compliance isk concepts
Outsourced Support, In-House Expertise
Mastering Compliance in an Evolving Financial World
Although financial market regulations are designed to keep our capital markets safe and secure, the regulatory environment is expansive, blanketed with land mines and becoming more complex each year.
“Peace of Mind...
That’s the feeling I get when I work with the team at CRC. And peace of mind is priceless in this increasingly complex world of compliance. CRC is so thorough in its analysis of problems and opportunities, and the work they do is so professionally sound and accurate, that it leaves me the time to focus on other areas of my business that will positively benefit the bottom line. For over decade, I have worked with the CRC team, and put my own clients in their care. I highly recommend their services
Derek Bruton, Senior Managing Director, Gladstone Group
While meaningful, trustworthy compliance guidance is more important than ever, financial services organizations continue to struggle with the ever-rising costs of attracting and retaining a skilled internal compliance department at a reasonable cost.
So, how do you access world-class regulatory advice without breaking your budget?
CRC Bridges the Gap
We bridge the gap between accessing world-class regulatory advice and managing your budget. We bring deep capital markets expertise to the table, along with experience building compliance programs for broker-dealers and asset management organizations.
CRC is a compliance professional services company that meets you where you are, with advisors who have spent large portions of their careers in-house and who furnish pragmatic, actionable advice - at a price point that won’t break your budget.
Our Mission
Enabling your business to achieve long-term, sustainable, and scalable success is our business
“I can’t say enough great things about our experience with CRC. We’re a consumer technology team who came to them with zero broker-dealer experience. Over the course of the next year they not only expertly navigated the FINRA NMA process but also helped us build our broker-dealer from the ground up while simultaneously giving our team a crash course in operating a broker-dealer. Today, as we’ve moved from the application process to operations, we continue to rely on CRC’s experience and expertise on a daily basis.”
Ben Gildin, General Counsel, Upside Marketplace, LLC
CRC Service Delivery Model
CRC’s solutions are designed to assist you with achieving your financial, operational, and strategic goals by:
• handling ongoing, routine compliance matters at a fraction of the cost of traditional resources;
• translating regulatory noise into coherent guidance to achieve competitive business advantage;
• balancing your commercial interests with the critical need to withstand regulatory scrutiny; and
• functioning as an extension of your in-house team to drive better results.
Put simply, we handle risks, so you reap rewards
“The CRC team have been instrumental in helping us navigate the regulatory universe. They’ve been patient, responsive and true partners in problem solving. As a startup, CRC has helped us approach registration economically, and with the right sequencing for our evolving platform.”
Craig Hine, Head of Capital Markets, Juniper Square
Does Our Approach Work?
WE LET OUR NUMBER SPEAK FOR THEMSELVES: INTERNAL TEAM GROWTH
50%+ 80%+ 75%
500+ CLIENTS
GROWTH IN NO. OF CLIENTS OVER OVER OF OUR IN 4 YEARS IN PREVIOUS 4 YEARS
PROUDLY SERVED SINCE INCEPTION
CLIENTS ENGAGE US FOR OUTSOURCED COMPLIANCE AND C-SUITE DESIGNATION SERVICES
Serving the Needs of Small & Large Companies
Whether yours is a startup or enterprise-level organization, trust our experts to help you build, maintain, and scale the right risk management program.
Offerings Tailored to the Size of Your Company
For small companies that operate modest in-house compliance support groups or have appointed a front office producer to serve as CCO, CRC handles ongoing, routine compliance matters at a fraction of the cost of traditional resources.
For larger companies that employ a CCO, General Counsel or more robust in-house staff, we serve in an overflow capacity, acting as an extension of the in-house team.
For all our clients, CRC works to ensure your compliance program is properly functioning, manage spikes in workload or address under-served areas of your business.
“We would not have been where we are today without the partnership and personal friendship CRC has generously provided us over the years. Their support, expertise, and care for who we are personally and professionally has helped define our service model to our own clients. CRC has been an integral extension of our firm from our initial vision to launch to where we are today. Congratulations on 10 years! We can’t thank you enough.”
Don O’Hara, Chief Executive Officer / Chief Compliance Officer, PennHaven Brokerage Partners, LLC
Verticals We Serve:
Financial Marketplace
• Broker Dealer Compliance Services
• SEC and State Registered Investment Adviser
Support National Futures Association (NFA)
• Compliance Support
• Enterprise Risk Management
• Enterprise Compliance Support
• Financial and Operations Principal (FinOp) Services
• Block chain Assets/Cryptocurrency Consulting
• Research Supervisory Analyst (SA) Services
• Designated Supervisory Principal (SP) Services
• Outsourced Chief Compliance Officer (CCO) Services
• Independent Due Diligence Services
• Money Services Business Compliance Support
• Money Transmitter License Filing Services
• Expert Witness Services
While our roots are grounded in broker-dealer and investment adviser compliance support, we continue to expand our offerings to meet the evolving needs of our clients and industry.
