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Financial Services Industry Regulatory Compliance & Ethics Forum 2014

Speaker(s): Andrew M. Calamari, Brian C. Loutrel, Brian L. Rubin, Claudia Marmolejo, Clifford E. Kirsch, David Jaffe, Jay Palmer, Paul S. Tufaro, Paula A. Bosco, Ronald A. Holinsky, Savaria B. Harris, Steven A. Yadegari
Recorded on: Oct. 29, 2014
PLI Program #: 49446

Paul Tufaro
Managing Director and Global Head of Corporate Compliance

Paul Tufaro is the Global Head of Corporate Compliance at Citigroup.  In this role, he has compliance oversight responsibility for Citi’s corporate functions, including Operations & Technology, Risk, Finance, and Human Resources, as well as enterprise compliance responsibility for bank regulatory requirements, records management, and pensions and retirement plans.  It addition, Paul serves as the Chairman of the Citi Policy Committee which has the sole authority to approve internal policies that are intended to apply broadly across organization.    He joined Citi in 2010, as Associate General Counsel for Citibank, N.A., in which role he provided strategic legal advice to bank executive management on regulatory and compliance matters, corporate governance issues, and international franchise management.

Paul previously served as the General Counsel and Chief Compliance Officer of a leading independent investment banking firm’s wealth management division, in which role he established and managed compliance programs for a de novo bank and a newly registered investment adviser.   In addition, Paul was the General Counsel and Head of Compliance of Merrill Lynch’s primary U.S. bank subsidiary before its acquisition by Bank of America.  At Merrill Lynch he was the driver of many key infrastructure initiatives, including the development and implementation of the bank’s corporate governance framework and safety and soundness compliance program, and the overhaul of the bank’s policies and procedures.

Paul began his legal career as an attorney in the bank regulatory practice of the international law firm, Mayer, Brown & Platt, where he advised financial institutions on a wide array of regulatory compliance matters.

Paul is the former Co-Chairman of the Banking Law Committee of the New York County Lawyers Association and has authored and co-authored various articles on financial regulation appearing in the New York Law Journal, National Underwriter, and the Banking Policy Report.

Paul holds a B.A. from Tufts University and a J.D. from American University.  He is a member of the bars of New York, New Jersey, and Washington, D.C.

David Jaffe is a Director in the Regulatory Management Group at Deutsche Bank Securities, Inc. in New York City.  Previously, he was Regional Chief Counsel of FINRA’s New York Regional Office in the Department of Enforcement for 9 years.  Prior to joining FINRA (f.k.a. NASD), Mr. Jaffe was a trial attorney with the United States Commodity Futures Trading Commission (CFTC) and a Senior Assistant District Attorney in Brooklyn, New York.  Previously, he was in private practice.  Mr. Jaffe graduated cum laude from St. John’s University and received his JD from St. John’s University School of Law.

Jack (Jay) Palmer is a native of Alabama where he resides today. Jay’s twenty plus years of consulting experience has provided him with broad industry knowledge in regards to technology and business processes. Mr. Palmer has worked for (and with) such companies and clients such as; Apple, AT&T, Boeing, Cisco, Home Depot, Infosys, Kraft, Oracle, Microsoft, Vodafone UK, and countless others.

In 2010 while an Industry Principal at Infosys, Jay uncovered an illegal scheme in which the company was using B1 workers for unlawful work in the United States. Later in the 2010 he filed a whistleblower complaint which led to a 2011 Grand Jury investigation. During the 3 year period he worked with DHS, State Department, IRS, and other agencies. His cooperation was not only with Infosys, but he also educated federal agents on how the illegal operations work from the inside out.

Additionally he submitted testimony to Senator Grassley which was read into congressional record in July of 2011. In October 2013 Infosys settle criminal allegations (civilly) for an immigration record $34 million. Infosys agreed that it committed civil violations of 8 U.S.C.1324A. That particular law is titled Unlawful Employment of Aliens.

