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Office PHONE NUMBER AVAILABLECell PHONE NUMBER AVAILABLEFax PHONE NUMBER AVAILABLESUMMARY OF QUALIFICATIONSROCS CONSULTINGMANAGING DIRECTOR 2000 PresentAssisted with the Regulation Best Interest (Reg BI) review under the Securities and Exchange Act of 1934. The review encompassed the standards of conduct for broker-dealers and associated persons when making a recommendation to a retail customer of any securities transactions or investment strategies involving securities, including recommendations of types of transactions. The review included the summary disclosed in Form CRS to retail investors. These reviews also included the standard of conduct with respect to investment advisers standard of conduct under the Investment Advisors Act of 1940.Performed a Supervisory Control Procedures review as required by FINRA Rules 3012 and 3013. Reviewed the firms Registered Representatives Outside Business Activity filings. Assisted a firm with application for a FINRA Rule 1017 application and provided support for the firms FINRA examination.Registered a Registered Investment Advisor with the SEC and the Office of the Commissioner of Financial Institutions for the Commonwealth of Puerto Rico. Also, registered the firm as a broker dealer with FINRA, the SEC and the Office of the Commissioner of Financial Institutions for the Commonwealth of Puerto Rico. This engagement also included providing Regulatory and Compliance Consulting on an on-going basis (which included a FINRA Examination and the FINRA approval of a Waiver of Registration for a non-participating disclosed owner).Acted as Project Manager for the coordination of the review of a firms Latin American Divisions customer account documentation for purposes of the AML Customer Identification Program. This review included 1,276 accounts with assets from $500,000 to over $10,000,000.Performed a review of a firms Supervisory Procedures as mandated by a FINRA regulatory action. Also, provided ongoing Consulting services for this Institutional Brokerage Operation. Services included assistance with FINRA and SEC examinations; amendments to its FINRA application and status updates.Served as Principal Consultant to the Office of the Commissioner of the Office of the Commissioner of Financial Institutions for the Commonwealth of Puerto Ricos Division of Securities. Reviewed a Municipal Underwriting for the Puerto Rico Office of the Controller (PROC). Provided training, advice and review of Registrant Sales Practices, the Agencies Examination Program and proposed Regulatory Actions.Registered a New York Stock Exchange Member firm. This project included registration with FINRA, the SEC and the transferring all Clearing relationships to the new entity. The project concluded with the successful registration of the new entity with the requisite Regulatory bodies.Performed the annual compliance inspections of a firms OSJs and branch offices. Consolidated and updated the firms Written Supervisory Procedures. Performed a Mutual Fund Breakpoint Analysis. Responded to Regulatory inquiries with respect to Customer Complaints and reviewed advertising for sales materials. Also, functioned as interim Compliance Manager through a period of personnel changes.Acted as Project Manager for the performance of annual OSJs and branch offices for a large Mutual Find affiliated Broker Dealers annual compliance inspections.Acted as Project Manager for a large NYSE Member Broker Dealer. The engagement involved the review of the firms branch offices activity as it related to the firms Investment Profile Program and the Suitability of the Branchs Account Sales Practice Activity. The offices included 7 branch offices (This review was mandated by The State of Virginias Division of Securities).Developed Policies and Written Procedures for a Bank Affiliated Investment Advisory WRAP account program. Assisted the firm in its response to an SEC Deficiency Letter for alleged violations with respect to its Fee-Based Brokerage Accounts.Developed Chinese Wall and Personal Investment Policy and Procedures for a Broker Dealer.KPMG CONSULTING, LLCMANAGER, 1999 - 2000Performed a detailed review and analysis of the FOCUS preparation process for a self -clearing broker/dealer operation. The review encompassed the firms net capital computation, reserve formula calculation, possession and control procedures and the collection of financial and operational data for regulatory reporting purposes. A report to management was prepared with observations of deficiencies and detailed recommendations. The report also