, by early 2016, then to run and oversee all CCAR related control Items. Consistently with expected IHC regulatory internal control requirements, internal control framework for CCAR will be organized and driven by COSO guidelines, based on its 5 components and 17 principles. Consistently, it will include controls design and implementation for: Governance and Oversight, Risk & Control assessment, Independent review and Monitoring, Control of activities, Remediation and reporting.
Operationally, for all the areas of CCAR components (see Business Overview section), key duties /elements are:
• To identify key processes of the CCAR components according to COSO methodology,
• To perform walkthrough and create narratives for the key processes
• To build risks/controls matrices and specify control gaps identification
• To coordinate and/or contribute to the control testing, and report control deficiencies
For this position, specific responsibilities will be to design, implement and monitor the organization for internal control of the CCAR process for banking activities except Capital Markets ones.
For these areas, the position will be the one of a subject matter expert related to internal control for CCAR process.
- Good knowledge of COSO control framework is a must have. Same for understanding about capital requirements
- Candidates will have worked in external audit and/or advisory firm, reviewing Corporate and Retail Banking , activities, possibly under CCAR requirement, performing process walkthrough and independent testing
- Excellent verbal and written communication skills (English language)
- Rigorous, self-disciplined, paying attention to detail
- Committed to maintain strong control environment
- Capacity to interact with people in different areas, building confident and reliable business relationship
- Ability to adhere to strict project and production deadlines, showing strong planning and organization skills
- Proficient in Microsoft Office Suite (Word, Excel, Access, & PowerPoint)
- Bachelor in finance or audit. MBA and/or CPA are a plus