Jay holds a B.S from Auburn University in Public Administration and Business. He also is a graduate from the United States Army School of Computer Science and holds/held several certifications ranging from business to technical including networking, MCSE and MCDBA.

Brian Rubin is the leader of the Washington, DC litigation department of Eversheds Sutherland (US) LLP and he is the head of the SEC, FINRA and State Securities Enforcement Team.  Brian defends companies and individuals being examined, investigated and prosecuted by the U.S. Securities and Exchange Commission, FINRA and states.  He also represents clients in litigation and arbitrations, and counsels them on regulatory and compliance matters.  Brian has been named to The Best Lawyers in America in the areas of securities law, securities litigation and securities regulation and he has been selected for inclusion in Washington, D.C., Super Lawyers® in the area of securities litigation.

Brian regularly writes and gives presentations about securities issues.  He won the Burton Award for Legal Achievement for writing, “The House That the Regulators Built: An Analysis of Whether Respondents Should Litigate Against NASD.”  In addition, he has authored numerous articles on chief compliance officer liability, including (1) #CCOsGoingViral: An Analysis of SEC and FINRA Enforcement Actions Against Compliance Officers, Written for Millennials (and those who work with Millennials); (2) “Harry Potter and the Compliance Stone: SEC and FINRA Enforcement Actions Against Compliance Officers” (using everyone’s favorite wizard as a theme); (3) “CCOs and In-House Counsel Who Got Whacked: SEC and FINRA Disciplinary Actions Against Chief Compliance Officers and In-House Counsel” (using the Sopranos as a theme), and (4) “The Girl with the SEC/FINRA Tattoo: Disciplinary Actions Taken Against Chief Compliance Officers” (using the Stieg Larsson book as a theme).

Before joining Eversheds Sutherland, Brian was Deputy Chief Counsel with the NASD’s Enforcement Department, where he managed attorneys and examiners throughout the country.  Previously, he was Senior Counsel in the SEC’s Division of Enforcement.  Brian received his J.D. and his M.A. in Economics from Duke University and his B.S. degree from the Wharton School of Business of the University of Pennsylvania.

Claudia Marmolejo, who is an Executive Director at Morgan Stanley since 2006, is an attorney with the Morgan Stanley Wealth Management Legal and Compliance Division.  She currently provides legal coverage to the MSWM’s Chief Investment Officer as well as the firm's Global Investment Committee, Strategic Lead Management, Global Stock Plan Services, and the VIP Business Development Group. She is also a member of the Legal & Compliance Division Diversity and Inclusion Committee, where she is the Co-Head of the Relationship Management Subcommittee, which is responsible for working with outside counsel on collaborative diversity events and sharing best practices across financial institutions.  Ms. Marmolejo is the Co-Head of the Firm’s Latino Employee Network, with more than 1,000 employee members.

Ms. Marmolejo has been a speaker and participates in industry groups on issues such as conflicts management, securities laws, leadership and career development.  Most recently, she was a speaker at the Practicing Law Institute, “Financial Services Fiduciary Duties: Navigating the Emerging Regulatory Maze” seminar on Practical Compliance Considerations in Structuring a Conflicts Management Program.

Prior to joining Morgan Stanley, Ms. Marmolejo was at Citigroup from 2002-2006, as Regional General Counsel at Citigroup Asset Management (CAM), Latin America, where she had legal coverage responsibility over 5 local businesses located in Argentina, Brazil, Chile, Colombia and Mexico, as well as Miami-based teams for off-shore sales. Prior to joining CAM, Ms. Marmolejo was a Senior Regional Counsel for Citi's Corporate and Investment Bank, and Pension and Insurance businesses, covering Citi's interests in all of Latin America.

