Compliance Officer Business Development
Resume:
Charity A. Davidenko
NYC Metro Area
*******.*********@*****.***
Professional Experience
ACA Group 6/2023 - Present
Senior Principal Consultant/Outsourced Chief Compliance Officer – New York, NY
Provide consulting to our broker-dealer clients
Perform CCO duties and functions – specifically onsite consulting, providing direct CCO level support, conducting exams, customizing policies and procedures and leading clients in maintaining best in class compliance programs
Complete onsite examinations, testing, and other onsite client visits as required
Assist with business development by providing technical expertise and industry knowledge
Assist with webinars, conferences, newsletters, blogs, and other publications
Responsible for reporting to senior management, including any potential or perceived violations of applicable laws, rules or Company policies
Potentially being named as CCO on form BD (outsourced CCO)
Thorough use of CRM system to document work product
Other tasks and projects as assigned
Independent Compliance Consulting 1/2021 – 2/2023
(Prager & Co., LLC, Chief Compliance Officer; Triad Securities Corporation, Compliance Director) – New York, NY
Revise and customize Compliance Program and Written Supervisory Procedures (“WSPs”), Anti-Money Laundering Program and Business Continuity/Cybersecurity Policies.
Design and implement compliance testing program to monitor and identify gaps in new and existing procedures/practices; Perform annual risk assessment to ensure policies and procedures are risk-based and modified to fit business needs.
Enhance due diligence processes and transition to independent, outsourced underwriting/advisory solutions provider.
Supervise Firm and Employee licensing/registration requirements and regulatory form filings.
Oversee and monitor employee trading, outside business activities, personal securities transactions and violation tracking system. Streamlined pre-trade approval process for employees’ personal trading requests.
Develop and administer the curriculum for the firm’s Firm Element Continuing Education Program and Annual Compliance Meeting.
Liaise with outside counsel and business units regarding regulatory updates and compliance matters.
Provide guidance, advice and training to investment banking teams, Management and Executive Committee to enhance understating of applicable securities laws and regulatory requirements.
Review and assure Principal approval of advertising and marketing materials, periodic supervisory review of electronic correspondence.
Collaborate with FinOp/CFO interpreting documentation and gathering data required to file financial reports (annual audits and insurance renewals).
Facilitate regulatory exams (FINRA/State Securities Division) and rapid response to regulatory inquiries.
Vice President, Compliance 7/2009 – 4/2020
Cain Brothers & Company, LLC (a division of keybanc capital markets inc.) – New York, NY
Served as the Chief Compliance Officer of Cain Brothers & Company, LLC (“CB” or the “Firm”) prior to its acquisition by KeyBanc Capital Markets Inc. (“KBCM”) in October of 2017.
Played an integral role in the successful integration of CB and KBCM, acting as the primary regulatory liaison between the two firms.
Crafted and maintained the Firm’s Written Supervisory Procedures; developed a testing system to monitor the effectiveness of the WSPs and identify proper remediations when necessary. Developed additional Policies and Procedures, as required by the NFA/CFTC, as the firm registered as a Commodity Trading Advisor.
Collaborated with the CEO and Management to identify and implement effective, yet pragmatic, procedures and processes designed to achieve compliance with applicable laws, rules and regulations.
Prepared the Annual FINRA Rule 3120/3130 Compliance Report and Certifications.
Solely responsible for managing all regulatory routine exams and ad-hoc inquiries (FINRA/SEC), with no material infractions.
Supervised home and branch office inspections.
Implemented and enforced the firm’s Anti-Money Laundering Program and Customer Identification Program (including OFAC and FinCEN screening), managed annual independent audits of the Programs.
Assured the firm’s Business Continuity Plan was updated as necessary and periodically tested by the IT Department.
Ensured all branch inspections were performed on a timely basis.
Managed all firm filings such as: Form BD, Forms BR, Form MA and NFA Form 7-R, MSRB Form A-12, FINRA Contact System updates, Entitlement User Accounts Certifications and Annual Risk Control Assessment Surveys.
Managed all individual filings: Forms U4/U5, Form MA-I and Form 8-R.
Supervised the accurate and timely completion and submission of quarterly MSRB G-37 filings.
