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02_Brandon Greenberg_Resume


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  • 1. Greenberg 1 of 6 Brandon Greenberg New York, NY 10011 (646) 470-3408 Email: LinkedIn: BACKGROUND: Regulatory Compliance Consultant with 12+ years of experience advising financial institutions on compliance issues and assisting C-level and senior management with the program and project management of large regulatory change initiatives • #1 Search Result on LinkedIn (globally) when querying: Dodd-Frank, Volcker Rule, and SEF Trading • Expansive and varied Dodd-Frank / Volcker experience, including: Swap Dealer implementation planning at a leading foreign bank, Swap Dealer and Financial End User implementation planning and execution at a Top 3 Global Bank, Volcker Rule implementation planning at a leading foreign bank, Volcker Rule implementation planning and execution at a US money-center bank, two Swap Execution Facility (SEF) implementation planning engagements • Subject Matter Expert in compliance system implementations, specifically those in service of AML Compliance and Trade Surveillance (Actimize, Mantas) • Former Employee of the US Treasury Department, Office of Foreign Assets Control SUBJECT *Dodd-Frank Title VII CERTIFICATIONS / MEMBERSHIPS: MATTER *Volcker Rule *Project Management Professional® (PMP) EXPERTISE: *Swap Execution Facilities (SEFs) *Certified Anti-Money Laundering Specialist® (CAMS) *Swap Dealer Rules *International Institute of Business Analysis *Major Swap Participant Rules *Financial End-User Rules METHODOLOGIES / STANDARDS: *Swap Data Repository Rules *SDLC (WATERFALL) *Market and Trade Surveillance *RUP *Compliance System Implementations *AGILE UP *Post-Implementation Compliance Review *PMBOK *Enterprise-Wide Gap Analyses *SIX SIGMA CLIENTS 8/12 - Present (Contract: TBD) CITIGROUP, INC. New York, NY Program Manager – Dodd-Frank Title VII & Volcker Rule Summary: Tasked with the end-to-end planning and implementation of all Dodd-Frank requirements, policies, procedures, and protocols for one of the largest Corporate Treasury departments in the world. Serving as the primary Dodd-Frank / Volcker Rule point of contact to 50+ traders and managers within Citigroup Corporate Treasury. Directly supporting C-level management on all Dodd-Frank and Volcker Rule matters. RESPONSIBILITIES / DELIVERABLES Major Swap Participant Calculation Participating in the calculation of Citigroup, Inc.’s Uncollateralized Outward Swaps Exposure and Potential Future Swaps Exposure, spanning multiple legal entities Swap Dealer (SD) and Financial End User (FEU) Requirements Definition • In the scenario where Corporate Treasury traders transact in the name of Citibank, NA, a registered Swap Dealer, I defined all requirements where the Swap Dealer implementation work streams did not extend their approach to Corporate Treasury. These included: (1) Identification of Associated Persons within Corporate Treasury (2) Dodd-Frank Part 43 and 46 Reporting of New Swaps (3) Swap Recordkeeping Requirements for a Swap Dealer (Pre-Execution Data, Execution Data, Archiving and Retrieval) (4) Risk Management Program Deployment within Corporate Treasury (5) Mandatory Clearing for a Category 1 Entity • In the scenario where Corporate Treasury traders transact in the name of Citigroup, Inc., a Financial End User, I reflected all applicable rules and developed implementation approaches across the following areas: (1) Dodd-Frank Part 46 Reporting for Historical Swaps (2) Dodd-Frank Part 43 and 46 Reporting for New Swaps (3) Swap Recordkeeping Requirements for an FEU (4) External Business Conduct Documentation (ISDA Protocol 1) (5) Swap Relationship Documentation (ISDA Protocol 2) (6) Mandatory Clearing for a Category 2 Entity
  • 2. Greenberg 2 of 6 Brandon Greenberg New York, NY 10011 (646) 470-3408 Email: LinkedIn: CLIENTS [Continued from previous] ------------------- 3/12 – 8/12 (Contract: 6 Months) STANDARD CHARTERED BANK New York / London / Singapore Program Manager – Dodd-Frank Title VII & Volcker Rule Summary: Advised and assisted senior management in the strategic planning of all Dodd-Frank and Volcker Rule projects, which included defining impacts and opportunities specific to a foreign bank seeking to register as a Swap Dealer as well as operate trading desks and take-on principal positions outside of the US in compliance with the Volcker Rule. Program Execution • Leading and executed all day-to-day activities in service of the foregoing • Organizing stakeholders across various business