Tag: compliance management

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Coffee and Regs

What’s Next for Cybersecurity in 2022?

Digital Assets: Trading & Compliance for Cryptocurrency

In this episode, Director of Registered Investment Company Services, Allison Fraser and Director of Broker-Dealer Services & Private Funds, John Gentile discuss the latest on digital assets and cryptocurrency. Are they considered securities, what does the SEC’s risk alert mean for digital assets, and how should investment managers be thinking about cryptocurrency trading and compliance?

 

 

About Our Guest Speakers:


 
E.J. Yerzak CISA®, CISM®, CRISC™ assists firms in assessing and managing their cybersecurity risk – from network vulnerability scanning and penetration testing to onsite cybersecurity assessments and assistance in implementing the NIST cybersecurity framework. E.J. has authored articles and alerts on emerging regulatory and technology issues, and is regularly requested to speak as a cybersecurity expert at industry conferences.
 
 

 
Mike Farrell is a Certified Information Systems Auditor (CISA®) and Certified Information Security Manager (CISM®), and Cybersecurity Consultant at CSS. He analyzes data and conducts cybersecurity risk assessments, policy gap analyses, vulnerability scanning and social engineering testing. His Information technology experience includes network installations and management, hardware and software configuration, and troubleshooting.
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Coffee and Regs

Special Episode with the Deputy Commissioner, Securities Division of the Vermont Dept. of Financial Regulation

Special Episode with the Deputy Commissioner, Securities Division of the Vermont Dept. of Financial Regulation

In this special episode, CSS’s Director of Retail Wealth Manager Services Korrine Kohm and William R. Carrigan, Deputy Commissioner, Securities Division of the Vermont Department of Financial Regulation discuss the latest news for registered investment advisers, including what will be required in 2022 surrounding continuing education requirements, the implementation of the new Marketing Rule and what’s next for Form CRS.
 

 

About Our Guest Speakers:

Korrine Kohm is CSS’s Director of Retail Wealth Manager Services. Prior to CSS, Korrine was the Chief Compliance Officer and Head of Operations at Estabrook Capital Management where she was responsible for all compliance functions of this SEC-registered, $2.1B investment advisory firm. Korrine began her regulatory career while working at Allied Irish Bank (NY) in the Operations Department where she was a key member of AIB’s Compliance Committee, responsible for ensuring compliance with Federal and State regulations. An active member of the National Society of Compliance Professionals for over 10 years, Korrine earned her Investment Adviser Certified Compliance Professional (IACCPTM) designation in 2006, is a member of the Association of Certified Fraud Examiners, and obtained her Certified Fraud Examiner designation. In addition to her experience in compliance and banking, Korrine began the 16-week intensive training course in Quantico, Virginia, to become a Special Agent with the Federal Bureau of Investigation. She has particular experience in crafting customized policies and procedures, developing and implementing compliance programs, conducting on-site compliance reviews, acquisition due diligence reviews, risk assessments and mock SEC examinations. She routinely councils clients on various regulatory matters, including SEC registration issues, social media and advertising, policies related to diminished financial capacity, disclosures and the annual review process.
 

William R. Carrigan was appointed Deputy Commissioner of the Securities Division in July 2016. He has worked at DFR since 2007 serving as Director of Examinations and Enforcement and Investor Education Coordinator. A Certified Fraud Examiner, he worked closely with the FBI and IRS to expose the $28 million Mac Parker Ponzi scheme, which involved hundreds of investors, and he was a member of the team that investigated the recent Jay Peak EB-5 matter that resulted in federal and civil lawsuits. Carrigan also spearheaded the inquiry that led to the recent $5.9 million settlement with Raymond James and Associates. He has 20 years of experience in the securities industry and held various positions prior to joining the division. He holds a bachelor’s degree in business management from Johnson State College and a master’s degree in forensic studies from Stevenson University in Maryland. He is a member of the Association of Certified Fraud Examiners and the North American Securities Administrators Association.
 
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Coffee and Regs

The RIA Wild West of Going Independent

The RIA Wild West of Going Independent

 
In this episode, CSS’s Director of Retail Wealth Manager Services, Korrine Kohm and Founder of Transition To RIA, Brad Wales discuss the path to becoming an independent registered investment adviser, best practices to get started on your journey and compliance pitfalls to avoid.
 