Broker-Dealer General Compliance Support
• SEC, FINRA and SRO Registrations
• Supervisory Controls Testing (Rules 3120) and CEO
Annual Certification (Rule 3130)
• AML Training and Reviews
• Regulatory Corrective Action
• Ongoing Compliance Support (AML, Email Reviews, Sales/Trading Surveillance)
• Training & Annual Compliance Meetings
• Compliance and Supervisory Policy and Procedure Development and Implementation
• Advertising/Sales Literature Review
Capital Market and Investment
Banking Compliance
• Trading and Sales
• Equity and Convertible Origination and Syndicate
• Public Finance/Organization/Underwriting
• Section 15(g) of the Exchange Act - Information Barriers
• Investment Grade Debt
• High-Yield Debt Re-marketing /Auctions
• Tender Option Bond Program
• Derivatives
Investment Adviser Support
• Mock Regulatory Exams
• Advertising and Marketing Reviews
• Access Person/Personal Account Trading Reviews
• SEC and State Registration
• Form ADV Parts 1,. 2A and 2B
• Form PF
• Annual Compliance Reviews – Rule 206(4)-7 of the Investment Advisers Act of 1940
• Code of Ethics
• Drafting/Revisions of Policies and Procedures
Enterprise Compliance Support
• Governance and Risk Compliance (GRC)
• Technology Identifying and Implementation
• Regulatory Intelligence and Associated Workflows
• Policy and Procedure Mapping
• Compliance Risk Assessment Development and Deployment
• Issue Management and Escalation
FinTech/Technology Support Services
Our team possesses the necessary skills, experience and credibility to help technology companies understand their users. We partner with technology companies to create a strategic approach and roadmap that enables our clients to succeed:
• Compliance Knowledge Transfer
• Landscape Analytics: Industry Needs Versus Current Solution Sets
• Independent Industry Surveys / White Papers
• Customer Preparatory Meetings / Dry Runs
• Retained Expert Guidance and Advice
“Collaborating with the CRC Team is not just a pleasure; it’s like having a trusted compliance partner by your side. Their expertise and seamless cooperation ensure a consistently positive working relationship with both MCO and our valued clients.”
Jeff Childs, Director of SMB Sales, MCO
Financial Institutions
• Banks & Bank Holding Companies
• Credit Unions
• Governance, Risk and Compliance (GRC)
• Regulatory Support, Due Diligence and Gap Analysis
• Expertise in Identifying, Assessing and Managing Risks
• Third Party Vendor Due Diligence
• Wealth Management Consultancy
Enterprise Risk Management
• Governance, Risk and Compliance (GRC)
• Banks & Bank Holding Companies
• Credit Unions
• FinTech Companies
• Regulatory Support, Due Diligence and Gap Analysis
• Three Lines of Defense Approach
• Expertise in Identifying, Assessing and Managing Risks
“Arta Finance has been working with CRC since before we named our company! CRC guided us through the RIA application process and has been an integral part of our team at all levels of the company. Their focus on building a healthy compliance environment at Arta and their keen knowledge of the regulatory landscape have been immensely helpful as Arta has grown. The team at CRC have been true partners from day one.”
Dave Shapiro, Co-Founder, Arta Finance
About Compliance Risk Concepts
CRC is a business-focused team of senior compliance executives and practitioners who offer top-tier compliance services to clients on an ongoing, as-needed project, or part-time basis. We provide our clients with the critical skills and expertise required to establish, maintain, and enhance a balanced and effective compliance operational risk management program. We offer outsourced support and in-house expertise to help organizations demonstrate a commitment to a strong risk management culture.
As career industry compliance risk management professionals, we understand the complexity of today’s regulatory environment and the heightened expectations and demands on executive leadership. In this new paradigm, organizations must contemplate how they will make the best use of resources to do more with less. CRC brings a unique tailored approach to help our clients succeed in today’s challenging regulatory and economic environment, enabling and empowering our clients to manage the cost of compliance without sacrificing the necessary infrastructure and control environment.
CRC: Outsourced Support, In-House Expertise.
