Howard Beach, NY 11414
**/** – Present: PEM III LLC
Responsible for providing strategic advice and guidance to the executive management, legal, and compliance teams at Fidelity Investments in their development of an institutional investment management service to investment advisers, broker-dealers, banks, and family offices. Consulted and advised on registration, contractual and investment advisory matters for the legal team and developed the policies and procedures and annual review testing infrastructure for the compliance team.
8/18 – Present & 12/16 – 9/17: BATES GROUP
Expert Witness and Compliance Consultant
Engaging with Bates professionals to create business development opportunities and develop the Compliance Consulting and Expert Witness practices.
9/17 – 8/18: ORIX USA
Managing Director & Chief Compliance Officer
Responsible for developing and implementing a world class compliance framework and program for the company and its subsidiary entities throughout the U.S and Latin America. The compliance program encompasses the following businesses: asset management, private equity, CDOs, structured products, commercial real estate, energy debt and equity solutions, fund investments and alternative strategies, low-income housing tax credits, middle-market lending, multi-family/senior living bridge and agency capital, and municipal/infrastructure lending and investment. These businesses include several registered investment managers and broker-dealers. Responsible for AML compliance and FCPA/anti-corruption due diligence compliance for all entities. Oversee new product development process. Developed internal controls processes with Internal Audit and external providers. Management reporting to Executive Committee, Board of Directors and Audit Committee. Manage a team of 12 professionals.
4/11 – 12/16: LPL FINANCIAL
Executive Vice President & Chief Compliance Officer; Advisory and Conflicts Management Officer
Chief Compliance Officer for all investment advisory businesses of LPL and two affiliated entities (Fortigent and IAG). Responsible for the supervision and oversight of the investment advisory activities of 10,000+ Financial Advisors and for the oversight of the Research Department. Responsible for the Investment Adviser Annual Review testing program. Member of numerous executive management and risk/compliance oversight committees, including the Risk Oversight Committee chaired by the firm’s CRO and the Advisory Business Oversight Committee (Chairman). Responsible for the design and implementation of the firm’s supervisory and compliance oversight program for the Department of Labor’s Fiduciary Rule and member of the DOL Steering Committee. Developed new advisory programs and designed and implemented the new supervision/surveillance tool. Member of the Private Trust Company’s Board of Directors and Audit Committee. Conflicts Management Officer for the firm. Head of Marketing Regulatory Review team. Executive liaison to the GRC Employee Engagement Working Team. Mentor to numerous GRC employees. Supervised a staff of 100+ professionals.
4/06 – 2/11 & 11/99 – 4/05: MERRILL LYNCH GLOBAL WEALTH MANAGEMENT
First Vice President & Assistant General Counsel
Senior counsel for various investment management, wrap fee, mutual fund transfer agent, broker-dealer, retirement advisory, executive financial planning and wealth planning products and services. Lead counsel for the Financial Advisor as Portfolio Manager/Advisor Programs that oversee in excess of $100 billion in client assets. Responsible world-wide for all international legal issues relating to the investment managements products and services. Also responsible for all Cross Investment Management Product/Business issues for the firm’s investment management programs. Lead investment advisory counsel for the transition of $100+ billion of client assets from the fee-based brokerage program to alternative programs. Provided strategic advice and counsel to senior management in the development of the firm’s investment management and related platforms including the creation of new investment management, wrap fee, broker-dealer, retirement advisory and executive financial planning products and services. Counsel to equity and fixed income trading desks. Developed supervisory and internal reporting systems and created policies and procedures for the above products and services. Provided counsel on regulatory and litigation matters pertaining to the aforementioned products and services. Speaker at numerous industry-sponsored and firm training programs. Supervised 1 professional.
4/05 – 4/06: MORGAN STANLEY
Chief Compliance Officer & Executive Director
Chief Compliance Officer for all investment advisory products and services of the firm that totaled in excess of $150 billion in assets. These products and services were utilized by ultra high net worth and retail clients and included alternative investments, separately managed accounts, wrap fee programs, mutual funds, managed futures, retirement programs, asset allocation services and financial planning/wealth planning services. Developed supervision systems and internal control functions. Oversaw the creation of policies and procedures. Responsibilities also included supervision of the Compliance Marketing Review Department which reviewed all sales literature and marketing materials for the firm. Member of the New Products Committee and the Best Execution Committee. Supervised a staff of 12 professionals.
