Jennifer Aracri
Jennifer Aracri has been a Senior Consultant with National Compliance Services, Inc. (“NCS”) in Delray Beach, Florida since May of 2004.
Ms. Aracri has more than 25 years of regulatory compliance experience. In her role as Senior Consultant with NCS, she has served Broker-Dealers and Registered Investments Advisers in all aspects of regulatory compliance and registrations with FINRA, SEC, and various state jurisdictions. In addition, she provides FOCUS filing and financial reporting services to NCS clients. During the twenty-five years prior to joining NCS, Ms. Aracri has:
Served as First Vice President and Manager of Compliance for Mutual Service Corporation, where she oversaw all aspects of compliance and regulatory issues for over 1,500 Registered Representatives.
Served as Vice President of Asset Management Securities Corp./Barry Financial Group, where she was the Compliance Officer and FINOP for small boutique Broker-Dealer and Registered Investment Adviser.
Served as Vice President of Securities Consultants, Inc., where she provided consulting services to Broker-Dealers and Registered Investment Advisers. She also managed the department that produced financial statements and filed FOCUS Reports for approximately 200 Broker-Dealers on a monthly basis.
Ms. Aracri is a graduate of the University of Maryland and holds FINRA Series 7, 24, and 27 qualifying examinations. She has been invited to participate in numerous speaking engagements over the years at professional industry meetings and seminars on a variety of compliance topics.
John Cadena
John Cadena is the Director of Audit Services for National Compliance Services, Inc. (NCS). Mr. Cadena has been registered and working in the securities industry for 28 years and holds FINRA qualifying exams 7, 9, 10, 24, & 63. Mr. Cadena is a graduate of the University of Missouri at Kansas City and he is a former member of the Kansas City Board of Trade. Prior to joining NCS, he worked as a regulatory paralegal for Raymond James and Associates. Mr. Cadena has also worked for other Broker-Dealers as a compliance supervisor and recruiter and he is the former owner of Cadena Capital Group, Inc., Member FINRA/SIPC, a full-service investment banking Broker-Dealer. In March of 2007, Mr. Cadena received the CAMS designation from the Association of Certified Anti-Money Laundering Specialists.
Since 1999, Mr. Cadena has performed or participated in approximately 250 on-site examinations of financial firms. Broker-Dealer examinations included annual examinations of branch offices, independent 3012 reviews for certification, and AML. Investment Adviser examinations included on-site compliance reviews and new advisor consulting visits.
Erika A. Subieta
Erika A. Subieta has been a Consultant with National Compliance Services, Inc. since April of 2007. She currently assists clients in both the Broker-Dealer Division as well as the Investment Adviser Division.
Prior to joining NCS, Ms. Subieta attended law school and worked for The Henry Law Firm, where she was responsible for research as well as various aspects of the pre-arbitration process for several securities related cases. Prior to attending law school, Ms. Subieta was an operations associate for AIM Investments (currently known as Invesco Aim) in Houston, TX.
Ms. Subieta received her bachelor’s degree in finance from the University of Florida in 2000 and her law degree from South Texas College of Law in 2006. Ms. Subieta also holds the FINRA Series 27 License.
Samuel Luque, Jr.
Samuel Luque, Jr. has over 40 years of securities industry and regulatory experience. In addition to his extensive experience in the private sector, he spent 7 years with the SEC and more than 17 years with the NASD, having retired as the Associate Director of Financial Responsibility/Compliance.
Since retiring from the NASD, Mr. Luque has provided consulting services to a variety of broker-dealers and their legal counsel in connection with financial (net capital and customer protection) and operational issues, margin, clearance and settlement, sales practice compliance, training, registration and regulatory compliance. He has been accepted by the SEC to provide operational and compliance services to a broker-dealer pursuant to an SEC order, and was also chosen as the United States representative on an international project, co-sponsored by the World Bank, to study and report on the capital adequacy of broker-dealers for the Peoples Republic of China.
Mr. Luque has also provided expert witness analysis and testimony with respect to net capital, customer protection, operations, and sales practice issues for broker-dealers and other financial institutions; preparing reports, providing depositions, giving testimony, and providing ongoing technical support to a number of law firms. He is also a qualified General Securities Representative, General Securities Principal, and Financial and Operations Principal.
Robert E. Maina
Robert E. Maina is a Senior Consultant in National Compliance Services’ Broker-Dealer Services Group. He has over 35 years experience in the securities industry during which he served as both a senior regulator and senior compliance officer. He began his career with the NASD and was an Assistant Director in the NASD’s New York City office.
Mr. Maina then entered the private sector, spending twenty-two years with Merrill Lynch during which he held a succession of positions with increasing responsibilities that included managing the Surveillance Unit of the Compliance Department, the U.S. Retail Branch Office Compliance Unit, the U.S. Capital Markets Unit, and the Technology Compliance Unit. In addition to his specific compliance responsibilities, he also provided advice to various business units on the conduct of their business and managed the development of supervisory and management systems used in the compliance department and throughout the firm.
Mr. Maina was also a senior officer with Schwab Soundview Capital Markets, where he coordinated the compliance program across three broker-dealers that engaged in fixed income sales, institutional sales, research, syndicate, and equity market making, and with National Financial Services LLC, where he developed solutions for Operation Services Group Compliance in the areas of surveillance, training, annual certification, and responding to regulatory inquiries. He has the Series 4, 14, 24, 27 and NYSE BOM licenses.
Thomas N. Steenburg
Thomas N. Steenburg through his firm, IM Solutions, from time to time accepts specific engagements to work with or through NCS as a Special Consultant to meet the needs of NCS clients.