 

About Our Guest Speakers:

Korrine Kohm is CSS’s Director of Retail Wealth Manager Services. Prior to CSS, Korrine was the Chief Compliance Officer and Head of Operations at Estabrook Capital Management where she was responsible for all compliance functions of this SEC-registered, $2.1B investment advisory firm. Korrine began her regulatory career while working at Allied Irish Bank (NY) in the Operations Department where she was a key member of AIB’s Compliance Committee, responsible for ensuring compliance with Federal and State regulations. An active member of the National Society of Compliance Professionals for over 10 years, Korrine earned her Investment Adviser Certified Compliance Professional (IACCPTM ) designation in 2006, is a member of the Association of Certified Fraud Examiners, and obtained her Certified Fraud Examiner designation. In addition to her experience in compliance and banking, Korrine began the 16-week intensive training course in Quantico, Virginia, to become a Special Agent with the Federal Bureau of Investigation. She has particular experience in crafting customized policies and procedures, developing and implementing compliance programs, conducting on-site compliance reviews, acquisition due diligence reviews, risk assessments and mock SEC examinations. She routinely counsels clients on various regulatory matters, including SEC registration issues, social media and advertising, policies related to diminished financial capacity, disclosures and the annual review process.

 

 
Brad Wales is the founder of Transition To RIA, a consulting firm uniquely focused on helping established financial advisors understand everything there is to know about WHY and HOW to transition their practice to the RIA model. Brad utilizes his nearly 20 years of industry experience, including direct RIA related roles in compliance, finance and business development to provide independent advice regarding how advisors can benefit from the advantages of the RIA model.

 

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Coffee and Regs

Code of Ethics: A Win-Win-Win for Compliance, Employees and the SEC

Code of Ethics: A Win-Win-Win for Compliance, Employees and the SEC

 

In this episode, our team of former CCOs, Dan Haynes and Victoria Olson discuss why a code of ethics tool is not only beneficial to compliance but to employees and to stay on the SEC’s good side for upcoming exams.

 

 

About Our Guest Speakers:

Dan Haynes joined CSS in 2017 providing consulting services to investment advisers, registered investment companies and private investment funds. Prior to joining CSS, Dan was the Chief Compliance Officer for Summit Strategies Group. Summit is a large institutional pension consultant in the Midwest with multiple private funds – ultimately around $180 billion in assets under administration. Dan implemented several aspects of, and oversaw the entire compliance program. His time there resulted in experience in NFA/CFTC registration and regulation, Private Fund oversight, and the pension consulting world overall. Prior to Summit, Dan was the Chief Compliance Officer for Buckingham Asset Management and BAM Advisor Services. Dan is also a member of the Charles Schwab Compliance Advisory Board.

 

 
Victoria Olson has been a compliance consultant for several years, most recently with Alaric Compliance Services. She is a Certified Regulatory and Compliance Professional (CRCP issued by FINRA Institute at Wharton), and a Chartered Life Underwriter. She also completed the Certified Anti-Money Laundering specialist (CAMS) course. Victoria previously served as the Chief Compliance Officer to an SEC-registered investment adviser and has extensive experiencing working with RIAs. Prior to consulting, Victoria was Chief Compliance Officer and AML Compliance Officer at Forethought Financial, Director of Compliance at Prudential Financial, and a Senior Compliance Officer at The Phoenix Companies. Victoria formerly served as Chair of the FINRA District 11 Committee and successfully completed the FINRA Series 4, 6, 7, 24 and 66 Examinations.

 
 

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Coffee and Regs

Why Outsourced Compliance is No Longer a Dirty Word

Why Outsourced Compliance is No Longer a Dirty Word

 
In this episode, former CCOs Korrine Kohm and Ariana Monchick discuss compliance management and how to expand and optimize your program leveraging tools, technology and outsourced compliance services.
 

 

About Our Guest Speakers:

Korrine Kohm is CSS’s Director of Retail Wealth Manager Services. Prior to CSS, Korrine was the Chief Compliance Officer and Head of Operations at Estabrook Capital Management where she was responsible for all compliance functions of this SEC-registered, $2.1B investment advisory firm. Korrine began her regulatory career while working at Allied Irish Bank (NY) in the Operations Department where she was a key member of AIB’s Compliance Committee, responsible for ensuring compliance with Federal and State regulations. An active member of the National Society of Compliance Professionals for over 10 years, Korrine earned her Investment Adviser Certified Compliance Professional (IACCPTM ) designation in 2006, is a member of the Association of Certified Fraud Examiners, and obtained her Certified Fraud Examiner designation. In addition to her experience in compliance and banking, Korrine began the 16-week intensive training course in Quantico, Virginia, to become a Special Agent with the Federal Bureau of Investigation. She has particular experience in crafting customized policies and procedures, developing and implementing compliance programs, conducting on-site compliance reviews, acquisition due diligence reviews, risk assessments and mock SEC examinations. She routinely counsels clients on various regulatory matters, including SEC registration issues, social media and advertising, policies related to diminished financial capacity, disclosures and the annual review process.


