The Unsecured Consumer Lending team at Upstart Bank operates as the full first line of defense across product, growth, operations, and customer lifecycle for our personal loan, Cash Line, servicing and emerging consumer products. Compliance and controls are built into how we scale — not layered on at the end. This team is accountable for ensuring that everything we put in front of borrowers, partners, and regulators is accurate, fair, and examination-ready.
The Director, Compliance & Controls — Growth leads first-line compliance for Upstart’s growth engine: the acquisition channels, marketing programs, partner relationships, and product launches that bring borrowers to our platform across unsecured lending (personal loans and lines), servicing, and growth (for both unsecured and secured products).
This is a senior accountability role at the intersection of lending growth and regulatory discipline — one that shapes how Upstart grows as much as how it controls.
- Channel & partner oversight: Own first-line compliance and controls for the growth function — acquisition channels, marketing programs (social, direct mail, email, co-branded), partner and affiliate relationships, and new product introductions — reviewing each for regulatory, fair lending, and disclosure risk, and approving marketing materials and third-party-produced content before release.
- Regulatory review & approval: Bring UDAAP, Regulation B, CAN-SPAM, TCPA, and disclosure expertise to the front of the design process — translating regulatory requirements into practical guidance for channel launches, partner agreements, and product changes at the design stage, not at the finish line.
- Control framework: Build and maintain the business control framework: marketing approval policies, campaign inventory and change control, compliance monitoring, and regulatory change management. Quantify exposure and calibrate controls based on actual risk — not volume or optics.
- Accountability: Own root cause analysis and remediation design for growth-related compliance matters — complaints, risk assessments, marketing claims violations, and disclosure errors — working with the issue management function to drive durable fixes tracked to completion.
- Influence: Operate as a trusted compliance partner in both directions: enabling Growth, Product, Marketing, and ML teams to move with clarity and speed, while representing the business to second-line compliance, Legal, and auditors across risk assessments, fair lending reviews, and regulatory examinations. Maintain examination-ready documentation and serve as the business’s primary point of contact in audits and governance reviews.
- Team leadership: Build and develop a compliance team with depth across consumer protection, marketing, and acquisition channel regulation. Set the standard for analytical rigor, proactive issue identification, and practical guidance that enables the business — not just gatekeeping.
- Consumer lending experience: 7+ years in compliance, legal, or risk management in consumer lending, banking, or fintech
- Marketing compliance: Direct experience in marketing compliance, customer acquisition oversight, or partner/affiliate compliance
- Regulatory knowledge: Deep working knowledge of consumer protection regulations applicable to loan marketing and offer generation, including UDAAP, Regulation B, CAN-SPAM, TCPA, and applicable state laws
- Program leadership: Demonstrated experience managing a first-line compliance function in a bank-regulated environment, including operating across first-line, second-line, and Legal structures with clear accountability; credible with regulators, internal audit, and senior leadership
- Analytical rigor: Able to apply UDAAP, Regulation B, and related consumer protection frameworks to novel marketing and channel contexts — quantifying exposure and prioritizing controls based on materiality, not issue volume
- Influence: Confident and credible with Growth and Product leaders, regulators, and second-line partners — including experience supporting OCC, CFPB, or state regulatory examinations on consumer lending compliance; able to hold a position and represent the business directly
- Initiative: Track record of identifying compliance gaps in marketing programs, acquisition channels, or partner relationships before they escalate — proposing solutions and driving execution without waiting for direction
- Ownership: Accountable end-to-end for compliance outcomes — works root causes through to resolution on marketing violations, disclosure issues, and control gaps, not just escalation
- Secured lending: Familiarity with secured consumer lending marketing compliance, including HELOC or home equity lending
- AI fluency: Familiarity with AI/ML-driven credit decisioning — including adverse action accuracy and fair lending implications — and comfort using AI tools to increase the efficiency and quality of compliance work
Time zone requirements The team operates on the East/West coast time zones.