Richard J. Paley

Richard J. Paley

Richard J. Paley is a Bates Group Expert and Compliance Consultant. He is an experienced leader of legal, compliance, risk and regulatory programs for Banks, BDCs, ETFs, Hedge Funds, Institutional & Retail Broker-Dealers, Investment Advisers & Companies, Public Companies and REITs. He has a proven track record of providing effective advice, enhancing internal controls and managing regulatory relationships and firm examinations.  He has served as a General Counsel, Chief Compliance Officer, Chief Risk Officer and Executive Director of Regulatory Change and Policies & Procedures.

Prior to joining Bates, Mr. Paley had a successful career in executive roles at U.S. regulators (U.S. Securities and Exchange Commission and Depository Trust and Clearing Corp.) and global financial services firms (JPMorgan Chase, Fidelity Investments, Daiwa Securities and W.P. Carey). He has counseled firms on the regulations of the CFPB, CFTC, FDIC, FINRA, FRB, MSRB, NFA, NYSE, OCC and SEC.

Mr. Paley’s experience in legal, governance and regulatory policy includes being selected to lead key corporate governance initiatives and innovative risk programs, as well as the drafting of Corporate and Regulatory filings, Comment Letters, Sales and Advertisement Reviews, Contracts and Non-Disclosure Agreements. Mr. Paley has served as Corporate Secretary to Boards of Directors of both public and fund companies.

Mr. Paley is a turnaround specialist, building and re-engineering compliance and Enterprise Risk Management programs throughout his career. He has experience as a sole contributor and led large, 15+ member teams in numerous subject matter areas, including the Management of Policies, Written Supervisory Procedures, Regulatory Change, Operations, Codes of Ethics, CRD, Sales, Trading and Training.

Mr. Paley’s risk management and controls experience includes partnering with senior executives to create strategic methodologies to ensure legal, regulatory and operational exposures are managed, monitored, audited and documented. He has designed and conducted ERM Assessments plus Monitoring and Testing programs.


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Richard J. Paley

A Consultant and subject matter expert in these services:

  • Securities and Financial Services Litigation & Consulting
    • Retail
      • Securities and Financial Services Litigation & Consulting
      • Alternative Investments
      • Banking
      • Branch Management
      • Broker Dealer (B-D)
      • Broker Obligations
      • Clearing
      • Corporate Governance
      • Complex Products
      • Eligible Employee 
      • Employment Practices Liability
      • Equities
      • Elder Issues
      • Employment
      • Equity Research
      • Fiduciary Duties/Responsibilities
      • Fiduciary Investments
      • Financial Institution Sales
      • Financial Analyst Responsibilities
      • Former Regulators
      • Fraud
      • Insider Trading
      • Information Management
      • Introducing Firm/Clearing Firm Relationship
      • Investment Advisory
      • Investment Management
      • Limited Partnerships
      • Legal
      • Mutual Funds
      • Non-Publicly Traded Alternative Investments
      • Operations
      • Operations & Controls
      • Outside Business Activity
      • Real Estate Investment Trusts - REITs
      • Retirement Plans and IRAs
      • RIA Sales & Distribution
      • Risk Management
      • Selling Away
      • Senior Investors
      • Sales Supervision
      • Sales Practice
      • Suitability
      • Supervision
      • Trade Processing
      • U-5 Reporting/Defamation
      • Wrongful Termination
      • Alternative Investments
      • Banking
      • Branch Management
      • Broker Obligations
      • Clearing
      • Corporate Governance
      • Complex Products
      • Employment
      • Equities
      • Equity Research
      • Exchanges
      • Fiduciary Investments
      • Financial & Asset Management
      • Former Regulators
      • Fraud
      • Insider Trading
      • Institutional Trading Supervision
      • Introducing Firm/Clearing Firm
      • Investment Advisory
      • Investment Management
      • Market Manipulation
      • Mutual Fund
      • Mutual Fund Operations
      • Operations
      • Operations & Controls
      • REITS
      • RIA Sales & Distribution
      • Risk Management
      • Selling Away
      • Sales Practice
      • Sales Process
      • Sales Supervision
      • Suitability
      • Supervision
      • TICS
      • Trading
      • Regulatory & Internal Investigations
      • Data, Analyses & Analytics
      • Financial Crimes
      • Compliance Solutions
    • Institutional
      • Securities and Financial Services Litigation & Consulting
      • Alternative Investments
      • Banking
      • Branch Management
      • Broker Dealer (B-D)
      • Broker Obligations
      • Clearing
      • Corporate Governance
      • Complex Products
      • Eligible Employee 
      • Employment Practices Liability
      • Equities
      • Elder Issues
      • Employment
      • Equity Research
      • Fiduciary Duties/Responsibilities
      • Fiduciary Investments
      • Financial Institution Sales
      • Financial Analyst Responsibilities
      • Former Regulators
      • Fraud
      • Insider Trading
      • Information Management
      • Introducing Firm/Clearing Firm Relationship
      • Investment Advisory
      • Investment Management
      • Limited Partnerships
      • Legal
      • Mutual Funds
      • Non-Publicly Traded Alternative Investments
      • Operations
      • Operations & Controls
      • Outside Business Activity
      • Real Estate Investment Trusts - REITs
      • Retirement Plans and IRAs
      • RIA Sales & Distribution
      • Risk Management
      • Selling Away
      • Senior Investors
      • Sales Supervision
      • Sales Practice
      • Suitability
      • Supervision
      • Trade Processing
      • U-5 Reporting/Defamation
      • Wrongful Termination
      • Alternative Investments
      • Banking
      • Branch Management
      • Broker Obligations
      • Clearing
      • Corporate Governance
      • Complex Products
      • Employment
      • Equities
      • Equity Research
      • Exchanges
      • Fiduciary Investments
      • Financial & Asset Management
      • Former Regulators
      • Fraud
      • Insider Trading
      • Institutional Trading Supervision
      • Introducing Firm/Clearing Firm
      • Investment Advisory
      • Investment Management
      • Market Manipulation
      • Mutual Fund
      • Mutual Fund Operations
      • Operations
      • Operations & Controls
      • REITS
      • RIA Sales & Distribution
      • Risk Management
      • Selling Away
      • Sales Practice
      • Sales Process
      • Sales Supervision
      • Suitability
      • Supervision
      • TICS
      • Trading
      • Regulatory & Internal Investigations
      • Data, Analyses & Analytics
      • Financial Crimes
      • Compliance Solutions
  • Regulatory & Internal Investigations
    • U.S. & Global Regulatory Investigations
    • Internal Investigations
  • Data, Analyses & Analytics
    • Early case Assessment
  • Financial Crimes
    • Forensic Accounting
    • Internal Investigations
    • Fraud & Risk Management
  • Compliance Solutions
    • Broker-Dealers
    • Registered Investment Advisers
    • Cyber Security
    • Bank Secrecy Act
    • Compliance Testimony