functions, legal, compliance, and operations both within Citigroup, Inc. and Citibank, NA • Evaluating and revising complex trade flows to conform with Dodd-Frank rules and/or to minimize regulatory touch • Leading ad-hoc discussions on unanticipated critical issues and ensuring a timely and optimal resolution Post-Execution Control Design Developing Citigroup, Inc.’s Management Control Assessment protocol for Dodd- Frank, which is the firm’s uniform approach to evaluating risk management processes and assessing the quality of internal controls Volcker Rule Program Planning • Developing a pro forma Volcker Rule project plan pending issuance of the final Volcker Rule • Working with senior management on new product approvals to ensure that they are well within the bounds of exempted or permitted activities Program Management of Dodd-Frank Title VII Projects Supervised the setup and initial execution of the following workstreams prior to hand-off to BAU staff: (1) Swap Dealer Registration (2) Clearing and SEFs (3) Reporting and SDRs (4) Position Limits and Large Trader Reporting (5) Risk Management Program (6) Recordkeeping (7) External Business Conduct (8) Compliance (Internal Business Conduct) (9) Margin & Collateral (10) Client Documentation (11) Trade Confirmations (12) Portfolio Reconciliation / Portfolio Compression (13) Capital Adequacy Program Management of the Volcker Rule Program Proprietary Trading Assessment and Conformance Planning Developed a methodology to identify activity that may meet the definition of “proprietary trading” and require conformance. Hedge / PE Fund Assessment and Conformance Planning Designed a Covered Funds Assessment Questionnaire and subjected all entities (globally) to it in order to identify Covered Funds, requiring conformance Development of Volcker Rule Compliance Program • Leveraged the firm’s current risk management and MIS reporting capabilities to begin generating the quantitative metrics proposed by the Volcker Rule • Worked with Compliance and Business Heads to begin developing required trading desk procedures by enhancing trader mandates, more precisely defining trader limits and restrictions, and detailing the revenue- generation and hedging strategies of each desk
  • 3. Greenberg 3 of 6 Brandon Greenberg New York, NY 10011 (646) 470-3408 Email: LinkedIn: CLIENTS 3/12 – 8/12 (Contract: 6 Months) INTEGRAL DEVELOPMENT CORPORATION New York / Silicon Valley Program Manager – Dodd-Frank Initiatives / SEF Trading Summary: Worked with C-level management in New York and Silicon Valley at a leading Foreign Exchange trading platform vendor as they sought to make NDFs available for trading and register as a Swap Execution Facility (SEF). ------------------- 3/11 – 3/12 (Contract: 1 Year) TULLETT PREBON New York / London Program Manager – Dodd-Frank Initiatives / SEF Trading Summary: Worked with C-level management in New York and London at one of the world’s largest inter- dealer derivatives brokers as they developed an approach to becoming compliant with Title VII of the Dodd-Frank Act and register as a Swap Execution Facility (SEF). RESPONSIBILITIES / DELIVERABLES Dodd-Frank Analysis for C-level Management • Conducted detailed analysis of all proposed rules of the Dodd-Frank Act and presented a distillation of each rule to C-level management along with an overlay as to the applicability of the rule to the Firm's business Detailed Business Requirements • Developed detail business requirements documentation for both senior management and senior IT staff to enable their development teams to write technical specifications with respect to the following: o Reporting: Reference Data, Real-Time Reporting, Post-Trade Reporting, and Part 16.01 Reporting as well as STP Enhancements o Orders, Trade Execution, and Clearing: Orders Types, Execution Rules, RFQ Considerations, Clearing o Audit Trail o Surveillance Dodd-Frank Analysis for C-level Management • Conducted detailed analysis of all proposed rules of the Dodd-Frank Act and presented a distillation of each rule to C-level management along with an overlay as to the applicability of the rule to the Firm's business • Developed a Master Requirements Matrix for use in the Definition phase of SEF-related projects in order to ensure that all requirements are fully- addressed Setup of All Core Infrastructure and Trading Platform Enhancement Projects • Developed, in consultation with the Global CTO and Regional CIOs, the firm’s approach to the enhancement of Core Technology Infrastructure to support Swap Reporting, Clearing Connectivity