Broker-Dealer, RIA & Futures Commodity Merchant 

Compliance Expert Witness

Brokerage Firm Compliance Expert Witness | FINRA Rules & Regulations Expert Witness

Ann Grady

Ann Grady is an experienced financial services compliance officer with broad expertise in capital markets, broker-dealer regulation, futures and commodities operations and regulation and investment advisory compliance programs. She possesses special expertise with registration and regulation of broker-dealers, market makers, specialists and clearing firms. 

As a former regulator, Ann is experienced with operations and compliance matters including clearing firm operations, significant order routing, execution, advertising, customer complaints, FINRA arbitrations, contract and vendor due diligence and negotiation and fraud reviews. She is an active compliance consultant for Registered Investment Advisers, FINRA broker-dealers, institutional brokers, hedge fund managers, and commodities firms operating as Independent Brokers (IBs) or Futures Commission Merchants (FCMs). 

Ann Grady has worn many different hats throughout her 30+ year career in the financial services industry which includes 20 years of acting as a regulator followed by serving as the Chief Compliance Officer (CCO) working at a variety of well-respected brokerage and investment advisory firms for the majority of the last 15 years. Ann has been a registered Principal with a clean regulatory history at a variety of brokerage and advisory firms, including TD Ameritrade, ABN AMRO, Wolverine Trading and thinkorswim.  She led the registration and compliance program as the CCO to open tastyworks for business in 2017 and an affiliate advisory firm opened in 2018. Her experience has yielded a comprehensive understanding of the financial services industry from the ground up.

Ann is retained on a consulting basis or as a testifying expert witness on matters concerning broker-dealers, Futures Commission Merchants (FCMs), Registered Investment Advisers (RIAs), clearing firm operations, and order routing by exchanges. Her expertise and experience offer valuable insight for FINRA arbitrations, legal matters and internal investigations involving securities, futures, order routing, trade executions and annuities. 

Professional Experience

  • Pyrenees Compliance LLC - Compliance Consultant (October2014 – Present)

    • Act as a registered Chief Compliance Officer for Investment Advisers and Broker-Dealers on a temporary or long-term basis, prepare annual CEO-CCO reports, registrations (CRD-ORS) advertising reviews & approvals for BDs, IAs registrants of FINRA, SEC and SROs or NFA registered entities​.

    • Register securities firms (broker-dealers, investment advisers and Exchange market makers, hedge funds and prop firms) and commodities firms (IBs and FCMs) typically  in less than 4 months (investment advisers and hedge funds) and less than 1 year ( FINRA and NFA registrants as FCM or Introducing Broker or Proprietary Firm) and prepared and filed applications. 

    • Develop and implement compliance programs, identify and conduct due diligence of vendors, execution, best execution, surveillance, cybersecurity and clearing vendors as necessary.

    • Develop compliance manuals and procedures for investment advisory firms, broker dealers, market makers, Exchange floor-based brokers and prepared the application of a futures exchange.

    • Compliance support on key items such as conflicts of interest, compliance calendar, marketing material, supervision & registration, solicitation of business and employee compliance monitoring.

    • Annual Report and Testing documentation for Main Office and Branch Office Exams, AML Audits and regulatory reports such as the NFA Self-Exam and Questionnaires, FINRA 3130 and 3120 Report, reviews and updates to any State, FINRA or NFA registrations or the filing of Form ADV.

    • Expert witness for any arbitration or legal matter or internal investigation.

  • tastyworks, Inc. - Chief Compliance Officer (March 2015- July 2018)

    • Responsible for internal and external supervision, regulatory and compliance training programs and regulators’ registration & filing systems (NFA ORS and FINRA CRD system including access to IARD) and registrations of the firm and its employees​.

    • Review and edit promotional material to satisfy FINRA, SEC & NFA Requirements for firm & affiliates.

    • Update and write policies, disclosures and responses to regulatory inquiries.

    • On-boarded regtech software for employee trading and firm’s employee attestations.

    • Prepare annual regulatory reports (FINRA 3130) and NFA Self-Exam Checklist & Questionnaires.

    • Act as regulatory liaison between the Firm, its Principals and the regulator for all matters and to guide legal counsel on any arbitration, civil or other legal matter.

    • Constructed website(s), email and social media in compliance with SEC, NFA and FINRA marketing rules for the firm and its parent company’s financial news network, tastytrade and IA entity.

  • X-Change Financial Access LLC - Chief Compliance Officer (August 2012-2014)

    • Responsible for all U.S. Exchange securities and commodities registrations as a floor broker and Options Clearing member and related compliance policies and procedures, regulatory exams, marketing, AML and oversight of the Compliance Manager and his surveillance reviews.​

    • Registered the firm as an Options Clearing Corporation member in less than 9 months to facilitate correspondent execution business on all U.S. option exchanges and facilitated new stock and futures clearing firm relationships for cost savings and improved operational efficiency.

