TIMOTHY SULLIVAN

Mobile: 075********

INVESTMENT & COMPLIANCE CONSULTANT

Email: acy1h9@r.postjobfree.com

Nationality: British

Domicile: Surrey

Languages: French & Spanish: Fluent - Spoken

Profile

Fellow of the Chartered Institute of Securities & Investment with a long term, and successful career of regulated Sales Process Review and interaction with Financial Planners & Intermediaries

Former Global Fixed Income Portfolio/Fund Director

Extensive experience of “in situ” and remote Project Management

Experience of Compliance, Thematic reviews & Conduct Risk

Extensive experience of Managing Investments & Compliance Advisory

Extensive experience of KYC/AML/Sanctions/Suitability/EMIR/EMEA

Extensive experience of Remediation & Redress

Former FCA contractor on AIFMD Onboarding & Authorisations Project

October 2016-January 2017, MIFID 2 intensive training, working on “live” client driven projects, (MAR, EMIR, MIFIR/MIFID2, Data Mapping & Retention policies, RTS Scoping, Costings, Pre & Post trade Reporting schemes, Best Execution & extensive Compliance documentation)

Pension Management & Transfer Reviews

Education/Qualifications

2005: Fellow of the Chartered Institute of Securities & Investment (admitted by Examination & Experience in December 2005)

2013: Passed “Integrity & Ethics” paper of CISI (above)

1980: BA (Honours) King’s College London University Graduate in French Studies, with Spanish Subsidiary.

Project Management applications and methodologies:

Miura Consulting MIFID2 Projects Training, Management & Project Scoping

(October 2016-January 2017)

MIFID II Specialist

Project: Best Execution MIFID II

Trained in MiFID II Regulatory Technical Standards, MiFID II Delegated Acts and the projects to satisfy the Regulatory Technical Standards and Delegated Acts including Pre and Post Trade Transparency, requirements for Algorithmic trading, MiFIR Transaction reporting and Best Execution and function of Systematic Internaliser.

I have been working with analytics software and solutions companies on the development of the Best Execution reports and MiFIR Transaction Reporting for trading venues and investment banks.

Responsible from business analysis & requirements gathering, working on designing the reports in line with the MiFID regulation, preparing test cases, organizing and executing of UAT testing together with presentation and user training.

Scoping and Action Points from RTSs for Investor Protection, Costs & Charges and Suitability & Appropriateness

SG Hambros Bank Limited, London (Contract) August 2016-September 2016

Complex Investment Complaints Review. Project Manager, Review Project of Complex Complaints in respect of Investment Products, such as Pension Transfers. Sole independent reviewer. Subject matter substantially Pension Transfers, Trust arrangements and EIS Investments.

Investec Wealth Management, London (Contract, June 2016-July 2016)

Investment Suitability Review Project. One of 2 contractors hired to assess Investment Management Private Client files for Suitability. Multiple checks, including, but not limited to, documentation, correspondence, call monitoring, advice, risk and nature of mandate, Client Reviews & report/review predominant themes arising.

Rathbone Investment Management-Vision Independent Financial Planners, UK wide (Contract, November 2015-May 2016)

Project Manager, QA & QC, remotely managed, directly responsible for Investment Suitability Review Project to facilitate sale of Vision IFP client base to Rathbone Investment Management. Initial review of 1,400 potentially High Risk client files for review, defined as Pension Transfers, Potentially vulnerable Clients, EIS investments & specialised Trust vehicles. Project run remotely, with regular audio contact and electronic reports & Updates. Extensive & exhaustive Checklist to include all mandate documentation & adherence thereto, Client Knowledge & Experience, Affordability, Fees & Charges, frequency & content of client contact, additional investments (or withdrawal), tenets of TCF, RDR,EMIR

Julius Baer International Limited, London (Contract, September 2015 to November 2015)

File Repair, under Investment Suitability Review Pilot project (Manager), to assess and review all Private Client Investment files for audit trail, documentary conformity, and Suitability of Client outcomes. Terms of reference per FCA Guidelines, to include all checks and balances supporting Portfolio style, Risk, Objective, Client dialogue, level of Client knowledge and expertise, clarity & fairness of correspondence, and, inter alia, transparency of fees. Full time engagement with Front Office & Relationship Managers, including ‘coaching’, with a view to long term’ best practice’ and file integrity. Thematic Reviews & rigorous KYC & Oversight/Review of EMIR, EMEA considerations.

Canaccord Genuity Wealth Management, London (Contract, August 2014, to January, 2015)

Senior File Reviewer & Project Manager for Investment Suitability initiative. Review, scrutiny and assessment of Discretionary and Advisory Private Client & Trust portfolios for Suitability, as defined by ESMA and FCA guidelines & Mifid, latterly Mifid2. QA of Sales advice and Suitability of Investment Portfolios covering Risk, Ability to absorb loss, Asset Allocation, Client knowledge & Experience, plus overhaul of Fees & Charges. Phone call monitoring for Suitability of Investment Advice, Pensions & Transfers within Regulated Sales. Significant focus and emphasis on role and quality of Intermediary Business, (covering FPs and IFAs). Recommendation and implementation of wholesale system and strategic changes, including but not limited to: new Front Office System, recalibration of Investment Restrictions & Guidelines, full review of “In house solutions” including UCITS, Consolidation of smaller accounts, Overhaul of Audit Trail, fees and transaction charges.