Ms. Marmolejo was a Senior Associate at Skadden, Arps, Meagher & Flom LLP from 1999-2002, where she worked at the Mergers & Acquisitions, Latin America Practice Groups--Brazil Department, focused on cross-border acquisitions, multi-jurisdictional tender offers, strategic alliances, joint ventures, corporate restructurings, private equity and IPOs. Throughout her role, Ms. Marmolejo has had extensive interactions with public and private companies, governments and NGOs, and her professional experience expands into Europe and Latin America. Prior to joining Skadden, Ms. Marmolejo was an Associate at Brown & Wood LLP (now Sidley & Austin LLP) specializing in public offerings and private placement of debt, collateralized debt and equity securities for private and public issuers from 1996 through 1999.

Ms. Marmolejo holds an LLM degree from Columbia University and a law degree from University of Buenos Aires, Law School. She is also fluent in Spanish and Portuguese.

Ms. Marmolejo is also committed to philanthropy, and is a board member for two not-for-profit organizations: TurnAround for Children (serving as Treasurer, Head of the Audit Committee and member of the Finance Committee) since 2010 and Latino Justice PRLDEF since 2012 (member of the Audit Committee) and was a board member of Day One from 2009 until 2011.

Cliff Kirsch began his career at the U.S. Securities and Exchange Commission (SEC), became chief legal officer for one of the country’s largest dually- registered broker-dealer/advisers and then joined Sutherland (now Eversheds Sutherland) in 2006. He relies on his regulatory and in- house background and an up-to-date knowledge of regulatory developments to provide practical and innovative counsel to broker-dealers and investment advisers in the areas of securities regulation and compliance.

With more than 25 years of experience, Cliff regularly counsels clients on the design and distribution of investment products including wrap-fee programs and other advisory products, mutual funds, bank collective investment funds and insurance products. He also focuses on issues related to the design and implementation of compliance programs at financial services firms.

While at the SEC, Cliff received the Manuel F. Cohen Award, which recognizes younger lawyers who have displayed outstanding legal ability, integrity and judgment and he served as assistant director of the SEC's Division of Investment Management.

Cliff is a frequent speaker at industry conferences, and is the author and editor of two of the leading treatises in the broker-dealer and adviser arena: Broker-Dealer Regulation and Investment Adviser Regulation (published by the Practising Law Institute).

Cliff is also co-founder of the Julia Anne Kirsch Foundation, which seeks to serve the needs of disabled individuals and their families.


Eversheds Sutherland counsels a coalition of major life insurance companies on evolving state and federal regulations and other legal developments.

Eversheds Sutherland represents a coalition of major life insurance companies, which collectively account for more than 80% of the annuity business in the United States, in their efforts to affect the direction and details of various SEC, FINRA, CFTC, NAIC and state rule proposals and initiatives.

Eversheds Sutherland serves as outside counsel on broker-dealer and adviser regulatory issues for one of the largest independent broker-dealer networks in the country.  Eversheds Sutherland serves as regular primary outside counsel on broker-dealer and adviser regulatory issues for one of the largest independent broker-dealer networks in the country.

Eversheds Sutherland represents coalition of collective trust fund sponsors, advisers and other service providers.

Eversheds Sutherland serves as counsel to the Coalition of Collective Trust Funds. Among other things, Sutherland monitors and reports on legal and regulatory matters affecting collective trust funds.

Professional Activities

Member, New York City Bar Association

Faculty, FINRA Compliance Institute at The Wharton School of the University of Pennsylvania

Former Chair, FINRA Variable Products Committee

Former Board Member, National Society of Compliance Professionals

Paula A. Bosco is Managing Director, Chief Regulatory Counsel and Chief Compliance Officer of New Mountain Capital, L.L.C., where she leads the legal and compliance program for four SEC-registered investment advisers that individually manage several hedge, credit/loan/SBIC and private equity funds totaling $14 billion in committed capital.  She is also an Executive Officer, and the Chief Regulatory Counsel, CCO and Corporate Secretary, of the firm’s publicly traded business development company, New Mountain Finance Corporation (NYSE: NMFC).  Ms. Bosco has more than 18 years of business, legal, and regulatory compliance experience serving in various litigation, transaction and advisory roles for investment advisers, broker-dealers, dual-registrants, hedge funds, private equity funds, credit funds and BDCs.   