Credentials

EXPERIENCE

J.P. Morgan Chase & Co., New York, NY, Executive Director, Regulatory Compliance, Alts, Banking, Broker-Dealer, Ethics, FI, Hedge Fund, IA/IC, Swaps, 2015 – 2018

The Cadwalader Cabinet, New York, NY, Banking and Securities Law & Compliance, 2014 – 2015

W. P. Carey Inc., New York, NY, Broker Dealer General Counsel & Chief Compliance Officer, WPC Chief Risk Officer and Associate General Counsel, 2005 – 2014

Daiwa Securities America Inc., New York, NY, Director of Compliance, Associate General Counsel, Senior Vice President

The Depository Trust & Clearing Corporation, New York, NY, Chief Legal & Regulatory Compliance Officer, Associate Counsel               

Fidelity Investments, Boston, MA, Director, Counsel

U.S. Securities and Exchange Commission, New York, NY, Special Counsel, Enforcement                            

EDUCATION

Brooklyn Law School, Brooklyn, NY, J.D.; Associate Editor, Brooklyn Journal of International Law; Member, Moot Court Honor Society

St. Lawrence University, Canton, NY, B.A. with Honors in History

The Hebrew University of Jerusalem, Israel, International Relations, Junior Year

PROFESSIONAL QUALIFICATIONS/LICENSING

Member of the New York State Bar

Series 3, 7, 14, 24, 63, 79, 99

NFA Principal

Experienced FINRA Arbitrator and Disciplinary Hearing Panelist

INDUSTRY RECOGNITION

Elected to leadership positions at FINRA (Chair, District 10 Committee) and the Institute for Portfolio Alternatives (Chair, Legal and Regulatory Committee for Alts Funds Industry). 

Appointed by SIFMA to its Compliance and Regulatory Policy Committee and by FINRA to its Membership, Corporate Financing and National Arbitration and Mediation Committees. 

PUBLICATIONS

FINRA Comment Letter on reliable NAV valuation processes, at page 163 of 268, 2014. 

SIFMA White Paper: The Evolving Role of Compliance, Contributor, 2013.