Project Management Regulatory Compliance

RITU SINGH

*************@*****.*** – 732-***-****

SUMMARY

Regulatory Compliance Professional with Project Management experience in coordinating regulatory integration and implementation of policy, procedures, infrastructure, and operations from First and Second Line of Defense. Legal knowledge of US and EU regulations such as DFA (Swap Dealer, SBSD and Volcker), FATCA, Alphabet regulations (including but not limited to Reg W, B, YY), IRW, QFC, SOFIR, MiFID, MIFID II, EMIR, US PR SMR and SFTR for a US branch of a foreign banking institution. Specifically, designed, developed and implemented a US papering strategy to paper counterparty documentation (ISDAs, Account Control Agreements and Eligible Collateral Schedules) for US entities effected by the SMR. Tracked, developed, and provided advisory procedures and policy framework for FRTB methodology, specifically, align with the street on implementation of internal model of trading book review based on Volcker desk’s structure rather than standard model. Collaborate with trading desk, market risk and senior management to provide guidance as to BASEL III regulations, new requirements, and advisory guidance to comply with FRTB. Experience also includes understanding and conducting RCSA assessments, audit reviews, and regulatory readiness activities. Ability to proactively track and communicate regulatory changes to keep internal team versed and ability to educate clients about emerging risks and trends. Experience also includes US Broker-Dealer obligations, FICC and Equity trading knowledge, WSP, 3120, 3110, 2111, 144 A, QIBs, SEC Acts '33 and '34. Knowledge of roles and responsibilities of Corporation Actions requirements such as Reconciliation and payments. Experience with Investment Company Act and Investment Advisers Act of 1940 advising on compliance and legal obligations of funds and fund managers along with knowledge of ADV, 2B and PF filings and rule 38a-1. Knowledge of trading desk regulatory monitoring requirements and trading impacted by US Qualified Financial Contracts (QFC) Stay Protocol. Knowledge of US and Global KYC onboarding processes, experience in data analysis or business intelligence in accordance with BSA/AML program requirements, including experience with US FINCEN and US Patriot Act. Understanding of due diligence requirement for CDD and EDD, OFAC list and sanction screening and transaction monitoring. Worked in agile methodology-based environments. Strong analytical and problem-solving skills when onboarding client and conducting due diligence through World Check and D&B along with other systems. Experience with transaction disputes and consumer complaints, regulation B, E, UDAAP, Z and L along with advising on compliance requirements. Experience performing risk assessments of all regulations including not limited to NYDFS Cybersecurity requirements, FFIEC Cybersecurity Tool and NIST CSF, while taking a risk-based approach. Experience in engaging with regulatory agencies and SRO (FINRA and NFA) for SEC and CFTC respectively and FRBB as the umbrella regulator for the US. Experience with Transaction Trade Reporting (TTR) for swap transactions with the CFTC. Knowledge of OSFI as primary prudential regulator for financial stability and FCAC as consumer protection and market conduct regulator.

EXPERIENCE

RSM, Chicago, IL (worked through its NY Office location)

Manager – Regulatory Compliance Group

April 2023 – Present

Audit and Controls Monitoring & Testing

Develop and conduct an annual testing plan across relevant areas of the business and support functions based on risk control self-assessment results.

Conducted RCSA reviews for each regulatory requirement for each regulatory program.

Manage the reporting of key metrics for Compliance Assurance Testing Program to senior management, committees and Board

Review work performed, findings, conclusions, corrective action plans and workpaper documentation for completeness and to ensure Firm testing standards are met

Ensure assigned testing responsibilities are performed timely with high level of quality workpaper documentation and reports

Experience with consumer protection requirements, including UDAAP and Regulation E

Experience with transaction disputes and consumer complaints.

Experience advising product teams on compliance requirements.

Experience performing risk assessments for all regulations impacting consumer including but not limited to Regulation L and Z.

Define test step objectives, perform “Compliance Review” planning, execute test methodologies, and draw proper conclusions from evidence gathered.

Knowledge of US and Global KYC onboarding processes, experience in data analysis or business intelligence in accordance with BSA/AML program requirements, including experience with US FINCEN and US Patriot Act.

Understanding of due diligence requirement for CDD and EDD, OFAC list and sanction screening and transaction monitoring. Worked in agile methodology-based environments. Strong analytical and problem-solving skills when onboarding clients and conducting due diligence through World Check and D&B along with other systems.

Develop audit and testing methodologies to achieve 99% confidence level, including interviews, observations, analytics, re-performance, walk-throughs, and attribute sampling for BSA/AML program of regional bank (reviewed transaction, CIP, CDD, EDD, KYC information, OFAC screening, wire transfer, travel rule implications, 314 a and 314 b) based on the OCC’s Examiner’s Handbook and FFIEC.

