Michael Kelly Email & Phone Number

New York, New York, United States

New Jersey, United States

•Conduct annual compliance testing activities for various Prudential broker-dealer business units, separate accounts and an investment adviser •Develop test plans for each review by utilizing a risk based approach to identify key compliance and regulatory risks within each business•Work with CCO’s, supervision and compliance to identify testing focus and business unit coordination•Assess and evaluate the effectiveness of policies, procedures, processes and controls designed to comply with applicable regulations and internal standards through interviews, documentation reviews and forensic testing activities•Utilize various testing strategies to detect processes or procedures where unnecessary regulatory risk or weakened controls exist•Evaluate results of testing and identify potential regulatory issues, procedural gaps and/or process improvements •Create written reports summarizing the testing conducted and detailing issues, observations and recommendations •Effectively communicate testing results to senior business management and assist in the creation and remediation of findings reported•Manage multiple examinations concurrently while meeting agreed upon timelines •Maintain inventory of ongoing monitoring and testing conducted across Prudential businesses to identify testing overlaps, gaps and common issues/trends •Assist in the coordination and oversight of annual testing conducted by an outside consultant on behalf of multiple IAs, a transfer agent and a separate account complex •Liaison between outside consultants and each regulated business by facilitating interviews and providing oversight of testing activities and results•Manage project resources, timelines and deliverables to ensure testing is completed effectively and efficiently across all businesses •Managed RFP creation, distribution and response analysis to identify vendor(s) to conduct required annual testing for numerous regulated Prudential businesses

General Consulting•Provided advice on regulatory & operational matters to large brokerage firms, insurance companies, insurance affiliated broker-dealers, independent broker-dealers & investment management companies•Managed consulting projects concerning securities, insurance & corresponding compliance matters. Responsibilities included: drafting engagement letters, serving as project manager & anticipating, identifying & resolving engagement issues•Developed work plans, provided leadership/direction to members of the project team & ensured that all project commitments were met and that client expectations were exceeded•Cultivated client relationships by working directly with Sr. management of client firms•Managed multiple projects & responsibilities in the face of competing prioritiesClient Consulting Activities•Managed insurance & broker-dealer regulatory compliance assessments •Assisted firms in:-identifying gaps between current policies & procedures, regulatory expectations & leading industry practices-developing frameworks to identify & prioritize risks, including creating meaningful executive level compliance reporting dashboards used to communicate risks•Worked with CCOs, COOs & other Sr. compliance professionals to address, mitigate & resolve regulatory gaps & enhance current compliance and operating processes•Developed & implemented practicable recommendations for addressing gaps & identifying risk management enhancement opportunities•Worked with firms to implement policy decisions & create strategic initiatives•Assisted broker-dealers in:-responding to FINRA / SEC requests-drafting written supervisory procedures & compliance procedures to ensure compliance with applicable FINRA / SEC rules & regulations-creating suitability guidelines for general securities, mutual funds & variable products-FINRA 3012/3130 CEO Certification Testing and Reporting•Created, implemented & conducted training programs for broker-dealers

Market Surveillance•Investigated securities and insurance related sales practice issues •Created and implemented policies and procedures to comply with changing regulatory requirements•Assisted in the creation and implementation of suitability guidelines•Assisted in the development of various exception reports to assist the firm in identifying suitability concerns and suspicious activity•Monitored sales practice suitability•Reviewed securities activities of RRs for questionable sales practices (product suitability, mutual fund B & C share purchases, 1035 exchange/replacement activity, switching and churning)•Responsible for conducting over 60 special investigations and prepared reports of findings and corrective actions to be taken•Coordinated with branch supervision to implement disciplinary actions resulting from surveillance activities•Monitored and investigated mutual fund market timing issues •Conducted compliance examinations of branch offices•Responsible for the enhancement of the companies insider trading program and the implementation of an improved monitoring system •Monitored employee brokerage accounts for potential insider trading issuesRegulatory Reporting•Responsible for responding to FINRA and SEC regulatory inquiries •Coordinated with internal departments, branch managers and RRs to update firm regulatory filings and registered representative U-4 and U-5 filings•Assessed customer complaints received and worked with branch managers and RRs to update U-4 and U-5 filings timely and accuratelySpecial Projects•Conducted review of Long Term Care branch to ensure compliance with applicable regulations and company guidelines•Responsible for 38a-1 annual review of policies and procedures and recordkeeping requirements •Responsible for gathering and reporting of documentation for IMSA certification•Assisted in the development of an internal compliance “profile” system for use at over 150 branch locations

Facilitated client requests for securities transactions and account changesResolved time-sensitive client disputes regarding securities and account issuesCommunicated with back office and sales desks regarding securities orders and account transfersAdvised senior management in formulating policies and procedures regarding workflow and system improvementsConducted training presentations for senior management and registered representativesDeveloped training manuals and procedures for registered representative trainingTrained new registered representatives on policies and proceduresTrained managers, registered representatives and employees on new back and front office order-entry systems

Generated new client accounts through outbound calling, seminars and referralsHandled client inquiries and trade disputes in a timely manner