Tag: regulatory compliance

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Digital Assets: Trading & Compliance for Cryptocurrency

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:


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.
 

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.
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Regulator Insights & SEC Exam Priorities

Regulator Insights & SEC Exam Priorities

 
In this episode, CSS’s team of CCO experts Korrine Kohm and Dan Haynes discuss regulatory examinations, SEC priorities and trends and insights into how compliance teams can be more proactive before the regulators come knocking.
 

 

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.
 

 

 
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.
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The Latest News & Analysis on the PRIIPs RTS

The Latest News & Analysis on the PRIIPs RTS

 
In this episode, CSS’s Chief Product Officer Ronan Brennan does a technical deeper dive into the latest news on the PRIIPs RTS, regulatory timelines and the challenges stemming from divergence between the EU and UK.
 

 

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.
 

 

 
Natalie Silverman serves as CSS’s Chief Marketing Officer. A leading FinTech specialist, Natalie has over 18 years of go-to-market and strategic expertise in financial services, SaaS, media and news. Most recently she has helped to build innovation labs across startups and enterprises.
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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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Betting on Bitcoin: Cryptocurrency & Digital Assets 101 for Investment Managers

Betting on Bitcoin: Cryptocurrency & Digital Assets 101 for Investment Managers

 
In this episode, CSS’s Director of Broker-Dealer Services and Private Funds John Gentile sits down with Chief Executive Officer & Chief Investment Officer of Off the Chain Capital, Brian Estes to discuss the world of cryptocurrency and Bitcoin. Is this investing or gambling, is it an asset class, and why should investment advisers and broker-dealers be thinking about adding digital assets to their clients’ portfolios?
 

 

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.

Brian Estes is the CEO and CIO of Off the Chain Capital which manages the #1 performing blockchain investment fund over the past 4 years. Brian has been a VC in blockchain for over 7 years and has advised, mentored and/or financed 5 blockchain companies that have a combined value of over $100B today. Prior to his immersion in blockchain, the Brian was one of the top-ranked investment managers in the nation. Morningstar ranked his client’s performance between 2004-2014 in the top 1/10th of 1% of the Morningstar equity manager universe. Brian earned his BA in Economics from the University of Illinois, his MBA with high honors from Washington University, and has studied at Cambridge University and the London School of Economics. For fun, Brian earned his pilot’s license in 1989 and has logged over 2200 hours of flight time in his Cessna 177RG.

 
 

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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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ESG and the Impact of the EU SFDR on U.S. Asset Managers

ESG and the Impact of the EU SFDR on U.S. Asset Managers

 
In this episode, CSS’s Head of ESG Marye Cherry sits down with corporate attorney at Scale LLP, Adam Johnson to discuss the evolving ESG landscape from the U.S. perspective, including the impact of the EU SFDR on U.S. asset managers and the U.S. regulatory position on ESG.

 

About Our Guest Speakers:

Marye Cherry is the EU Regulatory Counsel and Head of ESG at Compliance Solutions Strategies (CSS). With more than 10 years of legal and compliance experience, Marye specializes in transparency and regulatory reporting issues in the financial services industry, including sensitive industries and ESG. At CSS, Marye focuses on European financial regulations that affect fund managers’ operations worldwide and helps translate those requirements into automated reporting solutions.
 
 


Adam Johnson advises individuals and institutions on investment and corporate law. He has more than twenty years of experience working with clients around the world on public and private investment vehicles, financial marketing and distribution, regulatory and governance issues, and capital markets transactions. He has worked with professional asset managers, high net worth individuals, and corporations in the public and private equity markets. He helps clients strategize on business development, negotiate complex agreements, navigate changing regulatory frameworks, address compliance obligations, and find efficient operational solutions. Working as both outside and in-house counsel, he has helped companies around the world meet their strategic business, corporate governance, and regulatory compliance challenges. Prior to Scale LLP, Adam advised business heads and senior management as a leader in the legal departments of publicly listed investment management firms. He has lived and worked in Asia and is proficient in Mandarin Chinese.

 
 

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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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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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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.