William Paul Hodge 109-20 Queens Blvd, Apt 3G, Forest Hills, NY 11375

Cell 917-907-2066 Home 718-263-5333 WHodge@msn.com

Compliance and regulatory professional with over thirty year’s continuous financial services experience.

Fifteen years direct broker dealer compliance oversight experience representing domestic, international, institutional and retail firms.

FINRA/NYSE Securities Licensed: Series; 4, 6, 7, 9, 10, 24, 53, 55, 63, 65, 79, 99 & Notary Public.

PROFESSIONAL EXPERIENCE

Sberbank CIB USA, Inc. New York, NY (formerly Troika Dialog USA, Inc.,) August 2008-present

Senior Compliance / AML Officer – Institutional Brokerage Successfully managed and coordinated FINRA 2014 sales practice exam as interim/acting CCO (Oct. 2013 - Sept. 2014)

Design and implement programs, policies, and practices utilizing tailored checklists to ensure domestic business units and

offshore OSJ branch offices are in compliance with federal, state, and local regulatory requirements.

Implemented SEC rule 15a-6 program for 3 international affiliates, ensuring firm compliance regarding client classification,

distribution of research disclosure language and chaperoning of road shows for US client visits with the firm’s foreign

affiliate staff.

Execute on-boarding of institutional clients, consisting of hedge funds, registered investment advisors and broker dealers

(on/offshore). Request, process and track required documentation necessary to open and maintain accounts while adhering to

the U.S. Patriot Act CIP, KYC, OFAC and internal firm requirements.

Develop compliance and operational processes to support domestic (ADR’s & GDR’s) and international trade executions

(pursuant to Reg. S & 144) as well as firm group level investment banking, syndicate lead, and co-managed deals.

Monitor & advise on all aspects of trading activity, both domestic and international, pre and post trade date fail reports; trade

adjustments, OMS blotters etc.

Redesigned the cross border customer on-boarding system document storage/retention system with 3rd party vendor (Patrina)

and involved/coordinated the decision making processes to remediate over 370 customer accounts

Oversee all AML requirements attributable to Operations & compliance business units. Advised on initial and subsequent

risk limit setting for cash DVP/RVP trades.

Coordinated with Fin-Cen (314-a) the retrieval and making current a year’s “backlog” of unprocessed notifications.

Created firm surveillance manual and review process utilizing - BBG TOMS & SSEOMS reports and other industry tools for

documented compliance, operational, and supervisory reviews.

Collaborate with internal staff and Bloomberg OMS personnel to introduce executed order flow to Pershing LLC and ensure

ACT, TRACE & OATS trade reporting as a straight through processes.

Conduct reviews ensuring the firm is supervising communications between IB and Research as required by FINRA Rule

2711frequent coordination w/ Moscow Compliance for wall crossings on behalf of NY in managing the firm’s global

restricted and watch lists.

Lead project for adding Firm Introducing Broker license with NFA for “SWAPS only” and FX Trading.

Electronic Securities Processing (ESP) LLC, New York, NY (firm acquired by ITG) March 2007-August 2008

Chief Compliance Officer – Institutional Brokerage, and ATS Platform Successfully managed FINRA and NFA audits that overlapped with minor administrative outcomes.

Designed and implemented programs, policies, and practices to ensure that all business units were in compliance with

federal, state, and local regulatory requirements.

Managed reporting requirements and publication for on/off exchange (NASDAQ, NYSE, etc.), and firm system changes

specific to Reg. NMS, Reg. SHO and Rule 605 Disclosure of Order Routing Data via the firm’s website.

Reviewed, developed, and analyzed trade exception reports, affiliated trading issues, and identification of trade errors.

Reviewed our products and systems to ensure compliance with relevant rules and regulations (SEC, FINRA, NYSE, and

NFA).

Coordinated document flow to initiate trading in foreign markets (Europe, Asia) for equities, futures, options, and FX.

Web-CRD Administrator managed forms U4, U5, broker dealer amendments, additions, terminations, state registration

changes, disclosure items, entity name changes, fingerprints, firm element continuing education requirements, etc.

Configured risk management program F-Ten RX for the daily monitoring on both trade and committed capital basis to screen

for breaches in risk levels assigned to accounts.

Reviewed, approved and filed all advertising (via AERF), sales literature, internal/external correspondence, faxes, e-mail,

instant messaging, Bloomberg and Blackberry communications, etc.

Reviewed trading activity, domestic & international fail reports, OATS rejects, cancel re-bills error account activity etc.

