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    Finance (Compliance)

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  • Designed and implemented a regulatory compliance change management program for a regional bank.

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  • Compliance with the Consumer Financial Protection Bureau (CFPB) regarding consumer credit issues, such as: Regulations B, C, D, DD, E, F, G, H, I, J, K, L, M, N, O, P, V, X and Z; and, unfair, deceptive, or abusive acts or practices (UDAAP) under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

 

  • Compliance with FINRA Rule 2090 (Know Your Customer) and FINRA Rule 2111 (Suitability).

 

  • Advised the business units and relevant compliance professionals on anti-money laundering and financial fraud issues.

 

  • Conducts research and analysis relating to suspicious account activity, collecting documents as necessary, and reviewing case investigation files to review case investigation decisions made by internal investigators.

 

  • Analyzes transaction data, research results, and information compiled by the investigations staff to ascertain whether transaction activity is suspicious and requires external reporting.

 

  • Validates decisions about whether particular activity is isolated or may be part of a larger conspiracy, identifies and resolves inconsistent information, and escalates matters to the appropriate departments for disposition.

 

  • Works with the business lines and participates in discussions with higher levels of management and more senior personnel within the shared services such as compliance, risk, audit.

 

  • Collaborates with investigator staff on their investigations and provides recommendations and feedback.

 

  • Reviews business issues, conducts appropriate research and investigation, and makes recommendations for the reporting and remediation of suspicious activity.

 

  • Review and revision of corporate Bank Secrecy Act (BSA)-related Anti-Money Laundering (AML) policies and procedures.

 

  • Drafting and implementation of corporate BSA-related policies and procedures to identify higher-risk banking operations (including products, services, customers, entities and geographic locations) and risk-profile updates.

 

  • Drafting and implementation of corporate BSA-related policies and procedures to inform the board of directors, committees and senior management of compliance initiatives, identified compliance deficiencies, Suspicious Activity Reports (SARs) filed, corrective action to implement risk-based customer due diligence (CDD) and enhanced due diligence (EDD) policies and procedures.

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  • Drafting and implementation of corporate BSA-related policies and procedures to identify a key person or committee responsible for BSA/AML compliance and to provide for program continuity despite management or structure changes.

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  • Drafting and implementation of corporate BSA-related policies and procedures to identify reportable transactions and accurately file all required reports, including SARs, Currency Transaction Reports (CTRs), and CTR exemptions.

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  • Drafting and implementation of corporate BSA-related policies and procedures to provide for dual controls and monitoring systems and for compartmentation of employee reporting duties.

 

  • Familiarity with the Risk Control Self-Assessment (RCSA)process and Sarbanes-Oxley (SOx) audits and consulting

 

  • Audits for compliance of corporate protocols, policies and procedures with guidelines of various regulatory entities, such as the Consumer Product Safety Commission (CPSC), Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Administration (FHA), Federal Reserve System, Federal Trade Commission (FTC), Food and Drug Administration (FDA), National Labor Relations Board (NLRB), Occupational Safety and Health Administration (OSHA), Securities and Exchange Commission (SEC) and the U.S. Department of Housing and Urban Development (HUD).

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  • Familiarity with standard compliance platforms such as Know Your Customer (KYC) and related compliance protocols, such as customer due diligence (CDD) and enhanced due diligence (EDD).

 

  • Monitoring of the domestic and international statutes, rules and regulations involving federal and state securities, AML, broker-dealer, consumer-protection, KYC and taxes.

 

  • Use of KYC, CDD and EDD for screening potential EB-5 Immigrant Investor Green-Card Program applicants.

 

  • Due diligence reviews of acquisition targets, SEC Rule 144A – for private placement offerings in the US, for US investors and clears, generally cleared through the Depository Trust & Clearing Corporation (DTCC), SEC Regulation S (for bonds issued in the Eurobond market for international investors, usually cleared through European clearing houses such as Euroclear or Clearstream), private placements and asset sales.

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  • SEC filings, including 10K, 10Q, 8K, proxy statements and Forms ADV, PF, 3, 4 and 5, and familiarity with EDGAR database.

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  • Maintained compliance certifications, compliance logs procedures and procedures on material non-public information.

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  • Prepared and reviewed annual stockholder meeting documentation, press releases and other disclosure materials.

 

  • Administered reporting violations and implemented a compliance hotline.

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  • Advised senior management in business development, financial, risk management, engineering and labor groups.

 

  • Performed compliance activities regarding SEC Rules 17a-3 and 17a-4, 206(4)-7 and U. S. Commodities Futures Trading Commission (CFTC) Rule 1.31 and the Dodd-Frank Internal Business Conduct Rules.

 

  • Authored new, and reviewed and revised existing, protocols, procedures and corporate policies governing records management and records retention, corporate governance, compliance, risk management, ethics, HR, approvals, security, privacy and all aspects of corporate functioning for more than 200 corporate entities.