Ariana Monchick is a Senior Consultant for CSS’s Compliance Services team, and offers broad expertise on securities and investment advisory regulations. Ariana’s experience working in senior compliance positions at various financial services firms allows her to offer effective and comprehensive compliance solutions while maintaining a big-picture orientation. She has established a strong background in developing robust compliance programs for organizations and partnering with business leaders to mitigate risk. Most recently, Ariana was an Advisory Chief Compliance Officer for Cetera Financial Group, one of the largest family of independent broker-dealers in the United States. She was also the Chief Compliance Officer for Legend Advisory Corporation, a registered investment adviser that services the 403(b) retirement plan market.

 
 

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Coffee and Regs

Expanding Your Compliance Program Through Trade Surveillance

Expanding Your Compliance Program Through Trade Surveillance

 
In this episode, CSS’s former CCOs Allison Fraser and Matt Calabro sit down to discuss trade surveillance and how CCOs can mitigate the risk factors through the trade lifecycle – from pre-trade to trade execution and post-trade. They’ll also dive into how compliance together with operations and third parties can build out a robust and automated trade surveillance program.
 

 

About Our Guest Speakers:

Allison Fraser provides compliance consulting services to investment advisers, registered investment companies and private investment funds, including conducting annual compliance program reviews and testing, developing risk assessments and preparing for SEC examinations. She also assists clients with drafting policies and procedures and preparing regulatory filings. On behalf of, the Compliance Services division of CSS, Allison served as the Chief Compliance Officer for a family of alternative funds registered under the Investment Company Act of 1940. Prior to joining CSS, Allison served as a Senior Vice President of Compliance at Northern Trust Investments, Inc. (“NTI”), the asset management subsidiary of The Northern Trust Company. In this capacity, she managed and administered the compliance due diligence program for NTI’s Multi-Manager Solutions and Outsourced Chief Investment Officer businesses. Allison also was the Chief Compliance Officer of two registered funds of hedge funds advised by NTI as well as a member of the funds’ Pricing and Disclosure Committees. Before joining NTI, Allison served as the Compliance Director for General Motors Asset Management, where she assisted with the administration of the compliance program for this registered investment adviser.


Matt Calabro is an experienced Chief Compliance Officer, having served as CCO for registered mutual funds, investment advisers and a family of UCITS funds. Before joining CSS, Matt was Deputy CCO at Delaware Investments, where he led the daily activities of the firm’s compliance department covering advisory, fund and distribution activity. Under his leadership, Delaware implemented specific improvements in its guideline compliance, advertising review and Code of Ethics programs. Prior to Delaware, Matt spent 20 years in Raymond James’ investment advisory business, where he led mutual fund operations. While there, Matt implemented and upgraded controls, processes and technology and also served as the first full-time CCO to the mutual funds following the adoption of the Compliance Rule. Matt leverages his compliance and operations experience in the investment management industry to assist advisers and investment companies in advancing the effectiveness of their compliance programs.

 
 

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Coffee and Regs

Getting a Head Start on the SEC Derivatives Rule 18f-4

Getting a Head Start on the SEC Derivatives Rule 18f-4

 
In this episode, CSS’s Director of Registered Investment Company Services Allison Fraser sits down with Partner at Morgan Lewis, Laura Flores to discuss the SEC regulatory framework for derivatives use with the new 18f-4 Rule. Even though compliance plans do not have to be fully implemented until August 2022, fund managers need to start preparing now for a compliant derivatives risk management program, calculating daily value-at-risk (VaR) measurements and performing stress tests.
 

 

About Our Guest Speakers:

Allison Fraser provides compliance consulting services to investment advisers, registered investment companies and private investment funds, including conducting annual compliance program reviews and testing, developing risk assessments and preparing for SEC examinations. She also assists clients with drafting policies and procedures and preparing regulatory filings. On behalf of, the Compliance Services division of CSS, Allison served as the Chief Compliance Officer for a family of alternative funds registered under the Investment Company Act of 1940. Prior to joining CSS, Allison served as a Senior Vice President of Compliance at Northern Trust Investments, Inc. (“NTI”), the asset management subsidiary of The Northern Trust Company. In this capacity, she managed and administered the compliance due diligence program for NTI’s Multi-Manager Solutions and Outsourced Chief Investment Officer businesses. Allison also was the Chief Compliance Officer of two registered funds of hedge funds advised by NTI as well as a member of the funds’ Pricing and Disclosure Committees. Before joining NTI, Allison served as the Compliance Director for General Motors Asset Management, where she assisted with the administration of the compliance program for this registered investment adviser.