“Working with CRC has been a great experience. Their professionalism, commitment, and reliability have made this partnership genuinely outstanding. We really appreciate their hard work in helping us achieve our goals.”
Leticia Gatto, Risk Management and Governance, Nomad
Executive Leadership
Comprised of seasoned former in-house chief compliance officers. CRC’s experts have deep front-office capital market roots.
Mitch Avnet Founder and CEO
mavnet@compliance-risk.com
Mitch Avnet is responsible for business development, relationship management, and overseeing the execution of all client-driven/ businessfocused compliance and ethics risk management strategic engagements.
Prior to launching CRC. Mitch was a member of the corporate leadership group CLG at Lincoln Financial Group (LFG), where he was senior vice president and chief ethics and compliance officer with direct oversight of the company’s anti-money laundering, privacy, ethics and compliance risk management programs.
Mitch maintained responsibility for Lincoln’s entire compliance and ethics technology strategic initiatives, developing an impending long-term strategic approach to upgrade and modernize the effectiveness and efficiency of Lincoln’s overall compliance programs. Mitch was a member of the social media governance committee and has a direct influence regarding LFG’s overall strategy toward the enablement and usage of social media outlets across the LFG footprint.
Throughout the course of his career in the financial services industry, Mitch has worked for top-tier investment banks, commercial banks, and hedge funds, such as Wachovia Capital Markets, PNC Bank and D.E. Shaw, developing an extensive knowledge of both buy side and sell-side businesses with a deep understanding of Equity and Fixed Income Market Structured Products and Variable Products.
Over the past several years, Mitch has built Compliance Risk Management programs to support the manufacturing/ organization and distribution of proprietary products (closed architecture) and source, third-party products on behalf of customer/client relationships (open architecture). During his time frame. Mitch served in leadership roles, building and integrating Compliance teams to be a meaningful and sought-after component of the business process.
Mitch maintains series 3, 4, 7, 9, 10, 14, 24, 55. 63 and 65 securities license designations. He obtained his bachelor’s degree in economics, graduating magna cum Laude from the State University of New York at Oneonta.
CRC’s Leadership Team
David J. Amster
Managing Principal
damster@compliance-risk.com
David Amster is responsible for CRC’s business development and client relationship management and for supervising the execution of strategic engagements.
David joined CRC in September 2016 from CRT Capital Group LLC, where he served for more than 15 years as Managing Director and Chief Compliance Officer. CRT operated as an institutional brokerage, market-maker and investment bank that specialized in high-yield and convertible corporate debt, equities, special situations, capital structure arbitrage, securitized products, U.S. Government securities, debt and equity financings and securities research. As CCO, David managed comprehensive global regulatory compliance programs for CRT’s U.S. broker-dealer unit and its FCA-registered UK affiliate, CRT Capital (UK) Ltd. and served as a member of CRT’s Enterprise Risk Committee, Policy Committee, New Product Committee and Capital Commitment Committee. David also served as Managing Director and Chief Compliance Officer of Harbor Drive Asset Management LLC, CRT’s SEC-registered alternative asset advisory affiliate. HDAM managed Harbor Drive Fund, a special situations-centric hedge fund, Pine Street Institutional Partners LP, a fund of hedge funds, and a variance swap strategy designed for separately managed accounts.
David’s Wall Street career began at Salomon Brothers, Inc., the free-wheeling broker-dealer of Liar’s Poker fame. As the Syndicate Desk Coordinator for Salomon’s Private Investment Department, David first learned the business from the sales and trading perspective and was immersed in the results-oriented culture of a high-energy trading floor. David then headed to FINRA where, as a Field Examiner, he led comprehensive on-site reviews of the books, records and operations of bulge bracket dealers. After FINRA, David joined UBS Investment Bank, LLC as an Associate Director in its Fixed Income Capital Markets Compliance division with primary responsibility for supporting the firm’s Primary Dealership, Rates and Repo Desks.
David earned his BA in Economics from Binghamton University and his MBA in Finance from Fordham University’s Gabelli School of Business.
“The entire CRC team are a huge asset to me and our business. They are always available when something comes up and are equipped with a deep understanding of the laws and regulations. They are always ready to discuss business strategy and planning so we can avoid potential pitfalls. I look forward to working with them for the next 10 years!’’
Joseph Reigadas, Chief Compliance Officer, Leste
CRC’s Leadership Team
Roland Reyes
rreyes@compliance-risk.com
Roland Reyes is responsible for the business development and execution of CRC’s compliance engagements. Most recently, he was Director at Wells Fargo Securities, LLC’s Compliance Department. He was responsible for overseeing the Equity Derivatives compliance program covering Structured Products, Corporate and Equity Derivatives, Convertible Securities, and Equity Finance sales and trading desks.