Conduct sanction screening, letter of credit review and escalation to BSA Officer as needed

Evaluating and documenting results of test work

Develop final testing reports to document and formally communicate results to stakeholders, senior management, and the Board.

Track and validate that the business and functional area has completed the agreed action plans by the due date

Experience with Transaction Trade Reporting (TTR) for swap transactions with the CFTC.

Policies and Procedures Monitoring & Testing

Experience performing risk assessments of all regulations including not limited to NYDFS Cybersecurity requirements, FFIEC Cybersecurity Tool and NIST CSF, while taking a risk-based approach.

Experience in security governance, policies, cybersecurity frameworks, security standards, and regulatory compliance.

Analyze the compliance framework and controls; and review and assets compliance policies and procedures to identify risks in relation to core activities in accordance with regulatory requirements and track the issues and the status of remediation.

Keep current with industry specific emerging risks, trends and issues across the industry

Natwest Markets, Stamford, CT

Controls Monitoring & Testing Generalist Consultant

February 2023 – April 2023

Analyze the compliance framework and controls; and review and assets compliance policies and procedures to identify risks in relation to core activities in accordance with regulatory requirements and track the issues and the status of remediation.

Develop final testing reports to document and formally communicate results to stakeholders.

Track and validate that the business and functional area has completed the agreed action plans by the due date

Review, update and enhanced Written Supervisory Procedures to comply with the business of the Firm

Conduct and review of Supervisory Program under FINRA 3110, 3120 and 3130

Develop and conduct testing based on RCSA results

Citibank, N.A., New York, NY

Senior Vice President- Regulatory & Policy Change Lead –CAO- NAM- Institutional Credit Management (ICM)

December 2022 to March 2023

•Assisting in analyzing regulatory controls library with an inventory of controls that cover all business activity in ICM and infrastructure functions for Citi ICM Regulatory and Policy team.

•Reading, reviewing, and analyzing the regulatory obligations and summarize the main requirements from a regulatory perspective based on ICM’s products, business framework, and activities

•Identifying and defining applicable regulatory obligations and recommend internal regulatory controls

•Drafting, mapping, categorizing, and evaluating the strength of applicable controls.

•Working with control owners and subject matter experts across first and second lines

•Assisting Regulatory Program Management by engaging with business lines regarding Issue and CAP resolution

•Led the Seniority of Claims project management of several business lines with the completion of Action Plan and Milestones

•Leading working group discussions, agenda, minutes and tracking completion of Milestones

•Reporting on findings, any trends, and potential risks to business head/ Issue owner

•Assisting in drafting and submitting closure memorandum for Issue and CAPs

•Assisted in the development of training and tracking of results as to participation and completion

•Assisting the business line’s with review of controls and led discussion around sufficiency of current controls

•Assisted in the review, analysis and submission of materials related to regulatory exams by the Federal Reserve Board regarding Counterparty Credit Risk exam.

•Experience performing risk assessments (RCSA) of all regulations including not limited to NYDFS Cybersecurity requirements, FFIEC Cybersecurity Tool and NIST CSF, while taking a risk-based approach.

•Experience in security governance, policies, cybersecurity frameworks, security standards, and regulatory compliance projects.

•Experience with transaction disputes and consumer complaints.

•Experience advising product teams on compliance requirements.

•Experience performing risk assessments.

•Experience with consumer protection requirements, including UDAAP and Regulation E

•Creating, reviewing and aligning controls framework, conducting risk assessment, drafting a testing plan, policies and procedures for consumer regulations.

•Participated in review, alignment of documents and submission Hedge Fund regulatory exam by Prudential Regulatory Authority in UK submission

•Assisted in the analysis and developed integration template for different groups into ICM by reviewing Citi’s products, business framework, technology, and activities

•Escalate potential issue to head of group for resolution or further escalation

•Assisting in weekly updates related to integration details and updates for ICM CAO Finance team

•Assisting in weekly updates and business assessment for integration into ICM for ICM CAO Business management team

HSBC, New York, NY

Controls Monitoring & Testing Generalist Consultant

September 2022 –December 2022

•Responsible for the preparing and presenting formal written reports to senior management regarding Volcker desk review and DFA voice recording testing results

•Report and escalate control issues and any violations of laws or breaches of policy; and validating adequacy of remediation taken to address reported issues concerning Volcker desk review and DFA voice recording testing results

•Actively consider the inherent and material risks of the business and support functions to ensure risks are appropriately identified, assessed and mitigated to the desired risk appetite

Scotia Capital USA Inc., New York, NY

Consultant

June 2021 – August 2022

Operational Risk Oversight Consultant, U.S. Internal Control Team- SCUSA

•Assisting in creating a US regulatory controls library with an inventory of controls that cover all business activity and infrastructure functions for Scotiabank’s U.S. Operations.

