VICE PRESIDENT REGULATORY ENFORCEMENT OVERSIGHT SPECIALIST
Six Sigma DMAIC & Lean methodologies for process improvement. Diversified product knowledge in equities and fixed income, with expertise in capital markets, derivatives, Bankruptcy, and structured products. Excellent project management skills and well-versed in Microsoft Projects and VISIO for process-mapping. Proficiency in Microsoft Office products (Access, Excel, Outlook, Work, PowerPoint), with a strong knowledge in Microsoft Excel, including familiarity with pivot tables, vlookups, and basic macros. Analytical Problem Solving and Risk Management/Remedial Measures
10/2011 to Current
Vice President Regulatory Enforcement Oversight SpecialistBank of America － Charlotte, NC.
Worked independently under general supervision, with latitude for innovative and independent judgment, to diligently resolve outstanding regulatory issues with speed and finality.
Whether it is acting as Subject Matter Expert for all Consent Order related matters, or participating in business routines/meetings, I mitigated issues that might arise when communicating with our Prudential Regulators, decreasing both compliance and reputational risks.
On a day-to-day basis, I worked to drive both collectively and individual level accountability to ensure core risk culture dimensions are understood, interpreted, and applied in a consistent manner.
By timely sharing information, rapidly elevating emerging risks, and willingness to challenge practices, I made the front line aware, equipped and motived to appropriately weigh the risks and rewards of their actions, including the risk of noncompliance.
Selected Accomplishments Compliance Risk Management Consent Order Oversight: Whether it be helping with the Action Plan by mapping the underlying MRA requirements to the Orders; analyzing other banks under similar orders, providing comparison for similarities and tracking; or helping in writing our quarterly progress reports, I strove to ensure we meet our requirements in a timely and consistent manner.
This included writing more than Enterprise Risk Committees Updates: Summarizing remaining key Consent Order sub-articles identified by Prudential Regulators needing additional enhancements, outlining historic commitments, audit validation errors, enhancements we committed to making and their status.
In conjunction with business and control partners, jointly identified a set of outcome focused performance metrics and key risk indicators to include in Consent Order sustainability dashboards for our Board of Directors - and designated "Compliance Committee" -to monitor in order to spot potential issues.
Bankruptcy Process Summary for Enterprise Risk Committee Board Member: Created a succinct summary of our end-to-end Bankruptcy Process which included: Bankruptcy Set Up; Proof of Claim Filing; Payment Processing & Case Monitoring; and filing with the Bankruptcy Court a Motion for Relief from the Automatic Stay.
In addition, I included a Summary of Bankruptcy Enhancements undertaken over the prior 3 years, as well as, potential opportunities for improvement that would be undertaken during the following year.
Consent Order Mapping: Analyzed and mapped the requirements of 11 Article III Action Plans to underlying MRA remediation plans, corresponding Consent Orders issued in conjunction of interagency efforts or other settlement objections.
By doing so, I was able to identify which requirements have already been satisfied, where the Consent Order expanded the requirements needed, and what is needed to address this.
In addition, this undertaking helped identify instances where the requirements subsume the prior for ancillary documentation/validation efforts - ensuring proper visibility is maintained on all Consent Order requirements, allowing quicker validation efforts and speeding up our resolution timeline.
Helped in the Drafting of a Debtor-in-Possession Memo for the OCC: This included providing the Statutory Basis for Debtor-in-Possession Financing under the Bankruptcy Code, specifically § 364 (a-d), analysis of recently filed DIP Financing Agreements to ascertain industry practices in drafting Flood Requirements in both the Covenants & Affirmations and proving clarification on industry trends in collateralization and perfection practices for said agreements.
Maintaining Proper Regulatory Mindset Timely Responding to Increasingly Unique Regulatory Requests: This includes drafting white papers for our Prudential Regulators, providing a cogent summary of the issues, our positions, and if applicable, any effort undertaken to remedy deficiencies identified to responding to over 200 additional requests made by onsite examiners during the course of a Consent Order validation examination.
Created Markets Activities Definition Decision Tree, incorporating the requirements of the Federal Reserve FX Consent Order, as well as, the Federal Reserve Designated Market Activities Enumerated List (60+ products.) Regulatory Environment & Outlook: Trends and Lessons Learned Analysis.
This included, for example, reviewing the 583 enforcement actions issued by Federal Regulators (Federal Reserve, OCC, FDIC & CFPB) in 2014, breaking out restitutions by institutions and CMP by institutions and identifying the that while the number of severe enforcement actions is stabilizing, the associated fines have increased markedly since 2010.
Bankruptcy Testing Assessment: Undertook an assessment of current testing conducted within Bankruptcy operations; identifying key regulatory requirements, whether this be GSE Servicing Guidelines or Federal Bankruptcy Rules, and then comparing testing scripts for QA/QC testing, Audit Test Plans and Compliance testing to identify gaps.