Roland has extensive experience in regulatory, compliance and compliance technology matters in the equity derivatives, structured products and convertible securities space. Roland has 7, 63, 4, 24, 55, 3, 8 securities licenses. Roland graduated with a B.A. in Economics from Hunter College, CUNY.
Prior to Wells Fargo, Roland was at Bear Stearns covering its Equity Derivatives Sales and Trading Desks and JP Morgan’s Compliance Surveillance unit covering its listed options activity. Prior to JP Morgan, Roland worked at Salomon Smith Barney’s Retail Compliance Department helping in the coverage of the company’s large retail options business.
Jaclyn Bowdren Managing Principal
Managing Principal
jbowdren@compliance-risk.com
Jaclyn Bowdren, Managing Principal at Compliance-Risk Concepts (CRC), serves as the company’s Chief Operating Officer and is responsible for executing the company’s strategic business plans.
In addition to her role as COO, Jaclyn is an accomplished compliance professional with two decades of regulatory and operational experience on both the broker dealer and investment advisory sides of the business. Since her arrival eight years ago, CRC has relied on Jaclyn’s deep expertise; playing a key role in the direction, growth, and operationalization of the firm, while also working directly with clients and managing project teams across various verticals. Prior to CRC, Jaclyn served as Chief Compliance Officer for Tripleshot, LLC, a broker-dealer operating an Alternative Trading System, and shepherded the firm through its FINRA new membership application process and the development and deployment of its compliance program. Accordingly, Jaclyn has extensive knowledge of the regulatory concerns in connection with electronic trading and possesses significant insight involving the intersection of technology and compliance. Prior to Tripleshot, Jaclyn served in various roles for Aritas Securities, LLC, culminating with her promotion to Chief Compliance Officer.
Jaclyn earned her Bachelor of Arts in Psychology from the University of Massachusetts, Amherst. She holds Series 7, 24, 63 and 99 securities licenses.
CRC’s Leadership Team
Debbie Nathanson People and Culture Advisor
dnathanson@compliance-risk.com
With over 20 years of HR experience across multiple industries, Debbie is an accomplished executive coach, skilled facilitator, trusted strategic business partner, and leadership/talent advisor. She has spent her career leading teams as SVP, HR Business Partner at Fortune 500 companies in various industries including Financial Services, Energy, and Fashion (retail and manufacturing).
With a proven track record for delivery of both large-scale strategic people initiatives and smaller tactical projects, some of Debbie’s accomplishments include revamping on-boarding practices, facilitating project launches, strategic off-sites and talent reviews, crafting performance management practices, and educating managers and staff on topics including flexible work, goal setting and interviewing skills, as well as Diversity Equity Inclusion and Belonging (DEIB) and Unconscious Bias. She is passionate about helping leaders and teams find their unique voice, leverage strengths, shape their culture, and ultimately reach their full potential.
Debbie holds a BA in Urban Studies from Lehigh University and an Executive Coaching certification from iCoach at Baruch College, Zicklin School of Business.
“I have worked with the CRC team on numerous projects over the last 5 years. Across the board the team is incredibly knowledgeable and commercial in their approach. I am also consistently amazed at the wide range of knowledge and areas that they cover within the broker-dealer, RIA, and financial services sector as a whole. CRC is the first place I call when I have an issue. Congratulations on 10 years!”
Alan Arkin, Principal, OfÏt|Kurman
CRC’s Leadership Team
Michael Durette
mdurette@compliance-risk.com
Michael Durette is the Chief Revenue Officer for Compliance Risk Concepts. In this role, Michael is responsible for the company’s revenue-generation strategy and execution as well as the company’s go-to-market approach.
Prior to his role at Compliance Risk Concepts, Michael was a Principal, Chief Compliance Officer and Investment Committee Member of Nest Egg, a fintech company and digital advice platform designed specifically for Financial Institutions. During his time at Nest Egg, Michael helped oversee and execute the integration of the company with their Regional and Community Bank partners in addition to being the Chief Compliance Officer for the company’s Investment Adviser and Broker-Dealer. In addition to his role at Nest Egg, Michael spent the last 12 years as a Portfolio Manager and Investment Committee member of Addison Capital, a boutique Investment Adviser. In this role, Mr. Durette was the Head of Institutional Partnerships and managed Addison Capital’s Regional and Community Bank clients, as their outsourced Chief Investment Officer. Michael previously worked at Fisher Investments and began his career in financial services at Citigroup, Smith Barney.