Orchestrated the firm’s compliance-training program, prepared compliance briefs on new and revised rules, regulations and industry practices. Managed Firm and Regulatory Element Continuing Education requirements for all personnel, coordinated with Management in the Annual Needs Analysis. Delivered Annual Compliance Meeting presentations.
Mentored new hires through the registration and licensing process; conducted compliance training sessions to highlight key aspects of the Firm’s WSPs.
Performed reviews of all advertising and marketing to assure they contained the proper regulatory disclosures and supervisory review and approval.
Spearheaded a project to automate all employee pre-clearance requests such as: new brokerage account approval, personal securities and private securities transaction requests, outside business activities, gifts and entertainment, charitable contribution and political contribution requests; Consulted with Management in updating the firm’s Watch & Restricted Trading Lists.
Automated a system for the completion and submission of employee quarterly and annual attestations.
Assisted Bankers in responding to RFPs/RFQs, with respect to compliance centric questions.
Ensured the compilation and central storage of closed deal files and client presentations.
Cain Brothers Asset Management, LLC (2009 – 2015, date of sale)
Provided an instrumental role in the formation of an SEC-Registered Investment Advisor and NFA Commodity Pool Operator.
Built a compliance program, including Policies & Procedures, tailored to investment advisory firms.
Successfully managed an exam by the SEC, with no material infractions.
Served on the Firm’s New Business, Investment and Best Execution Committees.
Compliance Analyst 5/2006 – 1/2009
The Reserve Funds – New York, NY
Collaborated with the CCO in developing and enforcing a comprehensive compliance program including Written Supervisory & Control Procedures to ensure compliance with SEC/FINRA rules and regulations, in addition to the firm policies and procedures.
Monitored advertising, sales literature and educational materials to ensure supervisory review and approval, along with timely filing with FINRA as required; Reviewed electronic and hard copy correspondence.
Collaborated with Management to ensure supervisory infrastructure and policies were efficient and effective; identified areas of vulnerability and risk, assisted in corrective measures.
Conducted annual compliance reviews of businesses and identified initiatives for coming year.
Researched new and revised rules and regulations to assess impact on the firm’s businesses.
Interacted with FINRA and the SEC to facilitate examinations of the Registered Broker-Dealer and Investment Advisor.
Implemented the firm’s Anti-Money Laundering Program, filed Suspicious Activity Reports, conducted OFAC and FinCEN screening of customer accounts, reinforced the firm’s Customer Identification Program by ensuring customer identification documentation was collected and updated as required.
Created FINRA filings including Forms ADV & BD, Forms U4/U5, Contact System and Customer Complaints.
Reviewed trading activity of money-market mutual fund portfolios for adherence to SEC Rule 2a-7 and conducted initial review of portfolio manager’s monthly/quarterly compliance checklists.
Addressed Blue-Sky registration issues to ensure registration of the mutual funds in the appropriate states.
Managed distribution of Private Offering documents under Rule 506 of Regulation D, filed Form D with SEC and states.
Orchestrated compliance-training program, prepared compliance briefs on new and revised rules, regulations and industry practices. Managed Firm Element and Regulatory Element Continuing Education.
Supervised personal securities transactions of employees; collected and ensured timely completion of Quarterly and Annual Personal Securities Transactions Reports, Annual Insider Trading and Code of Ethics Certifications.
Monitored Outside Business Activity Reports and confirmed supervisory approval/periodic reviews.
Managed Regulatory & Firm Element Continuing Education Programs.
Gathered data and assisted in the coordination of Investment Company registration with and reporting to the SEC (Forms N-1A, N-CSR, N-SAR).
Education
Bachelor of Science in Business Administration, concentration in Finance and Economics
GPA 3.8/4.0, Summa Cum Laude
Edinboro University of Pennsylvania – Edinboro, PA
Professional Licensure
FINRA Series 6, 7, 79, 66, 28 & 24
Software & Skills
Microsoft Office Suite, Salesforce, FINRA Gateway, Web CRD/IARD, MSRB Gateway, SEC EDGAR Filing System for Municipal Advisor Registrations, NFA’s Electronic Filing Systems, Global Relay, Smarsh, ComplySci and My Compliance Office
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