Compliance Outreach Program
for Investment Advisers and Investment Companies
National Seminar Speaker Biographies
January 31, 2012
Introductory Remarks
Carlo di Florio
Carlo di Florio became the Director of the Office of Compliance Inspections and Examinations on January 25, 2010. Prior to joining the Commission, Mr. di Florio was a partner in the Financial Services Regulatory Practice at PricewaterhouseCoopers (PwC). While in private practice, Mr. di Florio was one of PwC’s national leaders in corporate governance, enterprise risk management (ERM) and regulatory compliance and ethics. Mr. di Florio has played a leading role in setting new industry standards, including the COSO Enterprise Risk Management standard and the Open Compliance and Ethics Guidelines (OCEG). He has extensive experience assessing the effectiveness of regulatory compliance, risk management and corporate governance programs. He has also led numerous fraud and corruption investigations nationally and internationally. Mr. di Florio received his Master of Laws (LL.M) with distinction from Georgetown University Law Center, his Juris Doctor (JD) from Penn State University’s Dickinson School of Law, and his Bachelor of Arts (BA) in Political Economy from Tulane University.
Eileen Rominger
Eileen Rominger joined the U.S. Securities and Exchange Commission as the Director of the Division of Investment Management in February, 2011. The Division is responsible for developing regulatory policy and administering the federal securities laws applicable to investment advisers and funds. Prior to becoming the Director, Ms. Rominger had a 30-year career in portfolio management, most recently as Chief Investment Officer at Goldman Sachs Asset Management where she had responsibility for oversight of portfolio management teams. Prior to that, she was at Oppenheimer Capital for 18 years, and held roles in portfolio management and as an Executive Committee member. Ms. Rominger holds an MBA in Finance from The Wharton School, University of Pennsylvania, and a BA from Fairfield University.
Panel 1: Compliance and Enterprise Risk Management
Andrew Bowden
Drew Bowden joined OCIE in November 2011 and heads its investment adviser and investment company examination program. Mr. Bowden previously worked at Legg Mason, Inc., and later for Legg Mason Capital Management in various roles, including legal, compliance, operations, sales, service, marketing, and corporate governance. Before joining Legg Mason, Mr. Bowden was a trial attorney and partner at a major Baltimore law firm. He has also served on the Board of Governors and Executive Committee of the Investment Adviser Association. He holds a Bachelor of Arts degree from Loyola University in Baltimore and a law degree from The University of Pennsylvania.
Kevin Goodman
Kevin W. Goodman serves as Associate Regional Director of the SEC’s Denver Regional Office, where he manages the Regulation program. Mr. Goodman joined the SEC staff in Los Angeles in 1992 as an Attorney-Adviser, and later served as Branch Chief, Senior Special Counsel, and Assistant Director, all with the Investment Adviser/Investment Company examination program. Mr. Goodman graduated from Purdue University in 1982 with a degree in accounting and received his law degree from Indiana University in 1985. Prior to joining the staff, Mr. Goodman practiced corporate and securities law in the private sector with an emphasis on mergers and acquisitions
Philip Kirstein
Philip L. Kirstein is the Independent Compliance Officer and the Senior Officer of the AllianceBernstein U.S. registered investment companies. Previously, he was the General Counsel of Merrill Lynch Investment Managers, LP (formerly Merrill Lynch Asset Management) from May 1984 through March 2003 and was Of Counsel to Kirkpatrick & Lockhart LLP from October 2003 until October 2004.
Mr. Kirstein is a member of the New York City Bar Committee on the Investment of Funds and the most recent past Chair of the New York City Bar Committee on Investment Management Regulation. He is also a former member of the American Bar Association Committee on Federal Regulation of Securities, Subcommittee on Investment Companies and Investment Advisers; and a former member of the Executive Committee and Board of Directors of ICI Mutual Insurance Company and the Planning Committee of the Investment Company Institute/Federal Bar Association Mutual Fund Conference. Mr. Kirstein was a member of the Independent Directors Council Task Force that prepared the Board Oversight of Fund Compliance Report. He is a frequent panelist at conferences regarding investment company legal, compliance and regulatory issues.
Mr. Kirstein is a graduate of the University of North Carolina (Chapel Hill), College of Law, Syracuse University and School of Law, New York University.
