Angelo R. Framularo II, Esq. J.D. / M.B.A., CRCM

*** ******* ****** ~ Trumbull, CT 06611 ~ 203-***-**** ~ adikam@r.postjobfree.com

Financial Services Executive

Expertise

Compliance Risk / Operational Risk / Risk Assessment / Governance / Implementing and Managing Change in a Dynamic Environment/ Turnaround / Cyber Security / Analysis / Control Systems / Global Operations / Legal / SOX /Investment Banking / Risk & Crisis Management / Compliance / Intellectual Property / Communication / Vendor Risk Management /

Recognized For

Complex Problem Solving / Solution Implementation / Engaging with C-suite Leadership /Engaging with U.S. Federal Examiners / Engaging with Bank Board of Directors / Results Driven / High Level of Attention to Detail / Navigating Complex Matrix of Accountability and Stakeholders / Analyzing complex business challenges and developing solutions / Translating global vision into local tasks / Mentoring and Leading staff / Building Relationships with regulators

Results / Selected Accomplishments

Designing and Implementing Operational Risk Framework. LRB had no enterprise risk program in place. Designed, developed and executed a comprehensive ERM Framework based on COSO principles.

Designing Control Systems. RBS had no regulatory compliance program in place. Designed, developed and executed a comprehensive regulatory compliance monitoring and testing program, covering all applicable banking regulations. Ensured $0 in regulatory fines since inception and continues to maintain its industry leading position.

Managing Compliance Risk. Lead the compliance work stream at American Express for the re-launch of card acquisition in the Puerto Rico/Virgin Island Market, allowing re-launch of card acquisition the market.

Turn Around. Through an internal audit, UBS established that all un-reconciled trades were growing in dollar volume. Implemented daily procedures for Euroclear trade reconciliation, and department wide distribution of report. Reduced daily un-reconciled trades from $1B, to $1-2M by the end of each work day.

Project Management. UBS key trading systems were tied correctly to master file system. Initiated and completed the Orphaned GL Project - Identified, mapped, and reconciled accounts between key UBS back office systems. Successfully completed project leading to no system failures, and the ability to launch new back office systems.

Security Implementation. RBS internal audit revealed a large amount of unsecured data on our network. Implemented and completed a data cleanup and security sweep of all network drives. Guaranteed no more unsecured data was found on the network.

EXPERIENCE:

Millennium Group – New York, New York July 2020 – Present

Business Program Manager Lead- Contractor

Working with USAA as the Business Program Manager Lead for the Enterprise Affiliate Services Program (EASP).

Leading and delivering on a variety of large-scale risk and compliance related projects and programs.

Project management, creating new project plans, establishing management routines, and building detailed status reporting.

Enhancing complex operational processes with multiple handoffs, including building and testing business controls; process re-engineering.

Briefing and communicating with all levels of executive management.

Knowledge of third-party risk management regulations that apply to large financial institutions, including: OCC Bulletin 2013-29, SR 13-19, and Regulation W.

Knowledge of third-party risk management (TPRM) lifecycle.

Arrayo – New York, New York October 2019 – July 2020

Regulatory Risk Consultant - Contractor

Working with the Risk Regulatory Change Management team in a leading foreign banking organization (FBO) identifying, analyzing, and overseeing the timely implementation of new or changes to existing laws and regulations that impact the responsibilities of Americas Risk Management; and ensuring that appropriate change management initiatives are initiated.

Amalgamated Bank – New York, New York February 2020 – March 2020

Director Enterprise Risk Management

Responsible for executing the bank's Enterprise Risk Management (ERM) program, framework and operation to effectively identify, assess, monitor and report on the bank's full range of enterprise risks and risk mitigation actions.

Sarbanes-Oxley (SOX) program implementation.

Protiviti Inc. – New York, New York July 2019 – October 2019

Senior Manager – Process Audit - Contractor

Lead credit risk product audit for US banking client.

Laurel Road – Bridgeport, CT September 2017 – November 2018

Laurel Road Bank (formerly Darien Rowayton Bank)

Director, Enterprise Risk Management

Head of the Enterprise Risk Management (ERM) Team.

Responsible for ensuring the Bank's enterprise risk framework is effective in managing the operational risk profile of the bank.

Identification, assessment, measurement, monitoring and reporting of the Operational Risk profile of the Bank to the Executive Risk Committee and the Board of Directors.

Subject Matter Expert in Risk and Compliance Assessment

Design and Implementation of the Enterprise Risk Management framework

Oversight of Loss Events, Issues Management, and Change Management

Development and oversight of the operation of the regulatory development tracking tools

Identify key risk indicators to monitor these risks.