 

  • Reviewed existing and drafted proposed corporate policies and products for compliance with banking-related Federal statutes, guidelines, derivatives rules, agencies and regulations including the various securities Acts (such as the 1933, 1934, 1939, 1940 Investment Advisers, 1940 Investment Company and 1970 Securities), the anti-boycott laws (the 1977 amendments to the Export Administration Act and the Ribicoff Amendment to the 1976 Tax Reform Act), Bank Bribery Amendments Act of 1985, Bank Holding Company Act (BHCA), BHCA 1970 anti-tying § 106 (12 U.S.C. § 1972) Bank Merger Act (BMA), Bank Protection Act (BPA), Bank Secrecy Act (BSA), Basel Committee on Banking Supervision (Basel), Committee of Sponsoring Organizations of the Treadway Commission (COSO), Commodity Futures Trading Commission (CFTC), Consumer Credit Protection Act (CCPA), Consumer Financial Protection Bureau (CFPB), Consumer Leasing Act (CLA), Equal Credit Opportunity Act (ECOA), Fair and Accurate Credit Transactions Act (FACT), Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), Federal Deposit Insurance Act (FDIA), Federal Deposit Insurance Corporation (FDIC), Federal Deposit Insurance Corporation Improvement Act (FDICIA), Federal Financial Institution Examination Council (FFIEC), Federal Reserve Act (FRA), Federal Reserve Board (FRB), FRB Regulations B, C, D, E, F, G, M, O, P, V, W, X, Z, AA, DD and GG, Financial Stability Oversight Council (FSOC), Foreign Corrupt Practices Act (FCPA), Gramm-Leach-Bliley Act (GLBA - a/k/a Financial Services Modernization Act - FSMA), Right to Financial Privacy Act (RFPA), Sarbanes-Oxley Act (SOx), Servicemembers Civil Relief Act (SCRA), Telemarketing and Consumer Fraud and Abuse Prevention Act, Telemarketing Sales Rule (TSR), Truth in Lending Act (TILA), Truth in Savings Act (TISA), and the USA Patriot Act (Patriot Act).

 

  • Reviewed existing and drafted proposed new corporate policies and products for compliance with consumer-related Federal statutes, guidelines, derivatives rules, agencies and regulations including the Alternative Mortgage Transaction Parity Act (AMTPA), Children’s Online Privacy Protection Act (COPPA), Community Reinvestment Act (CRA), Controlling the Assault of Non- Solicited Pornography and Marketing Act (CAN-SPAM), Electronic Signatures in Global and National Commerce Act (E-SIGN), Employee Retirement Income Security Act (ERISA), Emergency Economic Stabilization Act (EESA), Equal Credit Opportunity Act (ECOA), Fair Debt Collection Practices Act (FDCPA), Fair Housing Act (FHA), Federal Home Loan Banks (FHLB), Federal Home Loan Mortgage Corporation (FHLMC), Federal Housing Administration (FHA), Federal National Mortgage Association (FNMA), Financial Industry Regulatory Authority (FINRA), Flood Disaster Prevention Act (FDPA), Home Mortgage Disclosure Act (HMDA), Homeowners Protection Act (HOPA), Housing and Economic Recovery Act (HERA), Housing and Urban Development (HUD), International Swaps and Derivatives Association (ISDA) Master Agreements, Protecting Tenants at Foreclosure Act (PTFA), Real Estate Settlement Procedures Act (RESPA), Riegle Community Development and Regulatory Improvement Act, Secure and Fair Enforcement Program for Mortgage Licensing Act (SAFE), Telephone Consumer Protection Act (TCPA), Uniform Electronic Transactions Act (UETA), Unlawful Internet Gambling Enforcement Act (UIGEA), as well as unfair or deceptive acts and practices (originally “UDAP”, expanded to add “abusive” under Dodd-Frank, so “UDAAP”).

 

  • Reviewed existing and drafted proposed new corporate policies and products for compliance with banking-related state rules and regulations of the New Jersey Department of Banking and Insurance, New York State Department of Financial Services, Connecticut Department of Banking, Pennsylvania Department of Banking and Securities and the Delaware Office of the State Bank Commissioner, familiarity the UK 2013 Financial Services (Banking Reform) Act (ring-fencing).

 

  • Compliance audits regarding foreign regulation of third-party relationships, such as those issued by the Canadian Office of the Superintendent of Financial Institutions (OSFI), including OSFI B-10.

 

  • Compliance audits for domestic regulations of third-party issues, such as the U.S. Office of the Comptroller of the Currency (OCC) Bulletin 2013-29.

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  • Analysis of existing corporate policies and standard operating procedures (SOPs), and jurisdictional research into various risk management frameworks and control frameworks, to determine any possible non-compliance issues and compliance gaps, and providing recommendations to management about how to close such gaps to achieve full compliance.

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