4/97 – 8/99: BANKERS TRUST COMPANY
Principal and Director of Private Bank Compliance
Responsible for Private Bank Compliance. These responsibilities included overseeing compliance with all U.S. federal and state banking, investment management, securities, trusts, employee benefit, derivatives and self-regulatory organization laws, rules and standards. The Private Bank had in excess of 17 institutional products and services covering the following product categories: investment management (U.S. domestic, international and derivatives-based), trust, mutual funds, hedge funds, fixed income, derivatives, exchange funds, custody, banking and lending. Oversaw distribution of Private Bank products and services through Relationship Management and broker-dealer (BT Alex. Brown) Investment Representatives. Liaison with all international and broker-dealer Compliance Officers, as well as all other control groups including Legal, Risk Management and Internal Audit. Major projects included development of Private Bank Compliance Policies and Procedures Manual, Private Bank Annual Compliance Training Program for all 700+ U.S. domestic and international employees and development and purchase of a new portfolio management compliance system. Supervised 1 professional.
9/93 – 1/97: PRUDENTIAL SECURITIES INCORPORATED
First Vice President and Associate General Counsel
Counsel to entire firm regarding all investment management products and programs maintained at Prudential Securities and to the unit investment trust and certificate of deposit product group. Developed new investment management products and programs. Counsel to equity and fixed-income trading desks. Oversaw all legal and regulatory matters concerning the investment management business. Counsel regarding certain broker-dealer issues. Counsel to Investment Management Business Review Committee. Member of Securities Industry Association’s Investment Adviser Committee. Supervised a staff of 5 professionals.
5/90 – 9/93: GABELLI ASSET MANAGEMENT COMPANY
Vice President, General Counsel & Assistant Secretary
Responsible for the firm’s asset management and related broker-dealer activities. Experience included negotiating all asset management and related contracts; oversight of trading desks; directly coordinated federal regulatory examinations; negotiated issues resolution with federal and state regulatory authorities; successfully guided firm through multi-jurisdictional blue sky registration; maintained compliance procedures; oversight of the asset management sales staff; participated in corporate administration as Assistant Secretary; and responsible for the oversight of outside counsel. The firm’s products included institutional asset management accounts, mutual funds, hedge funds and brokerage services. Counsel to equity and fixed income trading desks.
3/87 – 5/90: U.S. SECURITIES AND EXCHANGE COMMISSION
Staff Attorney – Enforcement Division
Litigated and investigated matters in the civil and administrative forums, including the largest free-riding scheme ever uncovered by the Securities and Exchange Commission. Conducted depositions and testimonies. Assisted and advised U.S. Attorneys, IRS, FBI and District Attorneys in their prosecution of joint matters.
10/86 – 3/87: WEIL, GOTSHAL & MANGES
Discovery phase of the Shoreham Nuclear Plant litigation; participant in the Litigation Training Seminars.
J.D. 1986: St. John’s University School of Law
Activities: Civil Trial Competition; Tax Club; Sports and Entertainment Law Society.
B.S. 1981: St. John’s University College of Business Administration
Honors: Graduated Magna Cum Laude, 3.8/4.0 – Top 2% of Class; Dean’s List 1977-1981; Beta Gamma Sigma; Omicron Delta Epsilon; Executive in Residence Business Honors Program.
Activities: Society for the Advancement of Management; Prospective Student Open House Program; Tae Kwon Do Team.
New York State Bar Association and SIFMA Compliance and Legal Division
Frequent Speaker at industry conferences including the SIFMA Compliance and Legal Division’s Annual Conference, the SIFMA Charlotte Regional Seminars and firm sponsored events
Series 7 and 24
20+ years as a Little League Baseball Coach and Basketball Coach; Safe Alliance Domestic Violence Shelter; Dedicated to empowering and mentoring developing talent; Participant in numerous firm sponsored volunteer activities
Family, travel, mentorship, golf and exercise