Casimir Capital L.P., New York, NY 2005-2007

Chief Compliance Officer – Retail Brokerage, Investment Banking, and Hedge Fund Designed and implemented programs, policies, and practices to ensure that all business units were in compliance with

federal, state, and local regulatory requirements.

Web-Crd Administrator manages forms U4, U5, broker dealer amendments, additions, terminations, state registration

changes, disclosure items, fingerprints, continuing education requirements, etc.

Successfully expanded NASD continuing membership agreement granting business expansion from a “$5K” broker dealer to

“$100K” broker dealer, so that the company could then initiate firm commitment underwriting of initial public offerings

without dollar capitalization restrictions.

Reviewed and approved all advertising, sales literature, internal/external correspondence, faxes, e-mail, instant messaging,

blackberry communications etc.

Responded to more than twenty Rule 8210 information request, handled all customer complaint reporting and resolution, and

when necessary coordinated with legal counsel and external regulatory consultant for the firm’s handling of any issues that

were likely to be escalated to the applicable regulatory bodies.

Reviewed and initialed daily trade blotters, order tickets, best execution reports, OATS rejects, cancel re-bills, error account

activity, etc.

Responsible for the production and updating of written supervisory procedures, restricted list, maintenance of

communications between retail, investment banking and private fund (Chinese walls).

Conducted regular account suitability reviews, including the mailing of activity letters, calls to clients, changes in investment

strategies, AML and CIP requirements, etc.

Banc of America Investment Services, Inc. New York, NY (Quick & Reilly acquired by Fleet Boston, acquired by Banc of America)

2000-2005

Assistant Vice President – Electronic Trading Services

Served as compliance control point to ensure that all outgoing correspondence, policy and procedures for customer requests

were adhered to in accordance with firm risk management and compliance requirements.

Managed daily activities of a team of 12 to 15 associates consisting of Registered Representatives and Customer Service

Agents.

Responsible for supervising Customer Service, Broker Assisted Trading, e-mail, and touch tone trading.

Worked closely with senior management in hiring, training, and associate career development on an ongoing basis via

regularly scheduled coaching, quarterly performance plans and annual evaluations.

Worked with the Director of Call Center Operations and Managers of other key areas on a daily basis to coordinate call or

work volume and ensure maximum staff efficiency.

Identified and provided final resolution of escalated customer inquiries of all types, including trading, service and sales.

Member of committee formed to measure and improve performance management, which resulted in formation of an incentive

program for both associates and management across five investment centers.

Neuberger & Berman Inc. New York, NY

1989-2000

Project Coordinator – Fund Advisory Service 1998-2000

Monthly Retail Fund Advisory Services WRAP platform product line management; responsible for updating 70 fund

templates and other FAS sales materials; applied fund selection criteria to determine buy, hold, or sell status.

Managed outside funds & industry agency relationships including requesting sales and networking agreements, inventory

control of participating fund groups financial reports, performance data, marketing strategies, legal and compliance

requirements, etc.

Premier Services Associate 1994-1998

Primary responsibilities were to provide prospective investors and current clients with a service (ISS) to help allocate their

mutual fund investments in Neuberger & Berman Funds.

Shareholder Services Representative 1991-1993 Processed purchases, exchanges and redemptions and serviced inquiries from shareholders and prospective investors.

Office Services Manager 1989-1991

Responsible for the purchase, billing, and distribution of office supplies as well as managing the daily operations of mailroom

distribution center.

Sanford C. Bernstein & Co. Inc. New York, NY 1983-1989

Brokerage Clerk, Office Services

Hired as mailroom clerk, moved to presentation preparation role for FA’s. Maintained all purchase orders and receipts.

SELECT COMPUTER SKILLS

Full Proficiency with: FINRA CRD, NFA ORS & Win jammer & Major Clearing Broker Systems, Microsoft Office Suite

(including Visio Diagrams), ADP (AOM5), Bloomberg SSEOMS & TOMS, MarketAxess, Dealogic, IPREO, NICE

Recording Systems, Aspect Director, Towers Data, Principia by Morningstar, DST Systems, Telemagic, Surpas, Siebel

Systems, Lucent CentreVu Supervisor, ILX, Streetscape, Reuters, Web CRD, Accentor, Silver Sky Systems, Live Office Net-

Exchange Pro, Oasys & Omgeo systems Patrina Platform, SECCAS and others.

EDUCATION

Business Management A.A.S. Degree, LaGuardia College CUNY-Dean’s List.