Assistant Management

Samantha E. Kefford

646-***-**** - Cell

********.*******@*****.***

SUMMARY

A senior Legal and Compliance executive with over 20 years of extensive proven troubleshooting experience on legal, regulatory, enforcement and compliance issues within the brokerage and clearing house industry. Candidate possesses a wide in-depth knowledge of major brokerage products and is proficient at all levels of corporate, client and regulatory communications. As a leader in legal and compliance issues, an excellent record of successfully formulating and coordinating with both internal and outside counsel on litigation, enforcement and regulatory inquiries has been established.

Career achievements include:

Developed and directed a pro-active Customer Complaint Response Unit to identify, prioritize and resolve both customer and regulatory inquiries resulting in a significant decline in regulatory exam findings.

Designed and creatively implemented effective programs to triage incoming regulatory, litigation and complaint issues; as well as, coordinated with counsel on responses, strategies and precedents.

Implemented effective programs to identify complaint and regulatory trends and recommended successful corrective actions.

In recognition for on-going creative, proactive service, was selected to a fast track program to develop branch management and administration strategies, process and procedures and Firm and Industry Committees relating to compliance and key legal matters

Achieved and maintain all major industry principal and representative licenses

PROFESSIONAL EXPERIENCE

TD Bank – Wilton, CT June 2018 – June 2020

Business Management Analyst II – Compliance

Responsible for the extensive analysis of numerous legal documents to onboard Canadian customers onto TD Bank's US Banking Platform

Senior liaison with Canadian counterparts to ensure complete and timely onboarding of upwards of 1,000 Canadian companies

Work closely with senior AML personnel in the US and Canada with the proper escalation of documents that require an additional and more extensive review (i.e., high risk customers)

Responsible for the ultimate attestation indicating that the documentation was deemed satisfactory on a particular date and the account is now approved to be onboarded

Participate in numerous conference calls and meetings updating Senior Management on the various aspects of the onboarding process and compliance thereto

Bridgewater Associates, LP – Westport, CT July 2017 – December 2017

Consultant – Legal and Regulatory Group – Paralegal

Supported the Compliance Department and Counterparty and Relations (“CPR”)

Responsible for the daily review and approval of Bridgewater’s world renown Daily Observations

Responsible for daily marketing review of client presentations to ensure proper disclosures are made

Supported CPR in a variety of functions surrounding the necessary daily flow of creating counterparties and updating existing

Supported CPR in all new fund launches that included very timely and accurate review of various legal documents, proper signature(s) and issuance (and return) to respective counterparty for same

Gathered the information necessary to create, maintain and ultimate issuance of management’s Transparency Reports on a daily and weekly basis

Rabo Securities USA, Inc., New York, NY May 2015 - December 2015

Consultant – Compliance Department – Compliance Generalist

Assisted CCO with various projects and timely assignments for senior management

Review and approval of daily exception reports reflecting trades that may be a violation of firm policy

Presence on firm trading desk and participate and escalate as necessary potential verbal and written violations of firm policy

Banca IMI Securities Corporation, New York, NY August 2014 - February 2015

Chief Compliance Officer

August 2014 - February 2015

Chief Compliance Officer

Developed, initiated, maintained, and revised policies and procedures for the general operation of the FINRA required Compliance Program and its related activities to prevent illegal, unethical, or improper conduct. Managed day-to-day operation of the Program

Developed and periodically reviewed and updated FINRA required Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees.

Collaborated with other departments (e.g., Risk Management, Internal Audit, Employee Services, etc.) to direct compliance issues to appropriate existing channels for investigation and resolution. Consulted with the Corporate attorney as needed to resolve difficult legal compliance issues.

Responded to alleged violations of rules, regulations, policies, procedures, and Standards of Conduct by evaluating or recommending the initiation of investigative procedures. Developed and oversaw a system for uniform handling of such violations

Acted as an independent review and evaluation body to ensure that compliance Issues/concerns within the organization were being appropriately evaluated, investigated and resolved

Active participant in all FINRA/SEC regulatory matters and/or internal and external audits that surround AML

Monitored, and as necessary, coordinated compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends

Identified potential areas of compliance vulnerability and risk; developed/implemented corrective action plans for resolution of problematic issues, and provided general guidance on how to avoid or deal with similar situations in the future

Provided reports on a regular basis, and as directed or requested, to keep the Corporate Compliance Committee of the Board and senior management informed of the operation and progress of compliance efforts

Ensured proper reporting of violations or potential violations to duly authorized FINRA enforcement agencies as appropriate and/or required

Worked with the Human Resources Department and others as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees as well as ongoing training for all employees and managers

Monitored the performance of the FINRA required Compliance Program and related activities on a continuing basis, taking appropriate steps to improve its effectiveness

JP Morgan Chase, New York, New York August 2012 – 2014

Legal Specialist Analyst – Legal Papers Served

Responsible for efficient triage of all legal documents served on JP Morgan Chase & Co.