Laura E. Flores is a Partner at Morgan Lewis with a practice that focuses on the regulation of investment companies and investment advisers. Laura regularly represents exchange-traded funds (ETFs), mutual funds, and variable insurance-dedicated products, as well as their sponsors and boards of directors, and investment advisers. She counsels both well-established clients and clients that are new to the industry on a variety of regulatory, transactional, compliance and operational issues, including the development of new financial products and services, federal and state registration issues, the preparation and implementation of compliance programs, business combinations involving investment companies and investment advisers, interpretive and “no-action” letter requests, requests for Securities and Exchange Commission exemptive relief, and regulatory examinations. Laura also counsels investment advisory clients on matters, including advertising and communications with the public, investment adviser registration, and separately managed account (or wrap fee) programs. Laura also has significant experience representing “liquid alt” funds, funds that invest through offshore subsidiaries, and funds that utilize QFII/RQFII quotas to invest directly in securities issued and traded in China.

 
 

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Coffee and Regs

Private Funds 101 – From SEC Registration to Compliance Rules

Private Funds 101 – From SEC Registration to Compliance Rules

 
In this episode, CSS’s Director of Private Funds and a former SEC regulator, John Gentile sits down with Senior Vice President of Ultimus LeverPoint Private Fund Solutions, Andrew Jones to discuss the world of private fund managers. The round-robin discussion covers SEC registration to identifying as an Exempt Reporting Adviser, the impact of the new Marketing Rule on private funds and compliance best practices for fund admins.
 

 

About Our Guest Speakers:

John Gentile is responsible for overseeing various types of broker-dealer and investment adviser consulting engagements, including conducting SEC/FINRA internal control reviews, anti-money laundering testing, written supervisory policy and procedures testing, and other consultation services. John is a frequent speaker at industry conferences on various compliance topics, including “Effective Supervision,” “Large Firm Testing,” FINRA Supervisory Control Rules” and “Anti Money Laundering Requirements for Broker Dealers under the PATRIOT Act.” In 1987 John joined the SEC as a Securities Compliance Examiner, becoming a Branch Chief in 1991. He became Assistant Regional Director in 1993, supervising a team of 20 broker-dealer managers and examiners. He also planned and conducted financial, operational, and sales practice examinations of the largest broker dealers and was among those responsible for a review of hedge funds’ impact on broker dealer internal controls. Before joining the SEC, John was a Financial Damage Analyst with PaineWebber Inc. Most recently from 2000-2007 John was an Executive Consultant, Broker-Dealer Services, at National Regulatory Services. John has an MBA from Fordham University and a BS in Finance from Central Connecticut State University. From 1995 to 2002, John was also a member of the Securities Industry Continuing Education East Coast Content Committee.
 

 

Andrew Jones is the Senior Vice President for Ultimus LeverPoint Private Fund Solutions. He joined Ultimus in April 2018, and is responsible for overseeing the promotion and sales for private fund services. Andrew works closely with the executive team to provide a client-focused approach and collaborates with other industry professionals to provide a diverse network of solutions for Ultimus clients. He works in the Chicago, Illinois office. Before joining Ultimus, Andrew worked as Senior Vice President at Woodfield Fund Administration, LLC, where he was responsible for the development of new business, marketing, client relations, and implementations. He also served as head of Investor Services, overseeing the day-to-day operational functions for hedge funds, private equity, venture capital, real estate, and other clients. Andrew earned a bachelor’s degree in Business, Management, and Marketing from the University of Iowa, and has been working in the financial services industry since 2007.

 
 

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Innovation in Compliance

Ascending Compliance Management with Gene Geiger


Gene Geiger of A-LIGN joins Tom Fox on this week’s show to discuss his company’s innovative compliance management platform, A-SCEND. Gene remarks that there was a market need to drive technology in the professional services space. “What we’ve been missing is driving automation and driving workflow and driving efficiency through technology, and that’s really what A-SCEND is meant to do. It’s meant to complement the people in the audit workflow to make the job as efficient and as automated as possible,” he says.

Built For Users
“The need for technology crosses multiple compliance standards,” Gene remarks. A-SCEND is built to comply with eight compliance standards in the cybersecurity industry. In addition, Gene says, users can input their own internal standards using the custom object module. He describes various features of the platform that helps clients automate their compliance workflow, and manage compliance tasks throughout the year, rather than just for the annual audit. A unique feature of A-SCEND is its ability to de-duplicate requests across multiple compliance standards, resulting in up to a 50% decrease in workload when preparing for audits. Gene points out how these innovative features allow their clients to do anytime, anywhere audits, and how both they and their clients were able to pivot easily to remote work as a result of the COVID-19 pandemic. Tom asks how feedback is built into the platform. Gene outlines several mechanisms, including their advisory board, surveys, and their customer support system. “We are able to build an application for compliance management that really meets the needs of the users,” he says.
The Future of Strategic Compliance
Tom and Gene discuss the future of strategic compliance. Gene predicts that there will be movement towards benchmarking, AI-based review and evidence collection, and data-driven metrics.
Resources
A-lign.com