America First CU Taps Legal Veteran to Steer Growth and Risk Strategy

OGDEN, Utah – April 08, 2026 – America First Credit Union, one of the nation's largest credit unions, has appointed legal and risk management veteran Jessica Graham as its new Executive Vice President and Chief Legal Officer. The move signals a strategic reinforcement of its leadership team as the financial giant navigates an aggressive growth phase amidst an increasingly complex regulatory landscape.

Graham joins the $24 billion institution with nearly three decades of legal experience, most recently serving as Executive Vice President, Chief Risk Officer & Chief Legal Officer for Global Federal Credit Union. Her appointment is seen by industry observers as a crucial step for America First as it continues its expansion through mergers, acquisitions, and digital innovation.

"We are thrilled to welcome Jessica to America First," said Thayne Shaffer, president & CEO at America First Credit Union, in a statement. "She brings incredible experience not just as a Chief Legal Officer, but also in compliance, crisis management, and mergers & acquisitions. Her expertise and leadership make her an outstanding addition to our leadership team."

A Strategic Hire for a Growing Giant

Jessica Graham’s background represents a confluence of skills perfectly tailored to the challenges facing a top-tier credit union. With 23 years spent as General Counsel and Chief Legal Officer for large institutions with multi-state and international operations, she possesses deep institutional knowledge. Her most recent role combined the duties of Chief Risk Officer and Chief Legal Officer, a dual responsibility that highlights a modern trend in financial services leadership: the deep integration of legal strategy with enterprise-wide risk management.

At Global Federal Credit Union, Graham was instrumental in strengthening business operations and contributing to the company's growth by facilitating cross-departmental communication and removing internal roadblocks. This experience will be vital at America First, which serves 1.5 million members across 116 locations in six states. As the credit union's chief legal advisor, Graham will not only oversee regulatory compliance but also provide strategic counsel on key growth initiatives, directly supporting the executive team and board.

Navigating Growth and Consolidation

America First Credit Union's growth has been robust. Consistently ranked among the top ten largest credit unions in the United States, its asset size has swelled, and its market presence has expanded. This trajectory is set to continue, most notably with a planned acquisition of Meadows Bank slated for the second quarter of 2026. This move is part of a larger, unprecedented wave of M&A activity within the credit union sector, where institutions are consolidating to achieve the scale necessary to compete with megabanks and invest in critical technology.

Graham's proven expertise in mergers and acquisitions is a direct answer to this strategic imperative. Successfully navigating an acquisition involves complex legal due diligence, regulatory approvals, and operational integration—all areas where a seasoned legal executive is indispensable. Her role will be critical in ensuring that America First’s expansion efforts are not only successful but also compliant and strategically sound, mitigating the inherent risks of M&A activity while maximizing the potential for market growth and enhanced member value.

Beyond M&A, the credit union is also heavily invested in digital transformation. It was the first credit union to implement next-generation cloud-native technology for its ATM network and has partnered with fintech firms like Loquat Inc. to streamline its small business banking services. This digital push, which has already led to a 400 percent increase in online business banking applications, introduces new legal and compliance challenges related to data privacy, cybersecurity, and vendor management that fall squarely within Graham's purview.

The Complex Web of Modern Regulation

The financial industry operates within a dense and ever-shifting regulatory framework, and large credit unions are under intense scrutiny. The National Credit Union Administration (NCUA), the industry's primary regulator, has identified credit risk, cybersecurity, and consumer financial protection as key supervisory priorities for 2025. With delinquencies on the rise in credit card and auto loan portfolios, examiners are expected to closely scrutinize lending practices and risk management frameworks.

Simultaneously, the Consumer Financial Protection Bureau (CFPB) continues to exert its influence over financial products and services, with recent focus on overdraft fees, “Buy Now, Pay Later” products, and fair lending practices. For an institution of America First’s size, which offers a full suite of consumer and business financial products, navigating the overlapping jurisdictions and evolving rules of these agencies requires a robust and proactive compliance strategy. Graham's role will be to lead this effort, ensuring the credit union not only adheres to current regulations but is also prepared for future changes, protecting both the institution and its members.

The Evolving Role of the Chief Legal Officer

Graham’s appointment is emblematic of a broader shift in the financial services industry, where the Chief Legal Officer is no longer just a legal advisor but a core strategic partner. The modern CLO is expected to possess a deep understanding of the business and contribute directly to its strategic direction, a role that demands expertise far beyond traditional law.

The integration of legal, risk, and compliance functions under a single leader is becoming a best practice for large financial institutions. This holistic approach ensures that risk management is not siloed and that legal counsel is embedded in every major business decision, from launching a new digital product to entering a new market. Graham’s experience as both a Chief Risk Officer and Chief Legal Officer makes her a prime example of this new breed of executive, one who can balance aggressive growth ambitions with prudent risk mitigation.

As she steps into her new role, Jessica Graham will be at the center of America First Credit Union’s efforts to build on its legacy. Her leadership will be fundamental as the organization continues to serve its members while navigating the significant opportunities and challenges of the modern financial landscape.