Dede Dunegan
Sonoma, CA **476
adoo4c@r.postjobfree.com
Compliance Officer
Seasoned professional with financial regulatory history, offering customized compliance and operational solutions in alignment with industry practices and client culture. Register investment advisers, investment companies, and private investment funds, and supervise ongoing operations. Regularly conduct simulated audits, train staff, and liaise with regulatory agencies including the Securities and Exchange Commission (SEC), the National Futures Association (NFA), the Commodity Futures Trading Commission (CFTC), the Financial Industry Regulatory Authority (FINRA), and the Federal Reserve Board (FRB).
Areas of Expertise
Regulatory Compliance Programs
Policies and Procedures
Marketing and Advertising Reviews
Risk Assessment
Compliance Testing & Monitoring
Staff Training and Development
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Professional Experience
COMPLIANCE CONSULTANT, San Francisco Bay Area
Independent Contractor, 2016 – Present
Provide compliance and operational oversight to registered investment advisers and broker-dealers, offering services to start-ups on formational issues, and to established advisory firms on SEC and state regulations. Provide assistance to clients responding to regulatory examination findings and advise on FINRA matters. Draft and file amendments to Form ADV Parts 1 and 2 for state and/or SEC registered investment adviser clients. Update compliance policies and procedures, as needed. Client projects have included providing services to Best Practices Consulting Group, The Lending Club, O’Donnell Financial Group and AD Remedies/Treatibles. Also served as an Office Operations Supervisor for the U.S. Census Bureau.
LATTICE STRATEGIES LLC, San Francisco, CA
Compliance Manager, 2015 –2016
Provided oversight of all levels of Lattice’s compliance program and firm marketing materials, and prepared ongoing regulatory filings, utilizing fundamental and technical investing analysis for high net worth individuals and charitable organizations. Administered Lattice’s personal trading policies and procedures and coordinated with compliance personnel from ETF issuers in accordance with FINRA requirements.
Key Achievements
Performed risk assessments to identify gaps between business and policies and procedures and updated such policies and procedures.
Developed the Compliance and Operations Calendar for the annual review of policies and procedures.
Contributed insights to transition team for Hartford Funds’ acquisition of Lattice to ensure compliance program would remain intact post-takeover.
WELLS FARGO BANK, N.A., San Francisco, CA
Vice President and Compliance Manager – Wealth, Brokerage and Retirement Division, 2004 – 2014
Served as Chief Compliance Officer (CCO) for three SEC-registered investment adviser affiliates (Advisers) and for closed-end funds (Funds) registered under the Investment Company Act of 1940 (ICA) offered to clientele of Wells Fargo within its Wealth, Brokerage, and Retirement Division. Developed, implemented and supervised regulatory compliance protocols for Advisers, reviewed and approved marketing materials, administered forensic testing and annual reviews, and trained business line team members. Monitored Adviser regulatory reporting, including Forms ADV, PF, 3, 4, 5 and 13F and Schedule 13G, as well as CFTC and NFA filings in conjunction with corresponding Wells Fargo filings. Administered ICA Rule 38a-1 compliance functions for Funds including drafting documentation for quarterly Board and Committee meetings, reviewing SEC and CFTC filings and quarterly tender offers, conducting on-site due-diligence of sub-advisers, and analyzing and approving RFPs.
Key Achievements:
Coordinated with Wells Fargo’s corporate compliance and internal audit departments, ensuring that business line policies and procedures conformed to banking regulations and other fiduciary requirements, while addressing applicable Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control requirements for non-financial institution banking affiliates.
Coordinated all SEC examinations for the Advisers, serving as primary contact.
Provided guidance to senior management on various regulatory and industry requirements, including comprehensive Dodd-Frank Act, Volcker Rule and JOBS Act.
Supervised the CCO of Wells Fargo affiliate, Alternative Strategies Brokerage Services, Inc., and provided oversight of the Associate's Manual, Written Supervisory Procedures, and other compliance and legal issues of the broker-dealer.
Additional Experience:
Chief Compliance Officer at Osterweis Capital Management, LLC
Assistant Director of Compliance at Charles Schwab Investment Management, Inc.
Assistant Director of Compliance at Dresdner RCM Global Investors, LLC
Assistant Vice President, Compliance at Equitable Capital Management, Inc.
Education
Bachelor of Arts in Literature, American University, Washington, DC
Designations and Affiliations
FINRA: Series 63 and 65 (inactive)