  • TD Ameritrade, Inc. - Futures & Forex Chief Compliance Officer (2009-2012)

    • Spearheaded a cross functional initiative between thinkorswim and TD Ameritrade business and compliance counterparts (e.g., Risk Management, Margin, New Accounts, AML, Registrations, Finance & Accounting, Marketing & Education programs, Autotrade, and Surveillance, etc.) to implement appropriate action and procedures as warranted.​

    • Consulted with the Corporate legal staff as needed to resolve difficult legal compliance issues and to assist on arbitration or legal matters that needed compliance’s input.

    • Researched trade errors, compliance exceptions, and conducted investigations of customer complaints, arbitration claims and regulatory inquiries.

    • Lead on-boarding projects to complete the integration of the thinkorswim business and to establish execution on U.S. exchanges for foreign affiliates and institutional clients.

    • Implemented the futures & forex branch audit program (Ft. Worth, Chicago and Omaha).

  • thinkorswim, Inc. - Chief Compliance Officer (2008-2012)

    • Managed the day to day compliance functions of the thinkorswim entity.

    • Acted as the primary liaison with all regulators and the firm’s outside counsel on compliance matters for the conversion of the firm into the TD Ameritrade operation and reconciliation of all registrations and supervisory changes to comply with all regulatory and firm requirements:

      • Established and implemented compliance and new account procedures for conversion of thinkorswim accounts to TD Ameritrade.

      • Trained compliance, trade desk and back office staff to reconcile and inform staff of the requirements necessary to follow until the broker dealer and clearing conversions completed.

      • Worked closely with firm’s AML Officer to create surveillance and fraud mitigation.

      • Acted as the US Compliance Representative for foreign affiliates: thinkorswim Canada, Singapore and Australia and to convert these foreign entities to TD Ameritrade affiliates.

      • Advertising & Marketing Reviews:  marketing agreements & social media compliance programs to conform to SEC, NFA and FINRA for the firm and its affiliates

Prior Experience

  • Merrill Lynch, Pierce Fenner & Smith, Inc. - Vice-President & Compliance Director (2004-2008)

  • ABN AMRO, Inc. - Vice-President & Compliance Director Professional Brokerage Execution Division (2002-2004)

  • Wolverine Trading, L.P. - Chief Compliance Officer (2000-2002)

  • Chicago Board Options Exchange - Director, Regulatory Services Division (1989-2000)

Education

 

  • DePaul University, Chicago, Illinois

    • Bachelor's Degree: Liberal-Arts & Sciences

  • Completion of FINRA & NASAA Examinations (current)

    • Series 4 - Registered Options Principal Qualification Examination

    • Series 7 - General Securities Representative Qualification Examination

    • Series 14 - Compliance Officer Qualification Examination

    • Series 24 - General Securities Principal Qualification Examination

    • Series 63 - Uniform Securities State Law Examination

  • Completion of NFA Examinations (current)

    • Series 3​ - National Commodities Futures Examination

    • Series 34 - Retail Off-Exchange Forex Examination

  • SEC Enforcement Compliance Training Program – 12-hour program

  • NASD Training Program for Capital Computation and Compliance – 30-hour program

  • FINRA AML Bootcamp – 25-hour program

  • ​Current on FINRA Regulatory CE and FINRA Firm Element and NFA Ethics Training over the last fifteen (15) years

Leadership & Activities

  • NYSE/Arca Ethics & Business Conduct Committee Member - (2001 - Present; Chairperson 2003-2006)

  • CBOE Arbitrator - (2002-2013; Arbitrator Chairperson 2010 - 2013)

  • Securities Traders Association of Chicago (STAC) Member - (2018 - Present)

  • National Association of Compliance Professionals Member - (2013-2019)

FINRA, SEC & CFTC Rules & Regulations
  • Supervision & Control System (FINRA Rules 3110 & 3120)
  • FINRA & NFA Firm Element 
  • The Risk Management Program (CFTC Rule 1.11)
  • Risk Assessment & Record Keeping (SEC Rule 17(h))
  • Market Access: Risk & Controls (SEC Rule 15c3-5)
  • Annual Compliance Reports FINRA 3130 or CFTC
Broker-Dealer Compliance & Operations
  •  Regulatory & Firm Compliance Requirements
  • Internal Controls Assessments
  • Supervision Plan & Enforcement
  • Anti-Money Laundering (AML)
  • Written Supervisory Procedures (WSP)
  • Ethics & Compliance Training
  • FINRA & NFA Registrations
  • Customer Complaints
Investment Advisers Compliance & Operations
  • Fiduciary Duty
  • Conflicts of Interest
  • Compliance Manuals & Procedures
  • Form ADV
  • Disclosures & Omissions
  • Registration Requirements
  • Employee Compliance Monitoring
  • Marketing & Advertising
  • Conducting Due Diligence

Our Experts    |    Services    |    FINRA Arbitration    |    Mediation    |      Pro Bono Services    |    Contact

Barrington Financial Consulting Group, Inc.

3800 American Blvd West | Suite 1110 | Bloomington, MN  55431
800-741-0704  |  952-857-2411  |  Fax: 952-835-1504  |  E-mail


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