and Position Limit Monitoring, as well as the Audit Trail and Archiving Strategy as required by the Dodd-Frank Act • Setup the Project Governance Structure for trading platform enhancements spanning 7 product lines • Created processes and documentation templates to govern the project management of all Dodd-Frank IT Projects • Developed the financial control plan for the entirety of the Dodd-Frank Technology Program Budget (~$30MM) • Presented approach and updates on analysis progress to C-level management Setup of the Firm’s Surveillance Program • Participated in a review of the NFA as an outsourced utility to provide post- trade surveillance of swaps deemed in-scope by the Dodd-Frank Act
  • 4. Greenberg 4 of 6 Brandon Greenberg New York, NY 10011 (646) 470-3408 Email: LinkedIn: CLIENTS 10/10 – 3/11 (Contract: 6 Months) BARCLAYS CAPITAL New York, NY Project Manager – Compliance Summary: Worked with Barclays Capital senior management to define and lead a multi-phase project aimed at enhancing and expanding the use of the Actimize application firm-wide. ------------------- 10/09 – 10/10 (Contract: 1 Year) NEW YORK UNIVERSITY - ABU DHABI New York / Abu Dhabi Project Manager – Compliance Summary: Advised NYU’s senior leadership on OFAC and export compliance issues in advance of the opening of NYU's Abu Dhabi UAE campus in 2010 and led a compliance system implementation to create internal controls, solving for same. ------------------- 4/09 – 10/09 (Contract: 6 Months) MORGAN STANLEY SMITH BARNEY New York, NY Project Manager – Compliance Summary: Performed enterprise-wide Gap Analysis of all compliance reports at the two brokerage firms, as part of the Joint Venture Integration, and provided a proposed Future State and Actimize implementation plan to senior management. RESPONSIBILITIES / DELIVERABLES • Derived an implementation approach from Deloitte analyses outlining the effectiveness of, and recommend improvements to, the AML Surveillance Program at Barclays Capital • Worked with senior-level management in Compliance and IT to define tasks around the tuning and enhancement of existing Actimize models in production. This included tasks such as changes to model thresholds and the acquisition of new data • Worked with senior-level stakeholders and the vendor to define needs around an upgrade of the core Actimize analytics engine (AIS), the Risk Case Manager (RCM), and the purchase of pre-packaged Suspicious Activity Monitoring (SAM) models • Framed issues regarding Customer Risk Scores and bridged gaps between the legacy Lehman approach and the new consolidated Barclays Capital approach • Scoped issues contributing to the success of the project, such as the implementation of a new enterprise-wide data warehouse, ETL configuration and testing, and project cost/resource interdependencies • Engaged stakeholders university-wide to understand Current State business processes across a variety of domains • Clarified regulatory requirements and suggested various approaches to address each • Led a compliance software vendor selection process, including: RFP creation, vendor demonstrations, vendor selection, and contract negotiation • Acted as the sole arbiter between the compliance software vendor and the University and directed all key implementation tasks • Defined and drafted Integration and User Acceptance Test Plans and Scripts and led Testing Kick-Off and Closeout tasks • Documented all new business processes needed to support the compliance system (Export On-Demand™) • Created training documentation and delivered training to senior and mid- level personnel • Compared similar compliance reports in production at both Smith Barney and Morgan Stanley relating to: real-time market surveillance, sales practices compliance, options, annuities, futures and commodities, mutual funds, fixed income, and AML compliance • Compared the effectiveness (yield) of each report at each firm along with the resource requirement (time spent, FTEs) • Provided a recommendation regarding which reports to eliminate, enhance, or research further and provided detailed business requirements for changes to reports being generated in Actimize