•Reading, reviewing, and analyzing the regulatory obligations and summarize the main requirements from a regulatory perspective based on Scotiabank’s products, business framework, and activities

•Identifying and defining applicable regulatory obligations and recommend internal regulatory controls

•Drafting, mapping, categorizing, and evaluating the strength of applicable controls.

•Working with control owners and subject matter experts across first and second lines

•Reporting on findings, any trends, and potential risks to project leads

•Escalate potential issue to project leads and resolve in a timely manner

•Assisting in reviewing obligations based on Scotiabank’s branch in TX and agency branch in NY and Representative office in FL under relevant state and federal consumer laws

•Providing guidance, helping in the interpretations, and assisting the internal testing team with updates to the internal monitoring and testing plans as needed.

•Experience conducting Risk and Control Self-Assessments either as a subject matter expert providing ratings and as a member of a RCSA team.

•Creating, reviewing and aligning controls framework, conducting risk assessment, drafting a testing plan, policies and procedures for consumer regulations including but not limited to Reg E, UDAAP, Reg Z and L.

•Assisted in SEC Compliance Reporting under Investment Adviser and Company Act of 1940, which includes filing of SEC Form ADV which includes review and updating Parts 1A, 2A and CRS disclosures.

•Designed assessment programs to identify, evaluated and prioritize business, operational, regulatory and technology risks as well as risk mitigation strategies for Act 33, 34 and 40

Banco Santander, S.A. New York Branch and Santander Investment Securities, Inc., New York, NY

Executive Director - Legal and Compliance

August 2015 – August 2021

•Lead conceptualization, prioritization, planning, development and implementation of Swap Dealer and other regulatory related projects and controls for the US National Bank (known as SBNA), US Broker-Dealer (known as SIS) and US Foreign Branch (known as NYB) (collectively CIB) according to the plans and priorities outlined by the US COO, Global Head of Regulatory Affairs and Global COO

•Aligned regulatory strategy and controls across functional and business areas of US GCB (FICC and Equity) following the US business strategy, projections and priorities at the direction of the US CIB COO

•Ensured and aligned all regulatory projects, controls and processes based on the regulatory strategy and control framework across functional and business areas for CIB and Global CIB

•Ensured proper communication and updating of the US CIB COO with reference to the above-mentioned activities

•Partner with core business and support units to lead efforts in sound, time-sensitive, trend driven project development, regulatory strategies, and controls framework

•Lead the creation and maintenance of regulatory compliant and up-to-date global documentation, processes and controls framework for US and EU regulations along with internal procedures

•Communicated (meetings, verbal, and written) with the US regulators for CIB and other regulatory agencies

•Maintained a close working relationship with business and functional heads for the purpose of cooperation to develop new projects, controls, procedures, and optimal execution of the collective goals of CIB

•Acted as US CIB regulatory contact for Madrid, UK, HK, SHUSA colleagues and establish a strong working relationship for all regulatory activities in support of CIB business

•Coordinated and lead the on-boarding of all clients/counterparties for Banco Santander, S.A., New York Branch (‘NYB’) and Santander Investment Securities, Inc. (‘SIS’) in the US region covering Corporate & Investment Banking/Market teams across Equities and Fixed Income (FICC)

•Experience conducting Risk and Control Self-Assessments as a subject matter expert providing ratings and as a member of a RCSA team.

•Subject matter expert on AML policy and procedures to the business; provides direction and guidance to all Lines of Business. Perform customer due diligence and KYC for to all Lines of Business for the NYB and SIS.

•Knowledge of US and Global KYC onboarding processes, experience in data analysis or business intelligence in accordance with BSA/AML program requirements including experience with US FINCEN and US Patriot Act.

•Understanding of due diligence requirement for CDD and EDD, OFAC list and sanction screening and transaction monitoring. Worked in agile methodology-based environments. Strong analytical and problem-solving skills when onboarding clients and conducting due diligence through World Check and D&B along with other systems.

•Develop audit and testing methodologies to achieve 99% confidence level, including interviews, observations, analytics, re-performance, walk-throughs, and attribute sampling for BSA/AML program of regional bank (reviewed transaction, CIP, CDD, EDD, KYC information, OFAC screening, wire transfer, travel rule implications, 314 a and 314 b) based on the OCC’s Examiner’s Handbook and FFIEC.

•Managed complex projects that involve working with businesses to improve controls to mitigate any deficiencies.

•Partnered with Internal Audit, Compliance, and/or Operations Management to share information and escalate issues as needed.

•Review current policies and procedures to identify process gaps and opportunities for improvement.

•Compliance professional that supported the New York branch (NYB) and US Broker Dealer (SIS) within their current programs.