Subject Matter Expert in U.S. Banking Regulation.

American Express – New York, NY July 2010 – December 2016

American Express Centurion Bank (AECB)

Senior Manager – Compliance & Ethics

Member of the US Card Compliance Team, supporting the Consumer (CPS) and OPEN (the leading small business payments provider in the U.S.) Card Marketing Businesses.

Served as second line defense risk manager and subject matter expert, responsible for providing advice and guidance on the marketing’s advertising, digital and mobile strategy.

Subject Matter Expert in U.S. Banking Regulation for the CPS and OPEN Card Marketing Businesses.

Worked with the consumer, small business, and digital credit card businesses and the banks’ Compliance Risk Management Committees (CRMC) to identify risks and control gaps for inclusion in the New Products Approval Process (NPAP) in preparation for Committee evaluation, and federal regulator review.

Reviewed Business Requirements Documents (BRDs) to ensure consistency with regulatory guidelines, industry best-practices, and internal policies.

US Banking Compliance Team, overseeing the implementation and ongoing effectiveness of the Compliance Risk Management Program (CRMP) for the banks across the affiliate organizations.

Provide compliance support, guidance and direction in the management of an effective compliance program for CPS and OPEN.

Leading efforts for the implementation of other enterprise compliance risk management initiatives, specifically the Process Risk Self-Assessment (PRSAs) and annual Compliance Risk Assessment.

Assessing risks and identifying control gaps surrounding the consumer, small business, and digital credit card businesses and collaborating with Operational Risk and Process Owners to establish control processes and procedures to be added to the annual Process Risk Self-Assessment (PRSAs) and annual Compliance Risk Assessment.

Driving implementation of policy and regulatory requirements in the areas of consumer protection, credit card practices, banking, and other relevant federal, state and local regulations.

Collaborating with other Compliance teams to create initial and ongoing enhancements of the surveillance, monitoring and testing processes for consumer, small business, and digital credit card businesses, which included digital credit card products, analytics, marketing and communications.

Manages the Corrective Action process to ensure timely closure of issues and gaps across the Consumer and Small Business Card marketing business units.

Liaise regularly with other control stakeholders: Independent Compliance Testing (ICT), the Internal Audit Group (IAG), and other business control functions.

Reviewing proposed marketing campaign materials and strategies and provide strategic advice, direction and leadership to ensure effective mitigation of Compliance risks.

Driving enhancements to the Compliance Program, specifically, Compliance Key Risk Indicators and Board Reporting.

Represents Bank Compliance on various internal committees to drive improved outcomes for the Banks and effectively manage Compliance risk.

Prepared weekly/monthly/quarterly summary reports and metrics dashboards to inform senior management and The Board of Directors regarding the status of key initiatives (direct marketing, digital and mobile) and their associated risks.

Works closely with Compliance & Ethics colleagues throughout the organization to drive compliant execution of business objectives, and works closely with colleagues in the General Counsel’s Office, Advertising Review, Brand Management, Privacy, and Operational Risk teams.

RBS Card Services March 2005 – July2010

The Royal Bank of Scotland Group

Assistant Vice President - Compliance Manager

Member of the Operational Risk & Compliance Team

Designed, developed and executed comprehensive Regulatory Compliance Monitoring and Testing Program for the U.S. Credit Card division of The Royal Bank of Scotland Group - reviewed and analyzed applicable federal and state regulations, and developed comprehensive internal control testing.

Prepared and managed federal regulatory exams performed by the Office of The Comptroller of the Currency (OCC).

Implementation and Oversight of bank Policies and Procedures. Responsible for testing policies, procedures, and processes for ongoing compliance.

Managed operational risk of Consumer Banking products: Credit Cards and product cross-sell initiatives.

Sarbanes-Oxley (SOX) compliance: performed quarterly SOX testing.

Executed Anti-Money Laundering, Know-Your-Customer, and Regulation Z policies for the U.S. Credit Card division of The Royal Bank of Scotland Group.

Due Diligence work under the USA PATRIOT Act for the consumer and commercial credit card portfolio.

Developed comprehensive training program on internal bank BSA/AML policies and procedures.

Reviewed Business Requirements Documents (BRDs) to ensure consistency with regulatory guidelines, industry best-practices, and internal policies.

