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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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Coffee and Regs

Special Episode: Spotlighting the Expect Miracles Foundation & Social Distance Challenge

Special Episode: Spotlighting the Expect Miracles Foundation & Social Distance Challenge

 
In this special episode, CSS’s Chief Revenue Officer Terence Faherty takes a break from compliance and sits down with the Managing Director of Stewardship at the Expect Miracles Foundation and Founder of The SamFund, Samantha Watson to talk about a dedicated commitment of the financial services community to bring meaningful resources to research and people impacted by cancer.

 

 

About Our Guest Speakers:

Terence Faherty has over 30 years’ experience in the financial technology, regulatory and banking industry living and working throughout the US and UK. Mr. Faherty is currently Chief Revenue Officer for Compliance Solutions Strategies (CSS). Previously, he was VP, General Manager for Broadridge’s revenue and expense management solutions focusing on helping clients apply solutions to help with transparency, efficiency and compliance in the Capital Markets/Trading arena. Mr. Faherty’s experience includes Managing Director of middle and back office technology companies, Milestone and MultiFonds. Mr. Faherty spent 12 years at SunGard BancWare as President and COO focusing on risk management, regulatory compliance and Basle II.
 

 

Samantha Watson is the Managing Director of Stewardship at the Expect Miracles Foundation and Founder of The SamFund. Sam is also a two-time young adult cancer survivor, diagnosed with Ewing Sarcoma in December of 1999 and with secondary Myelodysplastic Syndrome in April of 2001. She is proud to be an active member of the cancer community and a passionate advocate for young adult survivors throughout the country. Sam holds a BA from Brandeis University and an MBA in Mission-Driven Management from the Heller School for Social Policy and Management at Brandeis.

 
 

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Coffee and Regs

The Facts on FINRA & Capital Acquisition Brokers

The Facts on FINRA & Capital Acquisition Brokers

 
In this episode, CSS’s Director of Broker-Dealer Services and a former regulator, John Gentile and Executive Director, Jackie Hallihan sit down to discuss FINRA’s rule book regarding capital acquisition brokers. These are broker-dealers that limit their business to certain capital raising, mergers and acquisitions and corporate financing activities, so before you go down that regulatory path, it’s important to understand the rules and the benefits of CAB registration.

 

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.
 

 

Jackie Hallihan is the Co-Executive Director of CSS’s Compliance Services team and has over 25 years’ regulatory and risk management experience. She was the founder of National Regulatory Services (NRS) which started the compliance resource business and served as its President for over 20 years. She also founded the National Society of Compliance Professionals (NSCP), a non-profit organization for compliance officers, staff and lawyers serving the compliance industry. It now boasts over 2000 memberships. Jackie has been a leading speaker to compliance professionals, including in-house training programs and various other industry association conferences, and has received numerous industry awards. Jackie also serves as Director, Clerk of the New England Broker Dealer Investment Adviser Association (NEBDIAA), a non-profit organization, incorporated in 1997. The purpose of NEBDIAA is to provide a forum for the professional exchange of information among investment advisers, broker dealers, and persons who provide services to investment advisers and broker dealers, and to direct communication among its members which will improve their ability to serve the needs of their respective clients. The forum will help NEBDIAA’s members meet the increased regulatory demands placed on investment advisers, broker dealers, and persons who provide services to investment advisers and broker-dealers.

 
 

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Coffee and Regs

New Rule Roadmap: Navigating and Implementing the Marketing Rule

New Rule Roadmap: Navigating and Implementing the Marketing Rule

 

In this episode, former CCOs and CSS’s compliance services experts in retail and institutional wealth manager services, Korrine Kohm and Matt Calabro discuss a roadmap on navigating the new Marketing Rule, building an action plan and leveraging managed services and technology to help remove compliance complexities from the rule.

 

 

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.

 

 

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

Managing Cyber Insurance Risk

Managing Cyber Insurance Risk
 

In this episode, CSS’s Director of Cyber IT Services E.J Yerzak sits down with AVP, Program Executive at Varney Agency and cyber insurance expert Nick Weiner to discuss the recent NYDFS guidance for insurers that underwrite cyber insurance policies. The guidance includes a Cyber Insurance Risk Framework that provides best practices for managing cyber insurance risk amid concerns of systemic and “silent” risks to the financial sector.

 

 

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.

 
 

Nick Weiner is a commercial insurance agent, with ten years of experience focused on cyber, professional & management liability insurance for financial institutions. Nick firmly believes every professional organization deserves access to a specialist who can design, administer and implement a custom insurance solution. Working with an independent insurance agency gives Nick the opportunity to use his experience, knowledge, and understanding of the marketplace to assist his clients in finding the insurance solutions that meets their needs. At twenty-two, Nick started his own national insurance agency focused solely with the goal of servicing entrepreneurs in the financial services industry. Seven years later, Nick’s business was purchased, and he joined forces with Varney Agency (Portland, ME) to assist in the continued growth of their financial institution’s division. Nick often participates in thought leader groups for the industry and works closely with some advisory focused publications to provide input on insurance related topics.

 
 

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Coffee and Regs

ESMA Updates, MiFIR & Transaction Reporting Trends

ESMA Updates, MiFIR & Transaction Reporting Trends

 

In this episode, CSS’s Chief Product Officer Ronan Brennan sits down with Regulatory Specialist Nicklas Nilsson to discuss the latest updates from ESMA on MiFIR in the world of transaction reporting and the trend to consolidate regulatory reporting and data going forward.