Mr. Kirstein is a former member of the Board of Directors of Cancer Care of New Jersey and a former member of the board of Directors of the Susan G. Komen for the Cure, Central and South Jersey affiliate. He is currently on the Finance and Investment Committees of the New York New Jersey Trail Conference, Inc. He retired as a Captain of the United States Naval Reserve.
Joseph Carrier
Joseph Carrier is the Chief Risk Officer for Legg Mason, Inc. Most recently, he was Vice President and Division Head of Investment Operations at T. Rowe Price and Treasurer and Principal Financial Officer of the T. Rowe Price Mutual Funds. Prior to joining T. Rowe Price, he served as the Industry Chairman for Coopers & Lybrand’s Investment Management practice in the United States. He has also served as Assistant Chief Accountant in the Division of Investment Management with the Securities and Exchange Commission. Mr. Carrier is the Chairman of the Investment Company Institute’s Risk Management Committee, a former member of the Investment Companies Expert Panel of the AICPA, and the immediate past chair of the Accounting easurer’s Committee of the Investment Company Institute. He was also a member of the AICPA Investment Companies Committee from 1994-1997 and a contributing author to the Audit and Accounting Guide for Investment Companies. Mr. Carrier is a graduate of Loyola College in Baltimore and a Certified Public Accountant.
Panel 2: Trading Practices
Erozan Kurtas
Erozan Kurtas joined NYRO IA/IC as a Senior Specialized Examiner focusing on Quantitative Algorithms, Computerized Trading, Risk Management in hedge funds, and Structured Products. He has strong theoretical and practical background in the financial algorithms used in modeling and trading a wide range of products, as well as the mathematical strategies used in algorithmic and computerized trading. Mr. Kurtas was an Associate Director and senior analyst at Standard and Poor’s focusing on evaluating structured products, including CLOs/CDOs and Funds of Hedge Funds, from the financial and rating criteria perspectives. Prior to that, Mr. Kurtas worked as a Research Director at Seagate Technology where he led a distinguished group of scientists designing algorithms for detection and correction of anomalies in data sequences. Mr. Kurtas has authored/co-authored two technical books (CRC Press), over 100 scientific articles in peer reviewed top journals and conferences, and holds 20 patents issued by USPTO on algorithms. Mr. Kurtas has an MBA from Carnegie Mellon University, a PhD and MSc in Electrical and Computer Engineering from Northeastern University, and a BSc in Electrical and Electronics Engineering from Bilkent University in Ankara, Turkey.
David Grim
David W. Grim is an Assistant Chief Counsel in the Investment Management Division of the Securities and Exchange Commission. Mr. Grim, who joined the Commission in 1995, previously served in a variety of positions in the Division of Investment Management’s Office of Chief Counsel and Office of Investment Company Regulation. Mr. Grim received his A.B. cum laude from Duke University and his J.D. from George Washington University.
Chuck Senatore
Chuck Senatore is head of corporate compliance for Fidelity Investments, a leading provider of investment management, retirement planning, portfolio guidance, brokerage, benefits outsourcing and other financial products and services to more than 20 million individuals, institutions and financial intermediaries. He is responsible for overseeing the fulfillment of regulatory requirements across Fidelity’s investment management, investment advisory, institutional and brokerage businesses.
Prior to joining Fidelity in May 2003, Mr. Senatore served as co-head of Global Compliance at Merrill Lynch, after having served as head of the firm’s Regulatory Affairs Group. From 1994 to 1997, Mr. Senatore served as director of the Securities and Exchange Commission’s Southeast Region.
Prior to his service at the Commission, Mr. Senatore practiced law in South Florida, and served as an assistant U.S. attorney in the Southern District of Florida, including service as chief of that office’s Public Corruption Section.
Mr. Senatore received a bachelor of arts degree in economics from Williams College and earned a J.D. from the University of Chicago Law School.
Mr. Senatore has spoken and written on various securities laws subjects. He currently serves as vice-chair of FINRA’s National Adjudicatory Council, executive committee member of the National Society of Compliance Professionals, as well as a member of the Standing Advisory Group to the Public Company Accounting Oversight Board. He also serves on the SIFMA Compliance and Regulatory Policy Committee, the FINRA Compliance Advisory Committee and the ICI Chief Compliance Officer Committee. He served previously as chair of the Board of Directors of the National Society of Compliance Professionals as well as chair of its Investment Adviser Committee, chair of the NASD’s District 10 Business Committee in New York, as well as an adjunct professor of Securities Regulation at the University of Miami Law School.
