JEFFREY A. BUSH

**** ******** **** ** *******, IN 46040 317-***-**** ad3h8b@r.postjobfree.com

PROFESSIONAL

Admitted to practice in the State of Indiana, Northern and Southern Federal District, October 2004. Admitted to practice in the State of California, December 2003. EMPLOYMENT

Goelzer Investment Management, Inc.

General Counsel & Chief Compliance Officer 2018-Present

• Consulted with Senior Leadership on Legal Issues o Drafted and negotiated contracts, including service contracts and employment agreements o Advised Senior Leadership on corporate stock transactions for an S-Corp including updating the firm’s Non-qualified Stock Ownership Plan

o Provided advice and consultation for the company Employee Stock Ownership Plan, including loans, distribution analysis, and membership

o Recommended courses of actions on company 401(k) to both the company and to employees o Developed a plan for inorganic growth for future acquisitions by the firm o Reviewed state and federal laws and regulations to update the firm’s policies and procedures as necessary

• Responsible for all compliance duties as Chief Compliance Officer of the Securities & Exchange Commission (“SEC”) registered investment advisers in the firm o Performed and supervised transactional, periodic, and forensic testing of firm operations to ensure compliance with regulatory requirements and best practices o Chair of Risk Management Committee, which analyzed and mitigated risks facing all aspects of an investment adviser’s business

o Developed a due diligence program to ensure that vendors meet the best practices to protect the firm’s business and confidential information

o Formulated a cybersecurity program including Written Information Security Protocols and Cybersecurity Incident Response Plan

o Created an education initiative to keep the firm employees informed of all applicable regulatory requirements

o Represented the firm through multiple SEC routine examinations o Led the firm through initial Global Investment Performance Standards compliance and subsequent verifications

o Managed compliance software including National Regulatory Services Compliance Guardian and ACA Compliance Alpha

Chief Compliance Officer 2012-2018

• Responsible for all compliance and testing duties mentioned above

• Served as Chief Compliance Officer of a FINRA member broker-dealer until the firm withdrew its broker-dealer registration in August 2015

• Supervised the firm’s anti-money laundering program

• Represented the firm through a Financial Industry Regulatory Authority routine examination Indiana Secretary of State, Securities Division

Chief Deputy Commissioner July 2006-December 2012

• Developed, Formulated and Enforced Policies and Procedures for the Indiana Securities Division o Created and drafted updates to the statutes overseen by the Securities Division and represented the Securities Division before the Indiana Legislature during the legislative process o Implemented policies both for internal staff and for the Securities Division in its external actions

• Supervision of Securities Division Staff

o Supervised and provided guidance to six staff attorneys on interpretations and strategic decisions concerning the Indiana Securities Act, Indiana Uniform Securities Act, Indiana Loan Broker Act, and Indiana Franchise Act

o Developed enforcement initiatives pursued by the Indiana Securities Division attorneys and investigators

o Administrative oversight over licensing functions and all other operations of the Securities Division

• Indiana Uniform Securities Act

o Created the initial draft of the Indiana Uniform Securities Act from the 2002 Uniform Securities Act

o Served on the Indiana Uniform Securities Act Committee of local experts in securities law that debated and refined the initial draft

o Taught continuing legal education classes on the new statute as well as other topics

• Expert Witness

o Served as an expert witness in securities matters in two separate criminal trials under Indiana state law

o Served as an expert witness in a federal sentencing hearing on penalties under the Indiana Loan Broker Act

Enforcement Attorney March 2005 – July 2006

• Represented the state of Indiana in administrative enforcement securities cases by drafting complaints and orders, negotiating settlements, and conducting hearings that resulted in the revocation and suspension of licenses and other administrative penalties

• Lead examiner of all state registered securities offerings in Indiana through review of registration statements

• Drafted legislative updates to the Indiana Securities Act and other statutes EDUCATION

University of Washington School of Law, Seattle, WA, L.L.M. Taxation, June 2004 Vanderbilt University Law School, Nashville, TN, Juris Doctorate, May 2003 Calvin College, Grand Rapids, MI, B.A. Psychology and Philosophy, May 2000

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