Prior to joining NMC, Ms. Bosco held a number of senior legal and compliance positions with several prominent Wall Street firms including Lehman Brothers Inc. where, as CCO, her responsibilities included implementing and overseeing the compliance program for all investment advisory activities within the firm’s Private Investment Management division.  Prior to Lehman, Ms. Bosco held various positions at Citigroup Global Markets, Inc. (SVP and Assistant Director of International & Investment Advisory Compliance; Senior Regulatory Counsel), Schulte, Roth & Zabel LLP (Litigation Associate), the American Stock Exchange (Assistant Chief Counsel, Enforcement Division), and PaineWebber (DVP & Counsel, Litigation Department). Prior to attending law school, Ms. Bosco began her career in the industry as a sales trading assistant in the Asian equity markets.

Prominent in industry activities, Ms. Bosco is a frequent speaker on legal and compliance-related issues at various industry conferences and is regularly quoted in various industry trade publications.  She is an active member of the Private Equity Growth Capital Council (PEGCC), where she has been instrumental in leading efforts to lobby and educate regulators about private fund industry matters and proposed rulemaking initiatives.  She is also an active member of the American Bar Association, Section of Business Law, Committee on Federal Regulation of Securities, Subcommittee on Investment Companies and Investment Advisers and 100 Women in Hedge Funds (100WHF).  Additionally, Ms. Bosco is a member of the Editorial Board of the Journal of Securities Law, Regulation & Compliance.  In fulfilling her commitment to academia, Ms. Bosco serves as the Chairwoman of the CUNY School of Law Foundation Board, as a Director of the CUNY School of Law School Board of Visitors, and as an Advisory Council Member of the Institute for Financial Market Regulation (IFMR), a cooperative association between the University at Albany and Albany Law School that aims to develop interdisciplinary research and education in financial market regulation for students at both schools.   Ms. Bosco is also on the faculty of the Practicing Law Institute (PLI) and is a frequent lecturer at Fordham University School of Law.

From 2005-2008, Ms. Bosco served as Co-Chair of the Securities & Exchanges Committee at the New York County Lawyers' Association (NYCLA).  From 2006 through 2008, she served on the SIFMA Compliance & Legal Division’s Investment Advisers Committee, and in 2007, she was named as one of the 20 Rising Stars of Compliance by Institutional Investor News. 

Ms. Bosco holds a J.D., an M.B.A. in Finance (concentration in Investment Management), and a B.A. in Political Science.  She is admitted to practice in the U.S. District Court, Eastern and Southern Districts of New York, and the U.S. Court of Appeals, Second Circuit.

Savaria Harris is an experienced litigator with trials in state and federal courts as well as with government and internal investigations in the white collar context.

She is experienced in government and internal investigations, ethics and compliance training, as well as litigation and trial representation. Her practice centers on providing clients with an integrated approach to addressing fraud, anti-bribery and anti-corruption issues under the False Claims Act, Foreign Corrupt Practices Act and their equivalents.

In addition to her practice, Savaria is a frequent lecturer on workplace ethics, internal investigations and compliance. Savaria is an adjunct professor of Workplace Ethics at Georgetown University and a faculty member for the Practicing Law Institute, the American Conference Institute and The TRACE Anti-Bribery Specialist Accreditation program. She is also a member of the Advisory Council for the Association of Certified Fraud Examiners, the NYU Program on Corporate Compliance and Enforcement, and the National Employment Law Council. Finally, she is the author of an interactive video game "A Day In Your Shoes" for healthcare system clients to provide scenario-based training to physicians on the False Claims Act, Stark Act and Anti-Kickback Act laws.



Georgetown University Law Center J.D.

Yale University B.A.