Jennifer Duggins
Jennifer Duggins is the Vice President and Chief Compliance Officer of Chilton Investment Company, LLC, an investment adviser with over $6 billion in assets under management headquartered in Stamford, Connecticut. Ms. Duggins has served as a member of the Chief Compliance Officer Steering Committee of the Managed Funds Association, an industry trade group and is a faculty member for the National Society of Compliance Professionals (NSCP). Ms. Duggins also serves as a member of NSCP’s Hedge Fund Committee. Prior to joining Chilton in 2006, Ms. Duggins was a Vice President in the Legal and Compliance Department at Andor Capital Management, LLC from 2003-2006. Ms. Duggins has a B.A. in History from New York University.
Panel 3: Dodd-Frank Wall Street Reform and Consumer Protection Act
Norm Champ
Norm Champ is the Deputy Director of the Office of Compliance, Inspections and Examinations of the U.S. Securities and Exchange Commission. Prior to becoming Deputy Director, Mr. Champ was the Associate Regional Director for Examinations in the New York Regional Office of the Commission. Before joining the staff of the Commission in 2010, Mr. Champ was Executive Vice President and General Counsel of Chilton Investment Company, an investment adviser to long/short equity hedge funds and managed accounts. He has been a panelist on examination topics at programs by the Commission, the Practicing Law Institute, the Saudi Central Bank, the New York City Bar Association and the International Bar Association. Mr. Champ has participated in the Commission’s Technical Assistance program in Saudi Arabia and Abu Dhabi. From 2006 to 2009 Mr. Champ was a member of the Board of Directors of the Managed Funds Association, an alternative investment industry trade group, and was the Chair of its Investor Protection Task Force. Mr. Champ is a Lecturer on Law at Harvard Law School where he teaches Investment Management Law. Prior to joining Chilton in 1999, Mr. Champ was with the law firm of Davis Polk & Wardwell. From 1990 to 1992, Mr. Champ clerked for the Honorable Charles S. Haight, Jr. of the U.S. District Court for the Southern District of New York. Mr. Champ has an A.B. in History from Princeton University and a J.D. from Harvard Law School. He was a Fulbright Scholar at King’s College London where he received his M.A. in War Studies.
Robert Plaze
Robert E. Plaze is Deputy Director of the Division of Investment Management of the U.S. Securities and Exchange Commission. The Division is responsible for administering the securities laws regulating America’s $43 trillion investment management industry, including mutual funds, money market funds, exchange-traded funds, and advisers to institutional clients (such as pension funds and hedge funds) as well as individual clients. More specifically, on behalf of the Commission, the Division administers the Investment Company Act and the Investment Advisers Act of 1940.
Mr. Plaze has been a member of the Commission staff for 28 years during which he has held positions of significant responsibility. Most recently he has been responsible for preparing rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act affecting money managers, and amendments to rules governing the operation of money market funds. Mr. Plaze holds an AB (1978) and JD (1983) from Georgetown University and is a member of the District of Columbia Bar.
Thomas Kennedy
Thomas Kennedy is a member of Arden Asset Management and he has served as Chief Compliance Officer with responsibility for all of Arden’s compliance programs globally since he joined the firm in 2008. Arden Asset Management LLC is an investment adviser registered with the U.S. Securities & Exchange Commission and is based in New York, and Arden Asset Management (UK) Ltd. is authorized by the U.K. Financial Services Authority and is based in London. Arden’s sole business is to design, manage and distribute fund of hedge fund vehicles for institutional and high net worth investors located throughout the world. Arden manages private commingled funds, customized portfolios and closed-end investment companies registered under the Investment Company Act of 1940 and the Securities Act of 1933. Mr. Kennedy also serves as Chief Compliance Officer for the firm’s registered fund of hedge fund family.
Prior to joining Arden, Mr. Kennedy was with Citigroup. Over a period spanning approximately eight years he held a number of positions including Director of Citi Private Bank’s Asset Management and Trust Compliance overseeing compliance matters affecting domestic and international asset management and trust products made available globally to clients of Citi Private Bank and Citi Smith Barney, Director of Compliance for Citi Private Bank’s U.S. Region, Chief Compliance Officer of Global Hedge Strategies, LLC, and Senior Vice President and Head of Securities and Fund Services Compliance for Citigroup’s Global Transaction Services.
