HMDA/Fair Lending Manager

The Team:

Upstart’s Responsible AI Lending team supports fair and responsible lending practices through compliance oversight, analysis, and controls. The team partners across Product Compliance, Fair Lending, and Model Risk to identify and manage regulatory risk while supporting Upstart Bank’s continued growth.

As the HMDA / Fair Lending Manager, you will own key elements of Upstart Bank’s Home Mortgage Disclosure Act compliance program, with a focus on data integrity, reporting, and second-line oversight. You will establish and manage the HMDA quality program while expanding your impact over time through geographic analysis, Fair Lending support, and thoughtful use of automation to make compliance reviews more effective and scalable.

How you’ll make an impact

• Own the HMDA data-quality lifecycle, including periodic Loan/Application Register reviews, quarterly and annual filing preparation, and oversight of reporting accuracy and timeliness.
• Identify data-quality issues and root causes, partner with business teams on corrective actions, and monitor remediation through resolution.
• Build and maintain a risk-based HMDA sampling and quality-assurance program that provides an effective second-line challenge of business-owned reporting data.
• Perform and support geographic analysis of lending patterns to identify potential redlining and other Fair Lending risks and contribute to broader Fair Lending monitoring.
• Partner with Product Compliance, Fair Lending, Model Risk, and business teams to clarify responsibilities, improve controls, and promote consistent data-quality practices.
• Use automation and Generative AI responsibly to improve sampling, anomaly detection, trend analysis, and documentation while maintaining appropriate human review for regulatory interpretation and reporting decisions.

Minimum Qualifications

• 4+ years of hands-on experience reviewing HMDA Loan/Application Register data and applying HMDA data integrity, geocoding, and reporting requirements.
• Experience preparing, reviewing, or supporting quarterly and annual HMDA submissions in a regulated lending or financial-services environment.
• Experience performing root-cause analysis of compliance or regulatory data issues and coordinating remediation with business or operational teams.
• Working knowledge of applicable Fair Lending requirements, including the Equal Credit Opportunity Act/Regulation B and Fair Housing Act.
• Experience performing compliance testing, quality assurance, monitoring, or other second-line oversight activities involving regulated lending data.

Preferred Qualifications

• Knowledge of geographic or redlining analysis used to support Fair Lending monitoring.
• Experience building or improving risk-based sampling methodologies, quality-control programs, or compliance monitoring frameworks.
• Ability to work across compliance, product, model risk, and business teams to resolve data-quality and regulatory issues.
• Experience using scripting, analytics, automation, or Generative AI tools to improve regulatory data review and identify anomalous patterns.
• Ability to translate regulatory requirements and analytical findings into clear documentation and actionable recommendations.

Travel requirements

As a digital first company, the majority of your work can be accomplished remotely. The majority of our employees can live and work anywhere in the U.S but are encouraged to to still spend high quality time in-person collaborating via regular onsites. The in-person sessions’ cadence varies depending on the team and role; most teams meet once or twice per quarter for 2-4 consecutive days at a time.