Penny Borgerding

Penny Borgerding

Penny Borgerding is an Affiliate Expert with Bates Group, as well as being an experienced financial services professional with over 20 years experience specializing in compliance, including drafting, revising, and maintaining company policies and procedures. Ms. Borgerding has significant experience developing and upgrading policy management systems, including shaping the business design and usability needs. She is experienced in financial analysis and accounting and has a proven track record evaluating financial and compliance issues, and taking appropriate action to improve operational performance and develop and implement policies, procedures, and programs that will ensure compliance with existing regulations and best practices.

Before joining Bates Group, Ms. Borgerding was the Vice President and Policy Manager/Specialist for Bank of America-Merrill Lynch. While in this role, she collaborated with business, compliance, risk, and legal representatives to write and revise compliance policies and written supervisory procedures in compliance with SEC, FINRA, MSRB, and AML regulations. Ms. Borgerding maintained the company’s policies and procedures on the policy management system, being accountable for assuring that all new, revised, and retired policies and procedures were properly updated/removed and accessible to the financial advisors and associated employees of the firm.  She managed the timeline and workflow of contract workers and internal supporting project teams to meet urgent regulatory and departmental deadlines.  In addition, Ms. Borgerding contributed significant feedback that shaped the business design, usability needs, functional analysis, and the requirements documentation for developing and upgrading the company’s policy management system.  She provided ongoing feedback to help improve the system’s functionality. She also led the multiple compliance policy and supervisory procedure manual migrations from a paper based document to an electronic format then to a more advanced and robust searchable, reportable, and auditable application tool.   Each migration improved the firm’s ability to effectively update all related content in response to regulatory changes and to ensure policy consistency across lines of business. Along with this, Ms. Borgerding established training plans, training material, and provided instruction to policy management system users; and she developed and established queries, surveillance reports, dashboards, and performed data analysis to identify policy adherence gaps and instituting corrective action. She also researched SEC, FINRA, MSRB, and other regulatory rules to determine their applicability to the firm.

Prior to joining Bank of America-Merrill Lynch, Ms. Borgerding held several positions with USAA and USAA Investment Management Company (IMCO). Starting as a contractor for Registration and Broker Dealer Compliance, then moving into the role of Manager for this department, she managed the broker dealer regulatory compliance functions to include operational compliance, oversight and examination programs; trade execution and reporting compliance; written supervisory procedures; customer complaints; mutual fund state registration efforts (Blue Sky); licensing of registered representatives; and the maintenance of current personnel information in compliance with regulatory record keeping requirements. Ms. Borgerding researched, developed, and implemented written supervisory procedures and internal control systems for a self-clearing brokerage operations environment and conducted periodic review of the supervisory system and updated, as required.



Bank of America - Merrill Lynch Wealth Management, Vice President, Policy Manager/Specialist, 2006-2015


External Reporting and Residual Market Accounting, USAA and USAA Investment Management Company (“IMCO”), Financial and Accounting Analyst, 2005-2006


IMCO/Financial Planning Services, USAA and USAA Investment Management Company (“IMCO”), Financial and Accounting Analyst, 1998-2005


USAA and USAA Investment Management Company (“IMCO”), Manager, Registration and Broker Dealer Compliance, 1996-1998


USAA and USAA Investment Management Company (“IMCO”), Contractor, Registration and Broker Dealer Compliance, July, 1996 - September, 1996


Personal Financial Counseling, Ernst & Young LLP, Manager, 1995-1996


Financial Industry Regulatory Authority (“FINRA”), Special Investigator, 1985-1995


University of Texas at Dallas, MS, Management and Administrative Sciences with an Accounting Concentration, May, 1995


Stephen F. Austin State University, BS, Business Administration, Finance, December, 1984

Professional Qualifications

Certified Public Accountant


FINRA Licenses: General Securities Principal (Series 24); General Securities Representative (Series 7)