District of Columbia

New York



Steven A. Yadegari is Chief Operating Officer and General Counsel of Cramer Rosenthal McGlynn, LLC, a registered investment adviser located in New York.  Mr. Yadegari also serves as Chief Legal Officer and Chief Compliance Officer for the CRM Mutual Fund Trust and is a Director of the CRM UCITS PLC.  Prior to joining CRM, Mr. Yadegari worked at K&L Gates and before that Proskauer.  Mr. Yadegari also has served as Senior Counsel in the Office of the Chief Counsel, Division of Enforcement at U.S. Securities and Exchange Commission and as an Attorney-Adviser in the Division of Market Regulation.  He is a frequent contributor to industry conferences and publications.  In 2007, Mr. Yadegari was recognized as a top twenty “Rising Star of Compliance” by Institutional Investor.  Mr. Yadegari is an adjunct professor at Benjamin N. Cardozo School of Law and teaches in the areas of dispute resolution and negotiation.  Mr. Yadegari is a Past President of the Association for Conflict Resolution of Greater New York, a not-for-profit organization, and is a Past President and former Chairman of the Old Westbury Hebrew Congregation.  Mr. Yadegari has received a BA from Brandeis University and earned his JD from the Benjamin N. Cardozo School of Law.  Mr. Yadegari has been awarded an honorary Master’s Degree from the CCO University, a division of the Regulatory Compliance Association for which he serves as an advisor and senior fellow. 

Andrew M. Calamari is the Director of the Commission’s New York Regional office.  He served as Associate Director and co-head of Enforcement in New York for eight years before assuming his present position.  Before coming to the Commission in 2000, Mr. Calamari was engaged in private law practice for nearly 15 years, including as a litigation partner at Donovan Leisure Newton & Irvine.  He has co-authored a treatise on Complex Litigation and is co-author of the securities litigation chapter in a Matthew Bender treatise on securities law.

Brian Loutrel is a Vice President at New York Life Insurance Company in charge of anti-money laundering compliance, privacy/information security compliance as well as business conduct/ethics compliance programs.  Brian is the Anti-Money Laundering Compliance Officer for New York Life Insurance Company, New York Life Insurance and Annuity Corporation, and NYLIFE Securities LLC.  In addition, Brian is New York Life’s Chief Privacy Officer and Chief Ethics Officer.

Brian joined New York Life in June 1982 after graduating from Barry University in Miami, Florida.  During his tenure with New York Life, Brian spent fifteen years with the Corporate Audit Department conducting operational and information systems audits and fraud investigations, and the last sixteen years with the Corporate Compliance Department, where he has managed several divisions, including branch office compliance examinations, agent licensing and FINRA registration, complaint handling, sales material review and the handling of regulatory inquiries and examinations.

Brian is New York Life’s representative on the Anti-Money Laundering Committee and the Insurer Corporate Confidentiality Task Force of the American Council of Life Insurers (ACLI).  He is a Certified Internal Auditor, a Certified Financial Services Auditor, and holds FINRA’s Series 7, 24 and 63 registrations.  Brian also is a member of LIMRA’s Regulatory Compliance Committee.  He also has memberships in the Association of Certified Anti-Money Laundering Specialists and the International Association of Privacy Professionals, and over the years has spoken at numerous seminars and conferences about the insurance industry’s AML/OFAC compliance efforts and privacy / information security issues.

Ron Holinsky serves as Vice President, Chief Compliance Officer & Assistant General Counsel for Lincoln Financial Group, having joined Lincoln Financial in September 2013. In that role, he serves as the enterprise chief compliance and ethics officer for Lincoln Financial.  Prior to that, he served as Vice President & Deputy General Counsel for Janney Montgomery Scott LLC, as well as Chief Legal Officer for its investment adviser subsidiary, Janney Capital Management LLC.  Prior to Janney, he served as Associate General Counsel for Legg Mason, senior associate for K&L Gates and senior counsel for the SEC’s Division of Investment Management and Office of Compliance Inspections and Examinations. He is a graduate of West Virginia University’s business school and University of Baltimore School of Law, evening division. Mr. Holinsky has nearly 20 years of regulatory legal and compliance experience and leadership in the securities and financial services industries.