Prior to joining Citigroup, over a period spanning approximately eight years Mr. Kennedy held positions with JP Morgan Chase and Morgan Stanley and with the law firm Dewey Ballantine. Mr. Kennedy enjoys public speaking and has been an active advocate for the industry. He has a BA in Criminal Justice from Iona College, and a law degree from St. John’s University School of Law.
Eric Komitee
Eric Komitee is the General Counsel of Viking Global Investors LP and a member of its Management Committee. He oversees all legal, compliance and regulatory matters for the firm. Prior to joining Viking, Mr. Komitee was an Assistant U.S. Attorney in the Eastern District of New York, where he served as Chief of the Business and Securities Fraud Section. From 1998 to 2000, he was an Associate at Skadden, Arps, specializing in regulatory, compliance and white-collar crime matters. From 1996 to 1998, he was an Associate in the Corporate department of Cravath, Swaine and Moore, focusing on securities underwriting and mergers and acquisitions transactions. Mr. Komitee served as a law clerk to the Hon. J.L. Edmondson of the United States Court of Appeals following law school. He graduated from New York University School of Law, where he was a member of the NYU Law Review, and Emory University.
Panel 4: Enforcement-Related Matters
Rosalind Tyson
Rosalind Tyson is the Regional Director of the SEC's Los Angeles Regional Office, which has a staff of 170 in its enforcement and regulatory programs and is responsible for securities law enforcement in southern California, Nevada, Arizona and Hawaii. Ms. Tyson joined the Los Angeles office as an enforcement staff attorney in 1982, following several years in private practice. She served as staff attorney and then Branch Chief of the Branch of Full Disclosure, reviewing initial public offering registrations of small business issuers. In 1988, Ms. Tyson became Assistant Regional Director and in 1993, Associate Regional Director. As Associate Regional Director until 2007, Ms. Tyson managed the broker-dealer, investment adviser and investment company inspection programs, as well as bankruptcy review. Ms. Tyson graduated from Georgetown University’s School of Languages and Linguistics, the University of Hawaii, and Stanford Law School. She is a member of the California bar.
Barbara Chretien-Dar
Barbara Chretien-Dar is an Assistant Director at the SEC’s Division of Investment Management (Office of Enforcement Liaison). That office reviews the Commission’s enforcement cases involving investment companies and investment advisers.
Prior to joining the Office of Enforcement Liaison, Ms. Chretien-Dar served as a special counsel in the Division’s Office of Chief Counsel (Financial Institutions Branch), the office responsible for interpretive guidance and no-action positions under the Investment Company Act and the Investment Advisers Act. Ms. Chretien-Dar began her legal career with the Commission, joining the Division of Investment’s Office of Investment Company Regulation as a staff attorney.
Ms. Chretien-Dar received her J.D. from the University of Oklahoma, and her B.A. from the University of Maryland.
Bruce Karpati
Bruce Karpati is the Co-Chief of the Asset Management Unit of the SEC’s Division of Enforcement. The Asset Management Unit focuses on investigations involving investment advisers, investment companies, mutual funds, hedge funds, and private equity funds. Mr. Karpati has led investigations and cases involving valuation, performance, insider trading, conflicts of interest, derivatives, manipulation, board governance, soft dollars, best execution, disclosure, market timing and late trading, among other issues. Previously, Mr. Karpati was founder and head of the SEC’s Hedge Fund Working Group, and served as Assistant Regional Director for the New York Regional Office of the SEC. Earlier, he was a Branch Chief and Attorney in the Division of Enforcement. Prior to the Commission, Mr. Karpati was an Associate at Dechert LLP in Washington, D.C. Mr. Karpati received his law degree from the University at Buffalo Law School and his undergraduate degree in International Relations from Tufts University.
Robert Kaplan
Robert B. Kaplan is the Co-Chief of the Asset Management Unit of the SEC’s Division of Enforcement. Prior to his appointment to the AMU in January 2010, Mr. Kaplan served for six years as an Assistant Director in the Division of Enforcement. From 1998-2004, he served as an Assistant Chief Litigation Counsel for the Division, where he litigated SEC enforcement actions in District Court and administrative proceedings. From 1995 to 1998, Mr. Kaplan spent three years as a staff attorney in the Division of Enforcement. Prior to joining the Commission, he worked in private practice for a law firm in New York City. Mr. Kaplan received his law degree from the New York University School of Law and his undergraduate degree from Columbia College, Columbia University.
