Director, Affirm Bank Internal Audit

The Head of Internal Audit will report directly to the Bank’s Audit Committee and will serve as a critical member of the Bank's leadership team, responsible for establishing and leading the Internal Audit function for the Bank, an Industrial Loan Company (ILC) in organization. This role will oversee the design and execution of a risk-based internal audit program that provides independent assurance to the Board of Directors, Audit Committee, and senior management regarding the effectiveness of governance, risk management, and internal controls.

The Head of Internal Audit will develop the Bank’s audit infrastructure during the de novo phase and evolve it post-launch to align with FDIC and state regulatory expectations for the Bank’s deposits and lending sponsorship businesses. This leader will collaborate with all functional areas, including Risk, Compliance, Operations, and Finance, to ensure robust audit coverage, transparency, and continuous improvement.

The ideal candidate will combine strong technical audit expertise with practical, lending-sponsor bank insight, and the ability to build a best-in-class audit program from inception.

What You’ll Do

1. Internal Audit Program Development

• Establish and maintain a comprehensive, risk-based internal audit program that aligns with the Bank’s strategy and regulatory requirements.
• Develop the audit charter, policies, procedures, and methodology to ensure independence and objectivity.
• Oversee the creation and execution of the annual audit plan based on risk assessments and changing business conditions.
• Partner with Audit counterparts at Affirm to manage third and fourth party risk.

2. Audit Execution and Oversight

• Lead and conduct audits across key functional areas
• Evaluate the adequacy and effectiveness of internal controls, risk management, and governance processes
• Provide independent recommendations for control enhancements, process improvements, and risk mitigation
• Oversee documentation, issue tracking, and follow-up of audit findings to ensure timely resolution.

3. Board and Regulatory Reporting

• Report directly to the Audit Committee of the Board, providing regular updates on audit results, trends, and emerging risks.
• Prepare materials for Board and committee meetings, ensuring transparency and actionable insight
• Serve as liaison with external auditors, examiners, and regulators, coordinating responses to findings or requests
• Support the Audit Committee in fulfilling its oversight responsibilities related to risk, control, and audit

4. Risk and Control Advisory

• Collaborate with executive management to evaluate risk management and internal control frameworks
• Advise management on control design and efficiency without compromising audit independence
• Support integration of risk-based thinking and control discipline across all departments
• Identify opportunities to enhance governance and control maturity during early-stage bank development

5. De Novo and Pre-Opening Readiness

• Lead the design and documentation of the Internal Audit framework as part of the de novo application process
• Establish audit coverage for pre-opening activities, including policy development, system implementation, and vendor onboarding
• Develop readiness assessments and Board materials to support FDIC and state regulatory reviews
• Build and train an audit function capable of scaling as the Bank grows post-launch

What We Look For

• Minimum of 10 years of internal audit, risk management, or control experience, in a regulated banking environment
• Proven experience establishing or leading an internal audit program for an FDIC-supervised institution
• Strong understanding of lending-sponsorship banking and consumer deposits, and preferably experience with a lending-sponsor bank or ILC.
• Knowledge of the FDIC examination processes, and interagency audit guidance preferred
• Strong understanding of lending sponsorship-banking and consumer deposit operations, internal controls, IT systems, and regulatory compliance
• Demonstrated ability to assess risk, communicate effectively with senior management and the Board, and deliver practical audit insights
• Experience managing internal and co-sourced audit relationships
• Exceptional integrity, judgment, and attention to detail

Core Competencies

• Deep understanding of risk assessment, internal controls, and audit standards
• Ability to design and execute a scalable, risk-based audit program
• Strong collaboration with management while maintaining independence and objectivity
• Excellent analytical, communication, and report-writing skills
• Strategic thinker who can identify control gaps and operational improvement opportunities

Affirm Values

At Affirm, we live by our values: People Come First, No Fine Print, It’s On Us, Simplify, and Push the Envelope. As CCO, you will embody these principles while building the foundation of Affirm Bank as a trusted, transparent, and innovative financial institution.

Compensation & Benefits

Base Pay Grade - S

Equity Grade - 14

Employees new to Affirm typically come in at the start of the pay range. Affirm focuses on providing a simple and transparent pay structure which is based on a variety of factors, including location, experience and job-related skills.

Base pay is part of a total compensation package that may include monthly stipends for health, wellness and tech spending, and benefits (including 100% subsidized medical coverage, dental and vision for you and your dependents). In addition, the employees may be eligible for equity rewards offered by Affirm Holdings, Inc. (parent company).

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