included a data map that identified the relevant regulatory reporting information and the system resources that provide the information. Performed an End-to-End Business Assessment of a Capital Markets Fiduciary Trust Services operation. The review encompassed the firms debt servicing of Commercial Paper and Conventional Debt products. A report to management was prepared that analyzed the operations workflow, organizational structure, management information reporting, internal controls and technology. Developed Equity Option Supervisory Procedures for an Equity Derivatives operation of a large Capital Markets organization.Additionally, I performed a review and assessment of a NYSE firms Anti-Money Laundering Operations and Monitoring Technology Program for Corporate Banking. The project included among other issues: Identification and Review of Countries of Particular Concern; Review of Business Sector AML Program Approval Requirements, Escalation of Significant AML issues, Comparison of Suspicious Transactions Reports and Compliance Action required; review of Global AML Program Procedures, Data Basis, Search Results and Documentation; and reviews of the firms Supervisory Procedures with respect to the U.S. Patriot Act and other Regulatory Agency requirements.DOVER INTERNATIONAL, LLC (subsequently k.n.a. Bisys Regulatory Services; now k.n.a. RRS Compliance Consultants)SENIOR VICE-PRESIDENT, 1996 - 1999Designed and developed compliance, regulatory and operational processing systems and procedures for a range of financial institutions. These assignments have covered areas including asset allocation WRAP accounts; retail sales activities; back office securities processing; Chinese Wall and Insider Trading; brokerage accounting; financial reporting; markups and markdowns. Consultant to the Government of Puerto Rico's Office of the Commissioner of Financial Institutions on enforcement and regulatory matters, as well as providing training and examination procedures for the office's securities examiners. Assisted with the management of Regulatory examinations.THE INVESTMENT FIRM OF KEOGLER, MORGAN AND COMPANY, INC.FIRST VICE-PRESIDENT AND DIRECTOR OF COMPLIANCE, 1995 - 1996Director of Compliance for a retail Independent Contractor broker/dealer with 450 registered representatives. Responsibilities includes daily compliance department management of sales activity; field audits; asset advisory programs; liaison with corporate and regulatory authorities; adapting of firm policies and procedures; managing response to customer complaints, regulatory inquiries and arbitrations; and, blue sky laws, registration and licensing department functions.UNITED STATES SECURITIES AND EXCHANGE COMMISSION, ATLANTA REGIONAL OFFICESECURITIES COMPLIANCE EXAMINER - TEAM LEADER, 1990 - 1995Functioned as a team leader for the larger and more complex examinations of NYSE and NASD member firms and municipal and government securities dealers. Responsible for the examination of the NASD District Office and the various other Self Regulatory Organizations and their programs. Provided support and served as an expert witness for the Enforcement Divisions actions that resulted from the examination findings.Also responsible f or the development of the examination program's annual plan and the coordination and organization of the resources to accomplish the overall goals.NATIONAL ASSOCIATION OF SECURITIES DEALERS, DISTRICT #7 ATLANTASENIOR COMPLIANCE EXAMINER - 1985 - 1990Responsible for conducting on-site examination of larger NASD member firms books and records and sales practice activities to ascertain compliance with securities industry rules and regulations; monitoring and analyzing monthly financial/operational reports and market activities; and, preparation of narrative and statistical reports which document examination findings to the District Business Conduct Committee. Assisted in the training and development of Examiner-Trainees.EducationUNIVERSITY OF GEORGIABACHELOR OF BUSINESS ADMINISTRATION, FINANCE, 1983Training and SkillsKey Elements to Implementing the SEC Marketing Rule and 206(4)-7 Training; NASD Basic and Advanced Examiner Training; SEC Basic and Advanced Examiner Training; Joint NYSE/SEC Examiner Training; SEC Chicago Regional Office Examiner Training - 1990,1992 &1993; Microsoft Word, EXCEL, PowerPoint, OutlookExpert WitnessThe Puerto Rico Office of the Commissioner of Financial InstitutionsLugo Sotomayor & AssociatesLarson King, LLCPreviously held NASD series 7, 24 & 63 qualifications;Awards Toastmasters - 1989; SEC Performance Award- 1992References available upon request |
