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CPO and CTA Annual Reviews and Examinations: Current Trends


Speaker(s): Brian T. Daly, Mark P. Hannafey, Regina G. Thoele
Recorded on: Feb. 9, 2015
PLI Program #: 135381

Brian T. Daly is a partner with Schulte Roth & Zabel, where he advises hedge, private equity and real estate fund managers on regulatory, compliance and operational matters. He has extensive experience designing and improving compliance processes and organizational systems and helps clients navigate their initial and ongoing regulatory compliance obligations under the rules and regulations of the Securities and Exchange Commission, the Commodity Futures Trading Commission, and the National Futures Association. Brian also regularly represents clients in enforcement actions, regulatory examinations, trading inquiries, and in seeking no-action or similar relief. Having spent nearly a decade in-house as general counsel and chief compliance officer of several prominent investment management firms, Brian is well-versed in the wide range of legal and business challenges facing investment advisers, commodity pool operators and commodity trading advisers.

Brian is a recognized leader in advising alternative investment fund managers on regulatory and compliance matters and is well-known for his thought leadership in this area. He also regularly represents managers in examinations, investigations, and enforcement actions in both the securities and the commodity futures sectors. Chambers Global and Chambers USA list Brian as a “leading individual” in investment funds, noting that he is “especially skilled at assisting clients with the development of strategic compliance programs.” Interviewees also praise him for knowing “what it’s like on the ground” and for providing “practical and meaningful advice.” In addition, Brian sits on the New York City Bar Association’s Private Investment Funds Committee, and he is a chair of the Steering Committee for the Managed Funds Association’s CTA/CPO Forum and a member of the CFTC Working Group for the Alternative Investment Management Association. He formerly served as co-chair of the MFA’s General Counsel Forum, its CTA, CPO & Futures Committee, and as a steering committee member of its Investment Advisory Committee. In addition to his legal practice, Brian taught legal ethics at Yale Law School. Brian received his J.D., with distinction, from Stanford Law School.


Regina G. Thoele is Senior Vice President of Compliance at NFA.  Her current responsibilities include overseeing the Compliance Department's exam, investigation, financial surveillance, and risk management programs; working on enforcement cases; advising Members on compliance issues; assisting NFA Member committees; participating in industry conferences; and developing and monitoring Compliance Department goals.  In addition, Ms. Thoele works with NFA’s Legal Department to develop rules and interpretive guidance, makes presentations to NFA’s Executive Committee and Board of Directors and to other outside organizations, and develops strategic plans and initiatives for NFA’s Compliance Department.  From July 1994 until March 1998, Ms. Thoele held the position of Arbitration Manager and was responsible for supervising staff and helping manage the Arbitration program.  Ms. Thoele has also served as an adjunct faculty member at the Illinois Institute of Technology, where she taught a compliance course. 

Ms. Thoele attended Indiana University and received a B.S. degree in finance.  Ms. Thoele also received her designation as a Certified Regulatory and Compliance Professional through the NASD Institute at The Wharton School, as well as her designation as a Certified Fraud Examiner through the Association of Certified Fraud Examiners.