FCA (Financial Conduct Authority) London (Contract, April 2014 to July 2014) Onboarding Manager

Engaged to analyse AIF applications of qualifying Fund Managers, under new EEC led legislation AIFMD (Alternative Investment Fund Managers directive), authorisation deadline for which was July, 2014. Specialised in the scrutiny and Review of AIF applications for their compliance with the Directive, and of the newly defined Depositaries (as distinct from Custodians) for their ability to carry out these recently designated functions. Required to liaise with management of applicant firms every day, to enable them to complete their applications with the requisite & correct data. Guiding and negotiating with CIOs and/or Compliance Heads to ensure conformity with division of hierarchical and functional responsibilities, as stipulated in the directive.

Coutts Bank London/Guildford (Contract, Nov 2013 to Jan 2014)

Senior File Reviewer in an “Investment Suitability” File & Portfolio Review & Assurance project, assessing Private Client Discretionary Investment Portfolios for Suitability (Regulated Sales) pre- and post- RDR. Role required Point of Sale Reviews, Current Reviews and Full review of Files and Portfolios pertaining to Vulnerable/Later Life Clients and High Risk portfolios and inward Pension transfers, “In House” Funds & platforms, including UCITS. Remediation analysis, where appropriate and full KYC/AML/RDR/MIFID review. IFA & FP roles and introduction of business quality reviews, including remediation where required.

Lloyds Bank plc. London (Contract, February 2013 to April 2013)

Senior File Reviewer & Subject Matter Expert (SME) and, later, Senior QA, engaged to analyse and determine level of redress in cases of Mis-Selling of Interest Rate Derivatives. Successfully differentiated between Sophisticated and Unsophisticated Investors (per FSA Guidelines of Feb 2013) and drew up suitable candidates for Remediation and/or redress.

Rigorous file scrutiny, company searches, lists of directors, sales telephone call monitoring and client interviews.

Deutsche Bank Private Wealth Management (Contract, Nov 2011 to Dec 2012)

File Reviewer & QA, for an FSA sponsored “Suitability” project, initially to examine the integrity and suitability of 20,000 accounts and thence to a complete overhaul or process and structure in preparation and readiness for, and to comply with, the requirements of RDR, CASS and Mifid. All types of asset class reviewed, including differing legal vehicles, fees, portfolio styles, funds and structures. Intermediary Desk review, to cover role and quality of IFAs and FPs, as to suitability of advice, Pension Transfers, audit trail, and client screening. “In house” funds and solutions including recourse to UCITS.

Topland Group, September 2010 to November 2010

Securities Investment Manager, Private Wealth Management

HSBC Global Asset Management, London (Ten years, August 2000 to August 2010)

Recruited as Director, to launch Private Client & SME Discretionary Global Fixed Income Capability.

Promoted to Senior Director, within the first year.

Over the following 7 years, raised over £ 2 Billion in new assets.

Appointed to FSA “166 Review” Group, for Equity Portfolio oversight.

Senior Director for Business Development, Middle East, South & Central America, Mexico, excluding USA.

Raised a further £ 1 Billion in new assets over the ensuing 3 years.

Formed team to build new front office system, UAT and reaffirmed early stages of CASS regime

Frequent inter Group foreign travel and international sales and many SLAs written & delivered.

Restructured and rewrote international Sales Standards and Compliance Manual, as part of a team.

Very regular exposure to and interaction with Financial Planners and IFAs, including seminars, presentations and screening for suitability of Investment Advice & Recommendations, introducing stringent “check lists” to facilitate introduction to Discretionary Service. Managed Fixed Income range of HSBC Funds (Dublin/Luxembourg domicile) including design (and management of) UCITS.

Regular budget presentations and interaction with Main Board, and office of The Chairman and CEO (due to registration of new clients from regions, at that time not subscribed to International Anti Money laundering standards).

Heavily involved in Investment Management restructure and rebranding, post “166 Review” & introduction of Mifid .

Media exposure on BBC, CNBC, Bloomberg discussing Fixed Income and Global Macro

ABN AMRO Bank (Suisse) Zurich, Switzerland (1998 to 2000)

Head of Investment Strategy

Fixed term (18 month) contract to rationalise and completely overhaul a disparate Private Client Investment Business. Primarily focussed on Investment Process polarisation and performance dispersion. Radical review of business introducers and ethical standards. Achieved under budget, and ahead of schedule, centralising Investment Process in Zurich, closing certain centres and redeploying staff, without job losses.

Other employment:

Mitsubishi Trust & Banking, London (Treasury Manager) 1997-1998

Commerzbank Asset Management Asia Ltd, Singapore (CIO & MD) 1995-1996

Citibank Global Asset Management, Hong Kong & Singapore Senior Portfolio Manager (1989-1994)

NZI Securities (Hong Kong) Limited, Hong Kong Treasury & Capital Markets Manager (1987-1989)

Girozentrale Vienna (Austria) London & Hong Kong FRN Sales (1984-1986)

Manufacturers Hanover Limited London, Syndicated Loans Manager (1982-1984)

Standard Chartered Bank London-Hong Kong-Oman, Covenanted Officer (1980-1982)

Systems

System familiarity: Sentinel, thinkFolio, Charles River, Bloomberg, Reuters & diverse Microsoft applications

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