  • 5. Greenberg 5 of 6 Brandon Greenberg New York, NY 10011 (646) 470-3408 Email: LinkedIn: CLIENTS 4/08 – 4/09 (Contract: 1 Year) ACTIMIZE (Formerly FORTENT) New York, NY Project Manager – Compliance Summary: Analyzed the performance of an enterprise- level AML and risk management software suite at existing clients and provided recommended changes to senior-level stakeholders geared toward increasing the quality of the system’s output. ------------------- 4/06 – 4/08 (Contract: 2 Years) BANK OF AMERICA New York, NY Project Manager – Compliance Summary: Defined and led a series of projects relating to regulatory reporting, compliance process re- engineering, operational risk, and merger conversion activities. ------------------- 2/05 – 4/06 (Contract: 1+ Year) DEUTSCHE BANK New York, NY Project Manager / Sr. BA –Compliance Summary: Participated in a review of the firm’s highest risk correspondent banking clients in response to a government Cease & Desist Order and MOU. Input of risk scores into Mantas. RESPONSIBILITIES / DELIVERABLES • Created database schema to house a sample of several million transactions across commercial, consumer, and credit card business lines • Imported data into a statistical modeling tool to create a graphical representation of the transactional behavior of each peer group (grouping of “like accounts”) • Analyzed account-level reference data within each peer group where transaction activity did not fall within a normal distribution in an attempt to see if said peer groups could be further separated on the basis of other account characteristics • Recommended adjustments to peer group construction based on the above and provided bank compliance staff with training to repeat the exercise themselves on an ongoing basis Conversion of Investment Management Accounts • Developed a process to manually convert 5,000+ special class investment management accounts that were at risk of being subjected to erroneous asset sales • Managed (15) contractors in NY and Boston • Oversaw more than $2B of manual asset transfers between accounts, resulting in less than a .3% error rate Investment Management Ops Consolidation • Member of a team of Project Managers tasked with integrating the US Trust account base into the Bank of America environment • Delivered a Proposed Future State to senior management OCC / FDIC Regulatory Reporting Project • Managed the completion of the OCC Risk Summary Form and the collection of data from various internal sources in order to complete the Call Report SOX 404 Data Warehouse Remediation • Developed a methodology to identify invalid code combinations in US Trust’s data warehouse • Designed, managed testing for, and implemented a suited of automated SQL queries to run against US Trust’s Data Warehouse • Management UAT Testing for new system controls • Defined impacts to Federal Reserve AUM reports • Applied the CAMBRS risk assessment framework to all correspondent banking clients with a focus on Russia, Sub-Saharan Africa, and Eastern Europe • Provided expert guidance on relevant compliance issues and facilitated a weekly meeting between field reps throughout the world and senior management
  • 6. Greenberg 6 of 6 Brandon Greenberg New York, NY 10011 (646) 470-3408 Email: LinkedIn: CLIENTS 7/03 – 1/05 (Contract: 1.5 Years) DRESDNER KLEINWORT New York, NY Sr. BA – AML Compliance Summary: Provided subject matter expertise in the rollout and enhancement of the Actimize platform for AML compliance. ------------------- 7/02 – 7/03 (Contract: 1 Year) UBS INVESTMENT BANK New York, NY Sr. BA – Compliance Summary: Participated in the KYC/CIP remediation and due diligence of Prime Brokerage accounts, using Actimize. ------------------- 1/00 – 7/02 (Employee: 2.5 Years) US TREASURY DEPARTMENT, OFAC Washington, DC Compliance Investigations Analyst Summary: Staff member of the OFAC Compliance Programs Division. Acted as the first point-of-contact to banks seeking guidance and initiated investigative inquiries into suspicious transactions. Top Secret Security Clearance (Inactive). RESPONSIBILITIES / DELIVERABLES • Worked with the Director of AML Compliance in defining business requirements for the Actimize platform • Worked directly with compliance staff members to enhance compliance models and increase the value of system output • Used Actimize to conduct a remediation of UBS’s prime brokerage clientele (where Actimize served as the KYC/CIP tracking tool) • Identified and explicated hedge fund structures • Risk-rated prime brokerage clientele according to various metrics • Interpreted SWIFT messages, wire transfers, letters of credit, and other financial instruments to assess their compliance with U.S. sanctions policy • Initiated investigative inquiries into transactions deemed likely to have violated U.S. Sanctions Policy • TS Collateral Security Clearance EDUCATION: George Washington University Washington, DC *B.S., Economics *Magna cum Laude *Coursework toward M.A., Economics