Subject Matter Expert in U.S. Banking Regulation: Unfair or Deceptive Practices Act (Reg. AA), Equal Credit Opportunity Act (ECOA) (Reg. B), Fair Credit Billing Act, Fair Credit Reporting Act (Reg. V), Fair and Accurate Credit Transaction Act (FACT Act), Fair Debt Collection Practices Act, Community Reinvestment Act (Reg. BB), Regulation CC, Electronic Fund Transfer Act (Reg. E), Right to Financial Privacy Act, Service Members Civil Relief Act (Soldiers and Sailors Act), USA PATRIOT Act, Bank Secrecy Act (BSA), Regulation O, Gramm-Leach-Bliley Act (GBLA), Regulation W, Truth in Lending (Regulation Z), Uniform Electronic Transactions Act (E-Sign Act).

Deloitte & Touche May 2004 – March 2005

Anti-Money Laundering Project Team

Executed Anti-Money Laundering, Know-Your-Customer policies for major global investment bank.

Due Diligence work under the USA PATRIOT Act for accounts opened prior to October 1, 2003.

Reviewed and analyzed hedge fund client structures and related documentation.

Trained team of 30 analysts in internal bank systems and project procedures.

Verified client information using third party information systems including Bloomberg, Dunn & Bradstreet, Lexis-Nexis, OneSource, Factiva, Choicepoint, Autotrack and Equifax RDC GRID.

UBS Investment Bank August 2003 – May 2004

Vetting Analyst

Strong knowledge of FSA, SEC and FINRA regulations. Knowledge of the rules under the Investment Advisers Act of 1940 and Investment Company Act of 1940.

Lead Vetting team for ABN AMRO Prime Brokerage client integration into UBS IB.

Due Diligence work under the USA Patriot Act for the Client Vetting Department of the Credit Risk Management Division.

Responsible for data accumulation and verification of client companies: Hedge Funds, FX Clients, High Net-Worth Individuals.

Ensured that various financial institutions’ files conformed to Federal Reserve, SEC, FSA requirements and internal policies.

Interacted with Trading, Credit, Legal and Compliance on various issues.

Orphaned GL Project - Identified, mapped, and reconciled accounts between key UBS back office systems.

Knowledge of the rules under the Investment Advisers Act of 1940 and Investment Company Act of 1940.

Familiarity with the Registered Investment Advisers Act, ISDA Agreements, The National Association of Securities Dealers (NASD), Nelson’s Directory of Investment Managers, Thomson Bank Directory, S&P Directory of Registered Investment Advisors, S&P Directory of Tax Exempt Organizations, and the U.S. Offshore Funds Directory.

UBS Warburg Stamford, Connecticut

Research Summer 2001

Knowledge of the rules under the Investment Advisers Act of 1940 and Investment Company Act of 1940.

Due Diligence work for the Account Vetting Department of the Credit Risk Management Division.

Responsible for data accumulation and verification of client companies.

Ensured that various financial institutions’ files conformed to Federal Reserve and SEC requirements.

UBS Warburg Dillon Reed Stamford, Connecticut

Operations Specialist August 1998

Worked for the Emerging Markets Trading and Finance Division.

Responsible for data correlation for the 1998 Second Quarter SEC Trading Volume Survey.

Solely Responsible for Euroclear trade reconciliation information collation and department wide distribution.

Law Office of Attorney Nicholas G. Framularo Stratford, Connecticut

Paralegal May-September 1997

Paralegal work.

Assisted with drafting contracts, wills, and various court documentation.

Quality Homes Bridgeport, Connecticut

Computer Systems Operator Summers 1993-1996

Coordinated Billing Transactions

Contract Drafting

Profit and Loss Management Experience

EDUCATION:

Quinnipiac University Hamden, Connecticut

JD/MBA May 2003

Juris Doctorate and Masters of Business Administration

Admitted to Practice Law in the States of Connecticut and New York

Babson College Wellesley, Massachusetts

Bachelor of Science in Business Administration May 2000

Double Major / Concentration in Entrepreneurship and International Business

Universita per Stranieri di Siena Siena, Italy

Halsey International Scholarship Recipient Summer 1999

Summer Immersion Program. Fluency in Italian and exposure to Italian culture.

PROFESSIONAL CERTIFICATIONS:

Admitted to Practice Law in the State of New York

Admitted to Practice Law in the States of Connecticut

Institute of Certified Bankers (ICB) - Certified Regulatory Compliance Manager (CRCM) - 2011

COMPUTER SKILLS:

Windows ‘95-10, Microsoft Office, including Word, Excel, PowerPoint, Outlook, and Visio, Adobe Acrobat, Lotus Notes, Minitab, Netscape, Internet Explorer, MAC OS, PageMaker, PhotoShop, HTML, MS Basic, Bloomberg, Google Chrome, Google G Suite: Google Docs, Google Slides, Google Sheets, Firefox, LogicManager GRC System, RSA Archer GRC System, Google Business G Suite.

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