•Developed, reviewed, modified, and updated policies and testing controls for NYB and SIS.

•Interfaces with senior management and CCOs along with CRO and CLO of each entity to implement associated recommendations to further the goals of the Compliance Program.

•Researched, tracked, developed, and provided advisory procedures and policy framework for FRTB methodology, specifically, align with the street on implementation of internal model of trading book review rather than standard model. Collaborate with trading desk, market risk and senior management to provide guidance as to BASEL III Endgame regulations, new requirements, and advisory guidance to comply with FRTB.

•Implemented a Swap Dealer program for the New York branch which includes review and assurances from Madrid for

entity level controls

•Designed, developed and implemented a Swap Dealer (DFA Title VII) program for New York branch which includes

Transaction Level controls with no substituted compliance for Daily Trading Records, Swap Trading Relationship Documentation, Mandatory clearing, and Margin requirements, Swap processing, Segregation requirements, Trade execution, End-user relationship documentation, Real-time Public Reporting and External business conduct (antifraud rule, verification of counterparty’s identity and legal status, disclosures and notifications, scenario analyses; suitability, daily marks and no interactions with special entities) and on-boarding.

•Designed, developed and implemented an ongoing monitoring plan to ensure ongoing compliance with the Volcker Rule and Swap Dealer requirements.

•Developed escalation protocol for testing results for efficiency of the program and results across different levels of the organization

•Respond to internal / external regulatory requests and ad-hoc queries

•Attend Risk Committee and other management committees to report on Volcker and DFA Title VII matters and any escalation that are required Coordination between Madrid and US

•Designed, developed and implemented a US papering strategy to paper counterparty documentation (ISDAs, Account Control Agreements and Eligible Collateral Schedules) for US entities effected by the SMR

•Assisted with EU regulations that are related to DFA Title VII such as EMIR, MIFID II and SMR as these programs related to the US entities and impacted the New York branch

•Experience with Transaction Trade Reporting (TTR) for swap transactions with the CFTC.

KPMG LLC, New York, NY

Manager – Regulatory Risk

December 2014 – August 2015 (moved in-house to Banco Santander, SA)

•Responsible for implementing an Enhanced Volcker Compliance Program for Top 15 Foreign Bank’s US Operations

•Created, modified, drafted, and advised is US Firm’s Operations team as to all aspects of the Volcker Rule from Proprietary Trading and Covered Funds activity.

•Implemented policies by conducting a Gap Analysis checklist for a foreign bank’s US national banking unit based on the impact of Volcker Rule with regards to its Proprietary Trading and Covered Funds by reviewing existing internal policy, procedures, operation standard, regulatory requirements and other materials received from the client

•Drafted a new US Volcker Rule Proprietary Trading and Covered Funds Policy for a foreign bank’s US operations for over 180 entities functioning in the US

•Drafted Volcker Compliance Manual, Procedures, Desk Mandates, Internal Controls, CEO Attestation Program and worked with Market Risk to establish its Metrics reporting obligation under the Volcker rule for it business relating to proprietary trading and covered funds.

•Assisted in reviewing Training, Record Keeping requirements/Approach under CTFC 1.31 and under Volcker Rule for its US Operations

•Assisted firms to set up procedures relating to roles and responsibilities of Corporation Actions requirements such as reconciliation and payments.

UBS, Stanford, Connecticut Director – Compliance

April 2011 – December 2014

•Responsible for drafting, reviewing, and presenting the following:

•New/existing internal policy, procedures, operation standard, regulatory requirements and other materials to all internal front and back-office personnel through computer based and in-person training

•Trained on the obligations under the new Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) by providing an overview of the substantive regulation of over-the-counter (“OTC”) derivatives under U.S. securities and commodities laws to all staff and associated person through computer based and in-person training.

•Review, designed and trained on bank regulatory regulations such as Regulation D, W, K, U, US Anti-tying Rules under the Bank Holding Company Act, Financial Holding Company Act (FHC), revision to Bank Holding Company Act by Gramm-Leach-Bliley Act (merchant banking), Federal and Regulatory Reporting

•Designed and prepared Firm Element Plan based on the needs analysis for Americas Investment Banking and Global Asset Management Groups

•Conducted needs analysis survey with each business unit, compliance officers to develop the Firm Element Plan to comply with FINRA Rule 1250 for the Americas Investment Banking and Global Asset Management Groups

•Assisted in drafting and distributing global and regional bulletins and alerts on regulatory, policy and procedures for Global and Americas Investment Banking and Global Asset Management Groups

EDUCATION

•New York University, New York, NY College of Arts and Sciences

B.A., Political Science

LANGUAGES

Portuguese: verbal and written fluency

Hindi: verbal fluency

Spanish: verbal and written fluency

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