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Richard Paley

Richard Paley

Richard J. Paley is a Bates Consulting and Testifying Expert. 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.

Richard is a consultant and subject matter expert in these Practice Areas and Services:



Bates Group LLC, Consulting and Testifying Expert, 2018 - Present
J.P. Morgan Chase & Co., Executive Director, Regulatory Compliance, Alts, Banking, Broker-Dealer, Ethics, FI, Hedge Fund, IA/IC, Swaps, New York, NY, 2015 – 2018
The Cadwalader Cabinet, Banking and Securities Law & Compliance, New York, NY, 2014 – 2015
W. P. Carey Inc., Broker Dealer General Counsel & Chief Compliance Officer, WPC Chief Risk Officer and Associate General Counsel, New York, NY, 2005 – 2014 
Daiwa Securities America Inc., Director of Compliance, Associate General Counsel, Senior Vice President, New York, NY,
The Depository Trust & Clearing Corporation, Chief Legal & Regulatory Compliance Officer, Associate Counsel, New York, NY
Fidelity Investments, Director, Counsel, Boston, MA
U.S. Securities and Exchange Commission, Special Counsel, Enforcement, New York, NY    


Juris Doctor (JD), Brooklyn Law School, Brooklyn, NY

  • Associate Editor, Brooklyn Journal of International Law
  • Member, Moot Court Honor Society

Bachelor of Arts (BA), History with Honors, St. Lawrence University, Canton, NY
International Relations, Junior Year, The Hebrew University of Jerusalem, Israel


Member of the New York State Bar
Series 3, 7, 14, 24, 63, 79, 99
NFA Principal
Experienced FINRA Arbitrator and Disciplinary Hearing Panelist


  • 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.  


  • FINRA Comment Letter on reliable NAV valuation processes, at page 163 of 268, 2014.  
  • SIFMA White Paper: The Evolving Role of Compliance, Contributor, 2013.