Mr. Steenburg has over thirty years’ experience in the mutual fund, hedge fund and securities industry in both executive and legal/regulatory/compliance capacities. He assumed responsibility as Chief Executive Officer for a $7 billion investment manager, Duff & Phelps Investment Management, after an SEC enforcement action, reviving and resuscitating its business. Mr. Steenburg also served as head of the institutional line of business of Phoenix Investment Partners, Ltd., an $80 billion asset management conglomerate listed on the NYSE.
Mr. Steenburg’s primary experience lies in the legal and regulatory world. He served as General Counsel and Chief Compliance Officer for Phoenix Investment Partners, Ltd. and led the firm’s acquisition team through eleven mergers, lift outs and acquisitions. He served as inside counsel to nine fund complexes managing over $30 billion in assets in a diverse array of asset classes. Mr. Steenburg also was President of an affiliated-broker dealer that conducted an institutional trading business and was General Counsel to the affiliated companies’ mutual fund distributor. He also oversaw the integration of operations and systems among the Phoenix affiliates.
Most recently Mr. Steenburg has consulted for various asset managers and broker-dealers, conducting risk analyses, evaluating control systems and structuring policies and procedures for hedge fund advisers and broker-dealers. He has also served as an expert witness in several proceedings, including an engagement on behalf of the SEC.
Mr. Steenburg received his bachelor’s degree in economics from Harvard College and his law degree from the University of Connecticut School of Law. He is admitted to practice in New York and Connecticut and before the U.S. Tax Court. Mr. Steenburg has lectured at professional conferences and is the co-author of Monitoring Hedge Fund Investments: What’s a Good Fiduciary to Do in the Benefits Law Journal.
William M. Hartnett
William M. Hartnett has more than twenty-three years’ experience in the mutual fund, hedge fund and securities industry in a regulatory/compliance capacity. Prior to joining the NCS team, Mr. Hartnett has worked most recently for BISYS and Pricewaterhouse Coopers, LLP, and has consulted for various asset managers and broker-dealers, conducting risk analyses (mock SEC examinations and AML reviews), evaluating control systems and structuring policies and procedures for broker-dealers, hedge fund/investment advisers and investment companies. Within the last three years, he has conducted a FINRA mandated examination identifying errors that caused a firm to refund $1M to clients, thereby minimizing further firm penalties and satisfying all FINRA requirements. He has also made significant contributions in the compliance due diligence review of a major investment adviser and served as an expert witness. Further, he has made contributions to the control objective review documents at both firms.
Mr. Hartnett began his career with the NASD and was an examiner in the NASD’s Chicago office for more than four years. Mr. Hartnett has also spent over fifteen years with the Midwest Regional Office of the SEC in both the broker-dealer/transfer agent and investment management sections. He was recruited for special financial/operational/sales project and training examinations dealing with risk management, trading, co-mingled funds, Code of Conduct/employee trading, variable annuities, soft dollars, penny stocks and 12b-1 fees which involved high level broker-dealers and investment advisers due to his knowledge and sound business judgment. Mr. Hartnett has received his bachelor’s and master’s degrees in finance from DePaul University.
Harvey Wayne
Harvey Wayne became affiliated with the NCS team as an Independent Consultant in 2008. As a Senior Consultant with NCS he is currently involved with new business development and in providing expert testimony involving both broker/dealer and registered representative issues. He has over 45 years of experience in the Securities Industry.
He is a former regulator and experienced compliance professional with Series 4, 7, 14 (NYSE Compliance Official), 24 and 63 Licenses. He is also an Arbitrator/ Member, FINRA Dispute Resolution Board where he has served on numerous panels involving securities related litigation.
Starting with his early background working for the NASD in NYC as a securities examiner he moved on to the NYSE where he worked in the Regulation & Surveillance Department. He was a Senior Investigator and supervised numerous securities investigations involving apparent securities violations at member firms, conducting “on the record hearings” and coordination of findings with regulatory authorities.
Later, Harvey worked for Oppenheimer & Co as Sr. VP Retail Management coordinating compliance and legal issues for their retail branch system. He developed their internal branch review system including registered representative trade surveillance programs, investigated and resolved alleged customer complaints and other internal supervisory issues with brokers that required the advice and consent of senior management and the Legal department. As an adjunct to the Legal department he was often called upon to testify as an expert witness about compliance and supervisory procedures.
In recent years Harvey worked for Janney Montgomery Scott, LLC as their Regional Compliance Officer for the Southeast region.
Darla J Goodrich
Darla Goodrich has over 25+ years in the securities and insurance industry. Darla has been a consultant for 10 of those past years. In that role she has completed mock regulatory exams, conducted branch and satellite audits, completed several compliance and procedures manuals, written numerous compliance newsletters, written and conducted numerous annual compliance meetings, and was the liaison between broker/dealers and regulatory agencies during exams.
Darla has been a President of a start-up broker/dealer. She has successfully completed a Rule 1017 expansion application changing a limited broker/dealer to a fully disclosed broker/dealer. Darla has been a Chief Compliance Officer for three broker/dealers, two registered investment advisors, and one insurance agency.
Darla has a Juris Doctor from Washburn University School of Law, Topeka, Kansas. She is licensed to practice in Kansas and Iowa. Darla has the FINRA Series 4, 7, 24, 27, 53, 55, 63, 65 registrations and life, health, accident, and variable products insurance licenses. Darla has been a FINRA Chairperson and Arbitration Panelist for 10 years. In addition, Darla has been an expert witness in a number of arbitrations for several law firms from Texas.