Michael maintains the Series 6, 24, 51, 62, 63, 65 and 99 securities license designation. He obtained his bachelor’s degree in history from the University of Maryland, College Park.
Kaitlyn Wulfken Director, Chief Revenue Officer Director, Regulatory Research Support Services and Client Advisory
kwulfken@compliance-risk.com
Kaitlyn joined CRC in 2017. She is a regulatory compliance professional with 7 years of experience in the financial services industry. Kaitlyn has extensive knowledge of the rules of the Investment Company Act of 1940 and the Investment Advisers Act of 1940. She previously managed compliance processes and performed forensic testing in her role as Compliance Analyst at Welch & Forbes LLC.
She has experience performing annual reviews and risk analyses, regulatory research, as well as Code of Ethics administration. Her primary focus areas include, process implementation and enhancement, cybersecurity, marketing materials review, private equity investment compliance, and investment portfolio compliance. Most recently at CRC, Kaitlyn has performed regulatory research, evaluated compliance programs, and performed annual reviews and risk assessments for investment advisors.
Kaitlyn holds a Bachelor’s Degree in English from Boston University.
CRC’s Leadership Team
Jonathan Telfair
Lilian Colpas Director, Broker-Dealer Support Services and Client Advisory
jtelfair@compliance-risk.com
Prior to joining CRC in 2022, Jonathan spent more than a decade as a securities attorney and regulator, first serving a New York City-based law firm where he supervised 10 attorneys preparing complex mortgage-backed securities “put-back” litigation. Jonathan then moved to FINRA where he spent six years as an examiner in FINRA’s cycle exam program, conducting exams of broker-dealers across industry verticals before being elevated to serve as an Application Manager in FINRA’s Membership Application Program (“MAP”) group, overseeing a team of examiners reviewing New and Continuing Membership Applications, Materiality Consultations, Two Principal Waiver requests, and Membership Agreement Change requests.
Jonathan earned a Bachelor of Arts degree in Philosophy from Siena College, and his Juris Doctor from Pace University’s Elisabeth Haub School of Law.
Director, Investment Adviser Support Services and Client Advisory
lcolpas@compliance-risk.com
Lilian Colpas is Director, Head of Investment Advisory Support specializing in broad investment advisory compliance matters. Lilian’s background in legal and compliance spans over 19 years. Lilian focuses on assisting her clients in managing their compliance programs and advises on matters related to ongoing regulatory compliance including the review and revisions of policies and procedures, Code of Ethics review and testing, investment adviser registration, compliance calendar maintenance, marketing assistance, SEC examinations, regulatory filings, forensic testing, best execution reviews, gap analysis, 206(4)7 annual reviews, outsourced CCO. Lilian leads a team of compliance professionals who advise clients on ongoing regulatory compliance matters.
Lilian’s career includes compliance management roles at investment advisory firms including Davidson Kempner Capital Management, as well as experience as a paralegal at AIG and Sidley Austin. Lilian is a United States Navy veteran who served one tour of duty in Baghdad, Iraq, and was responsible for the analysis and dissemination of intelligence information. Lilian earned her Bachelor of Arts Degree from DeSales University, her paralegal certificate from Fairleigh Dickinson University and is pursuing her Master’s Degree from Seton Hall University.
Jeff Press Director, Regulatory Compliance and Client Advisory
jpress@compliance-risk.com
As a Senior Regulatory Compliance Professional, Jeff brings to CRC more than 25 years of deep and varied expertise in Compliance, Risk and Operations programs. With expert knowledge of the practical application of financial services regulatory implementation and best practices, Jeff formulates and executes a strategic vision toward effectively demonstrating proper controls s while helping to support commercial interests and protect the enterprise from legal and regulatory risk. Jeff has broad industry experience in Operations, Risk, Compliance, Exams/ Audit, and Governance from his time as a former CCO of large and small BDs and RIAs, including participation in the forensic compliance analysis of two high profile RIAs under SEC receivership.
“CRC has been an instrumental part of our firm’s stability and growth. As a fintech brokerage, our needs were constantly shifting and evolving. And CRC has been an incredible partner by providing specialized personnel, regulatory guidance, and strategic advisement as those needs arose. By providing ongoing, flexible resources for both short term and long term needs, CRC was able to help us reduce our headcount and overhead, while also covering all of our regulatory and license requirements.”
Victor Wang, Chief Executive Officer, Stockpile, Inc.
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