Benchmarking Industry Public Enforcement: Researched all outstanding Public Enforcement Actions entered into by financial institutions in our peer group, then benchmarking the associated clauses of the Cease and Desist orders for differences with our agreements, as well as the differences in the associated CMPs assessed.
Ensuring Proper Culture of Compliance Supporting Ongoing Supervisory Examinations: For example, I created a summary of applicable regulations and laws for deposit fees which fall under the purview of the CFPB, creating an emerging trend analysis incorporating Rule Writing Plans, CFPB Exam Handbook & Procedures, public speeches and Congressionally mandated reports to create a potential Exam Test Plan to help prep for an upcoming exam.
From a compliance and operations point of view, this approach proved more effective than waiting for our on-site examiners request letter.
Effectively Communicating our Risks: Identifying ways to improve cross-functional engagement and ensuring communication, whenever possible, is delivered with proper gravitas and impact.
Whether this be in the form of summarizing issues for the State of Compliance Reporting, providing guidance where validation of lien status is a Safety & Soundness factor, creating talking points for senior management to use at Board of Directors meeting and assisting in responding to both regulatory and Congressional informational requests.
Evidence Collection Routines: Helped oversee both the creation of and execution there forth, to ensure material documentation is retained to demonstrate compliance with Public Enforcement Actions and current risk management processes.
In addition, I helped manage outside requests for privilege documentation, which included creating a privilege log and working with internal and outside counsel to respond in a timely manner for requested documentation.
OCC PCN & ECN Analysis Request: Partnered with Front Line Units to conduct an analysis of our Bankruptcy Payment Change Notice filing process for all 94 Bankruptcy Districts.
My contribution to this completed assessment included: A summary of our PCN filing process, how this process is validated, the narrow use of vendors and how we effectively oversee them, and a summary of prior self-identified PCN issues and subsequent enhancements undertaken to rectify these issues.
Completed OCC provided template describing the administrative requirements and local rules for ECF filing for every Bankruptcy district and how our PCN processes comports with them Escrow analysis for bankruptcy account summary, describing how we conduct escrow anaysis for Chapter 13 borrowers, historical issues we had and process enhancements undertaken to address them.
01/2011 to 05/2011
Financial Service InternFederal Reserve Bank of Boston － Boston, MA.
Presented written and oral policy analysis to the Assistant General Counsel on SEC and CFTC new regulatory powers for clearing derivatives; "Regulated Municipal Advisor" registration under Section 15B of the Securities Exchange Act and Rule 206(4)-5 "Pay to Play".
Researched and drafted a memorandum on national banks ability to engage in market making activities under the Volcker Rule.
Provided statutory analysis on the elimination of the "Private Advisor Exemption" under the Investment Advisor Act of 1940 and the new required Form ADV Part 2A and Form PF.
08/2009 to 12/2009
Research FellowUniversity of San Diego School of Law － San Diego, CA.
Researched the Congressional intent of the American Job Creation Act of 2004, REMIC, HOEPA and financial accounting rules to analyze the effects of legislation on the mortgage-backed securities industry.
Analyzed the loss severity methodology used by Credit Rating Agencies for HELOCs and cash flow models used for MBS pricing.
LL.M: Banking and Financial LawBoston University School of Law － Boston, MAGPA: GPA: 3.78Banking and Financial Law GPA: 3.78
Financial Services & Lending and Credit Transactions
Activities: Steering Committee for the Institute for Finance, Law & Policy Workshop Series on Hedge Fund Reform
J.DUniversity of San Diego School of Law － San Diego, CA
B.A: HistoryUniversity of California － Los Angeles, CAGPA: magna cum laudeHistory magna cum laude
Steven Lessard & Richard Ngo, Riding the Juice Train to Bankruptcy: Ch. 9 Eligibility After In re Las Vegas Monorail Company, Norton Journal of Bankruptcy Law & Practice, Vol. 20, No.3 at 387 (June 2011). Steven Lessard, E.U. Re-Hypothecation and Lehman Brothers' Bankruptcy: Changes That Must Be Made to the MiFID, appearing in Folsom, Gordon, Spangole, International Business Transactions, Practitioners Treatise (2010 Treatise Supplement). Steven Lessard, Lending in the Shadow of the La How the American Job Creation Act of 2004 Encouraged Misallocation of Risk (Discussion Draft) Panelist, Institute for Finance, Law & Policy Workshop Series on Hedge Fund Reform on Rehypothecation and Lehman Brothers Bankruptcy, Boston University School of Law (April 4, 2011). Continued . . .
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Companies Worked For:
Bank of America
Federal Reserve Bank of Boston
University of San Diego School of Law
Boston University School of Law
University of San Diego School of Law
University of California
Job Titles Held:
Vice President Regulatory Enforcement Oversight Specialist
Financial Service Intern
LL.M : Banking and Financial Law Financial Services & Lending and Credit Transactions
Activities: Steering Committee for the Institute for Finance, Law & Policy Workshop Series on Hedge Fund Reform J.D B.A : History
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