Volume was upwards of 25,000 documents a month

Supplied Senior Management with daily, weekly and monthly management reports

Responsible for the daily management of approximately 40 Legal Specialists

Maintained access to approximately 10 legacy systems reflecting all activity for the entities that JPMC had absorbed

Maintained efficient relationships with all Lines of Business to ensure proper triage and disbursement of Legal Papers Served on JPMC

Pershing LLC (“Pershing”), Jersey City, NJ June 2005 – November 2011

Vice President, Regulatory Compliance

Directed and supervised all FINA, SEC regulatory inquiries received inclusive of Pershing and its introducing firms, including complex trading inquiries, Bluesheet requests (over 3,500 annually) and provided Executive Management summaries.

Managed extensive FINRA and SEC Regulatory Examinations of Pershing by Federal, State and Self-Regulatory agencies, including planning, production and responses.

Reviewed and interpreted proposed and newly proposed FINRA regulatory rules and requirements in connection with creating and updating written supervisory policies and procedures.

Planned and managed processes for accurate and timely FINRA and SEC regulatory reporting for all fully disclosed clearing agreements (approximately 900 introducing firms).

Key member of Pershing’s Suspicious Activity Reporting Oversight Committee reporting on key risk indicators specific to regulatory inquiries surrounding Pershing’s introducing firms.

Active participant in the drafting and filing of all AML Suspicious Activity Reports ("SARs") that stemmed from a FINRA and/or regulatory inquiry/matter.

Worked closely with the respective AML team(s) in the day-to-day investigation and review of operational and suspicious matters that may present exposure to the Firm.

Compiled and distributed comprehensive daily, weekly and monthly management reports and highlighting trends of potential exposure to Pershing and/or their introducing firms.

Compliance Liaison to members of Pershing’s introducing firm’s management teams to counsel them on Pershing’s processes regarding regulatory inquiries, reporting and examinations.

Point Person for Pershing’s Chief Compliance Officer concerning Pershing’s regulatory landscape.

Bank of America (Banc of America Investment Services, Fleet Bank and Quick & Reilly Inc.) 1993-2005

Vice President, Customer Complaint Response Unit 2003-2005

Legal and Compliance, New York, New York

Responsible for supervision and development of Customer Complaint Response Unit in responding to, and when appropriate, resolving investor concerns and regulatory inquiries.

Developed and implemented procedures to comply with Self-Regulatory Organization rules and guidelines

Active participant in coordinating necessary meetings and the preparation thereof, to senior management regarding significant

AML matters that may present potential regulatory and Firm exposure that resulted in an internal investigation.

Coordinated complaint identification and resolution processes with all other lines of business

Served as primary liaison for resolution/settlement of complex complaints in anticipation of litigation

Issued comprehensive reports on complaint trends to Senior Management and other lines of business with appropriate recommendations for correction/resolution

Co-chaired with Firm’s Broker Review Committee

Assistant Vice President, Legal Department, New York, NY 2001-2002

Extensive coordination with in-house and outside counsel on all enforcement, arbitration and litigation matters

Drafted responses to arbitration claims filed with the National Association of Securities Dealers (NASD) and the New York Stock Exchange (NYSE)

Formulated and coordinated responses to regulatory inquiries

Corporate Representative for Quick & Reilly in conjunction with outside counsel on various regulatory matters

Conducted legal research for litigation and arbitration matters

Primary liaison to Counsel and charged with identifying regulatory and legal precedents related to the cases

Assistant Vice President & Regional Manager, New York, NY 1997-2001

Responsible for the operation and profitability of several Retail Investment Centers

Acted as liaison between Investment Center personnel and Senior Management with regard to budgets, financial forecasting and cost controls

Key team member creating an effective distribution of Fleet’s Private Equity Portfolio products to Quick & Reilly’s high net worth clientele

International Liaison, New York, NY 1999-2000

Retail Brokerage Account Representative, La Jolla, CA 1993-1996

EDUCATION

Albertus Magnus College, New Haven, Connecticut

Bachelor of Arts, Economics, May 1993

Elected member of the Board of Trustees

LICENSES AND PROFESSIONAL AFFILIATIONS

Series 7 – General Securities Representative

Series 4 – Registered Options Principal

Series 9/10 – General Securities Sales Supervisor

Series 63 – Uniform Securities Agent State Law

Member, SIFMA Legal and Compliance Division

Former Member, New York Stock Exchange’s Complaints Initiative Committee

Elected and served as President of my Condo Association Board in November of 2013

oPreviously served 2 years as the Board Secretary

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