David Somers II, Esq.
Suffield, CT 06078 *************@*****.***
SUMMARY
A self-motivated Compliance and Legal professional with 10 years of
financial services experience who has subject matter expertise in broker
dealer and investment adviser regulation. Licensed attorney admitted to
State of Connecticut Bar in 2000 and has obtained the FINRA / NASD Series
7, 24, and 66 licenses. Known for being a diligent, strategic, creative,
and productive team player who works effectively in cross-functional teams
and produces accurate and high quality work product. Strong working
knowledge of financial services and insurance industry products, services,
and operations.
KEY ACCOMPLISHMENTS
. Subject matter expertise in FINRA and SEC rules and regulations,
including the Investment Advisers Act of 1940 with practical working
knowledge of the Investment Company Act of 1940, ERISA, state insurance
regulation, AML / BSA regulation, and data privacy/security regulation
and best practices.
. Responsible for writing and updating Advest's Form ADV Part II (Schedule
H Wrap-Fee Disclosure Brochure) and policy and procedures in Advest's
Investment Adviser Compliance Manual.
. Responsible for drafting, reviewing, negotiating, and revising all
client and vendor contracts and client proposals for department and
served as department's liaison with company's senior contracting
executive and outside counsel.
. Managed, coached, and supervised four account due diligence employees
who conducted initial and ongoing suitability reviews of advisory
accounts, fee-based brokerage accounts, alternative investments, and
mutual fund and annuity transactions in conjunction with periodic review
of trading activity in 18,000 accounts ($6 billion).
. Primary developer, senior editor, and project manager for "LIMRA
Regulatory Review" compliance newsletter which grew to 1,000 subscribers
after one year of publication.
PROFESSIONAL EXPERIENCE
LIMRA / LL Global, Inc., Windsor, CT
Director of Regulatory Consulting, Compliance & Regulatory Services 2007 -
2010
. Supervised and directed LIMRA's Regulatory Consulting team of 30
independent contractors who provided high-level broker dealer,
investment adviser, and AML / BSA consulting and audit services.
. Responsible for drafting, reviewing, negotiating, and revising all
client and vendor contracts and client proposals for department and
served as department's liaison with company's senior contracting
executive and outside counsel.
. Independently increased operational efficiency by standardizing
department's internal policies and procedures which included creating
and implementing a 48 hour turnaround process for all department client
proposals and contracts.
. Researched and updated LIMRA's broker dealer and investment adviser
audit templates.
. Provided guidance and recommendations to management on internal risk
management issues and policy and procedures changes.
. Counseled senior management on topical regulatory issues and produced
high-quality research and analysis reports in a timely manner.
. Primary developer, senior editor, and project manager for "LIMRA
Regulatory Review" compliance newsletter which grew to 1,000 subscribers
after one year of publication.
. Participated and collaborated in department's product development,
marketing, sales, and strategy initiatives which included working
closely with company's Marketing, Sales, and IT departments.
. Served as department's representative for three company-wide planning
and implementation committees: SAS 70, Code of Ethics, and Microsoft
Sharepoint.
. Developed and coordinated joint LIMRA / NSCP quarterly roundtables and
administered private LinkedIn.com group for participants.
Audit Services Consultant, Compliance & Regulatory Services 2006 - 2007
. Managed LIMRA's largest broker dealer audit services client overseeing
600 field office audits annually.
. Performed quality review process for completed audit reports to ensure
that LIMRA's examiners conducted field audits properly and completed
audit reports accurately.
. Worked with client firm's staff to review and update firm's audit
templates to comply with the latest FINRA and SEC rules and regulation
as well as changes to firm's internal policy and procedures.
. Trained LIMRA examiners on client firm's audit requirements and relevant
regulatory topics.
Advest, Inc. (acquired by Merrill Lynch), Hartford, CT
Compliance Officer & Vice President, Wealth Management Oversight 2001 -
2006
. Managed, coached, and supervised four account due diligence employees
who conducted initial and ongoing suitability reviews of advisory
accounts, fee-based brokerage accounts, alternative investments, and
mutual fund and annuity transactions in conjunction with periodic review
of trading activity in 18,000 accounts ($6 billion).
. Served as primary liaison between Wealth Management department and Legal
and Compliance departments.
. Advised Senior Management on sales practice issues and proposed
regulatory changes.
. Responsible for writing and updating Advest's Form ADV Part II (Schedule
H Wrap-Fee Disclosure Brochure) and policy and procedures in Advest's
Investment Adviser Compliance Manual.
. Drafted, negotiated, and reviewed investment management contracts with
35 third-party sub-advisor firms.
. Drafted, reviewed, and revised client investment advisory contracts, fee-
based brokerage contracts, financial planning contracts, and
miscellaneous disclosure documents.
. Drafted Advest's Code of Ethics and Proxy Voting Policy and Procedures
documents and was responsible for implementation and enforcement of
related policies and procedures.
. Reviewed marketing and sales materials, performance composites, and
wrote appropriate disclosure to ensure compliance with Advisers Act.
. Provided ongoing regulatory advice and training to 515 Financial
Advisors and corporate employees.
National Regulatory Services (NRS), Lakeville, CT
Investment Adviser Consultant 2000 - 2001
. Completed registration process for SEC and state registered investment
adviser clients via IARD.
. Drafted and filed Form ADV and reviewed advisory contracts for RIA
firms.
. Interviewed and counseled clients on federal and state regulatory
requirements, internal policies and procedures, and proposed regulatory
changes.
EDUCATION
Juris Doctor, Western New England College School of Law, Springfield, MA
Class Rank: Top 13%; 22/169 - Cum Laude
B.S., Business Management, Bentley University, Waltham, MA
. Minor in Computer Information Systems
. GPA: 3.0/4.0; GPA in Major: 3.4/4.0
. Zeta Beta Tau Fraternity (Executive Board Secretary)
LICENSES
FINRA / NASD Series 7, 66, and 24 (inactive as of September 2009).
Currently studying for the Series 65 (Uniform Investment Adviser Law)
examination.
AFFILIATIONS
Member of the National Society of Compliance Professionals (NSCP) since
January 2002.