Panel 5: Safety and Soundness of Client Assets/Custody
Donna Esau
Donna Esau is a staff member of the Securities and Exchange Commission and serves as an Assistant Regional Director in the examination program. She has been employed with the SEC for over 15 years.
Ms. Esau started as an examiner through the outstanding scholars program and was promoted to a branch chief in the Atlanta Regional Office. In 2009, she was promoted again to an Assistant Regional Director and relocated to the Fort Worth Regional Office where she oversaw both the investment adviser and broker-dealer programs. In 2011, Ms. Esau transferred to the Atlanta Regional Office to work in the examination program as an Assistant Regional Director. She was previously an examiner with the Department of Veterans Affairs.
Ms. Esau has a Bachelor in Business from University of North Carolina at Pembroke, a Masters in Accounting from Kennesaw State University in Georgia, and is a CPA licensed in Georgia
Daniel Kahl
Daniel S. Kahl is the Assistant Director in charge of the Office of Investment Adviser Regulation in the Division of Investment Management at the SEC. The Office of Investment Adviser Regulation is responsible for the development of policy, rulemaking and exemptive matters under the Investment Advisers Act of 1940. Prior to joining the Commission in 2001, Mr. Kahl worked for the Investment Adviser Association, FINRA, and the North American Securities Administrators Association. He received his B.S. from Penn State University, J.D. from Southern Methodist University, and LL.M. (Securities) from Georgetown University.
Nancy Morris
Nancy Morris is Executive Vice President and Chief U.S. Regulatory Counsel of Allianz Global Investors. Prior to joining the firm, Ms. Morris served two tours of duty at the United States Securities and Exchange Commission. In 2006, she became the first woman to be named Secretary of the U.S. Securities and Exchange Commission. Prior to becoming Secretary, Ms. Morris had been an Attorney-Fellow in the Division of Investment Management. During a previous tour of duty with the SEC from 1985 to 1992, Ms. Morris served as an attorney in the Office of General Counsel (1985-1987), Counsel to Commissioner Joseph Grundfest (1987-1988), and Deputy Chief Counsel for the Division of Investment Management (1988-1992). Ms. Morris served more than a decade as Vice President and Associate Legal Counsel to T. Rowe Price Associates, and as an attorney for Fidelity Investments. Ms. Morris began her legal career as an associate for Sutherland, Asbill & Brennan in Washington, DC.
Ms. Morris holds a J.D. from the University of Idaho, College of Law, where she was Editor-in-Chief of the Idaho Law Review. She holds a B.A. (cum laude) from Hartwick College. Ms. Morris is a Member of the District of Columbia Bar.
Lee Augsburger
Lee Augsburger is senior vice president and chief ethics and compliance officer in the Law, Compliance and Business Ethics unit of Prudential Financial, Inc., responsible for overseeing the company’s global compliance organization of more than 400 staff worldwide and the company’s global business ethics efforts.
Mr. Augsburger joined Prudential’s law department in 1997 later becoming the chief legal officer for the annuities business. In 2000 he moved to the compliance department and was appointed global chief compliance officer in 2007 and global chief ethics officer in 2009. He also has served as vice president, compliance, for the company’s Investment Division, where he was responsible for managing compliance programs for the retirement services, institutional brokerage, asset management businesses and mutual funds.
Prior to joining Prudential, Mr. Augsburger was a director in PriceWaterhouse’s Regulatory Consulting Practice, worked with Van Kampen Merrit, served several years with the law firm of Bell, Boyd & Lloyd, and later joined Smith Barney where he was deputy general counsel for its mutual fund organization.
Mr. Augsburger has an undergraduate degree in communications from Wheaton College and a JD from IIT/Chicago Kent College of Law. He is adjunct faculty at New York Law School, developing and teaching Compliance for Global Financial Services Companies for its financial services LLM program.
He is a member of the bar of Illinois and various industry organizations, including the Ethics and Compliance Officer Association and the National Society of Compliance Professionals (for which he also serves as a Board member). Mr. Augsburger also serves on the Board of Advisors for the Institute for Ethical Leadership at Rutgers University, and on the Board of Trustees of Star of Hope Ministries, an inner-city mission organization in Paterson, NJ.
Last Reviewed or Updated: Jan. 27, 2012