 

About Our Guest Speakers:

 

Ronan Brennan is the Chief Product Officer at Compliance Solutions Strategies (CSS). In his role, he has direct responsibility for the strategic evolution of the global suite of CSS products and regulatory content. Managing product in CSS involves ensuring the product suite is ready to support both the current and future compliance management and regulatory reporting needs of investment management and advisory firms globally. Ronan participates as a speaker in many industry events each year, in addition to publishing a company blog and development of thought leadership materials. Ronan has 26 years of experience in the technology sector, 21 of which have been spent in the investment data management and regulatory reporting space.

 

 

Nicklas Nilsson is a Regulatory Specialist at CSS concentrating on global transaction reporting, including SFTR, MiFIR and EMIR. Nicklas is currently in a cross-functional role covering the regulations from analysis to implementation. He has eight years of experience working in the finance industry, including operational experience in fund reporting and regulatory implementation. Prior to joining CSS, Nicklas held positions at Swedbank, SEB and Wahlstedt Sageryd.

 
 

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Coffee and Regs

Mastering the Marketing Rule

Mastering the Marketing Rule

 

In this episode, CSS’s Co-Executive Directors of Compliance Services Keith Marks and Jackie Hallihan sit down to discuss actionable takeaways on implementing the SEC’s new Marketing Rule for registered investment advisers within the next 18 months.

 

 

About Our Guest Speakers:

 

Keith Marks is involved in the management and distribution of Compliance Solutions Strategies’ (CSS) products and services. He works across CSS to find regulatory data and reporting solutions that investment managers need. Keith manages a team of Directors, Consultants and Compliance Managers in CSS’s Compliance Services team who provide consulting, annual compliance program reviews, risk assessments, on-site mock examinations, registration services, and cybersecurity services to institutional wealth managers, private fund managers, retail wealth advisers, and registered investment companies. He also helps coordinate educational conference agendas and speakers. Keith is an author, product contributor, and thought leader. His product contributions have included the design of the Form ADV Part 2 Template distributed to over 6,000 advisers in 2010-12, and his vision of compliance program management built into CSS’s Compliance Management solution. With his colleagues, Keith’s most recent significant publication is “Big Data, Using Data Analytics”, Modern Compliance vol. 2, ch. 23 (2017). Keith joined Ascendant in 2007, and became a part of CSS in 2016. Prior to Ascendant, Keith was an instructor for the Center for Compliance Professionals and Director of Investment Adviser Services at National Regulatory Services (NRS). Keith practiced law previously as an Associate with Day, Berry & Howard LLP (now Day Pitney LLP), a Hartford, Connecticut law firm in 1996-98. Keith served as a law clerk for two years in Connecticut’s Supreme Court and Appellate Court after earning his Juris Doctor degree Magna Cum Laude from Western New England University School of Law and his Bachelor of Arts Magna Cum Laude from the University of Connecticut. He is a member of the State Bar of Connecticut, and is actively involved in raising funds for the Polycystic Kidney Foundation (www.pkdcure.org). Keith served as President of the New England Broker Dealer Investment Adviser Association (NEBDIAA), a non-profit organization, incorporated in 1997, from 2012-17. He has been on the Board of Directors of SOAR Educational Enrichment, Inc. since 2013, and Board Chair since 2015. SOAR is a privately funded 501(c)(3) providing educational enrichment programs to Keith’s local elementary school.

 
Jackie Hallihan is the Co-Executive Director of CSS’s Compliance Services team and has over 25 years’ regulatory and risk management experience. She was the founder of National Regulatory Services (NRS) which started the compliance resource business and served as its President for over 20 years. She also founded the National Society of Compliance Professionals (NSCP), a non-profit organization for compliance officers, staff and lawyers serving the compliance industry. It now boasts over 2000 memberships. Jackie has been a leading speaker to compliance professionals, including in-house training programs and various other industry association conferences, and has received numerous industry awards. Jackie also serves as Director, Clerk of the New England Broker Dealer Investment Adviser Association (NEBDIAA), a non-profit organization, incorporated in 1997. The purpose of NEBDIAA is to provide a forum for the professional exchange of information among investment advisers, broker dealers, and persons who provide services to investment advisers and broker dealers, and to direct communication among its members which will improve their ability to serve the needs of their respective clients. The forum will help NEBDIAA’s members meet the increased regulatory demands placed on investment advisers, broker dealers, and persons who provide services to investment advisers and broker dealers.

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Coffee and Regs

Preparing Now for a PRIIPs KID Project Plan

In this episode, CSS’s resident document production experts, Shane O’Sullivan and Charles Seigle-Goujon sit down to discuss how to prepare now for the UCITS to PRIIPs transition using best practices from the insurance industry and getting data governance procedures in place today.

About Our Guest Speakers:

Shane O’Sullivan recently joined the CSS team and is Director of Sales for the Irish market. Prior to joining CSS, Shane spent six years working for Institutional Investor in Melbourne and London. Shane managed new and existing relationships with global fund managers in Australia, America, UK and the Middle East. In 2018, Shane returned to Ireland to take a role with FundAssist to develop new business with global asset managers to meet their regulatory challenges. Shane holds a BA in Economics and a Masters in Financial Economics from University College Cork.
 
 

 
Charles Seigle-Goujon joined the Fund Reporting branch of CSS at the beginning of 2017 to develop the strategy in France, Switzerland and Luxembourg thanks to 10 years of experience in sales and account management for the Financial industry. Starting his career at Amundi and Henderson in institutional sales for alternative funds in Paris, he then moved to the Fintech industry in mid-2009 in Singapore where he was the head of Client Relationship Management South East Asia at FIS – ex SunGard Global trading.