Patomak Global Partners assist firms in designing and implementing compliance frameworks for regulatory licensing to help ensure the approval process, and consummation goes smoothly. To support these efforts, the team develops policies, procedures, and internal controls for trading, risk management, margin, capital, compliance, cyber security, anti-money laundering, know-your-customer requirements, community reinvestment and consumer compliance, and other functions considered during the licensing process.
Risk management, trading and surveillance, swap data reporting, and capital adequacy assessments
The Patomak team assesses the design and implementation of risk management, trading and surveillance, and reporting (SDR, CAT, TRACE) systems to ensure they meet regulatory requirements. Team members also review capital, credit, liquidity frameworks, and regulatory capital modeling approaches to ensure clients exceed regulatory expectations.
Governance and supervision
Patomak reviews governance frameworks and advises clients regarding shareholder relations, management duties and responsibilities, risk control, assessment programs, supporting independent review functions (e.g., audit, credit, model, etc.), and committee structures and charters.
Compliance program assessment and exam preparation
Patomak Global Partners assess compliance programs at banks, broker-dealers, swap dealers, security-based swap dealers, futures commission merchants, consumer lenders, mortgage servicers, digital asset trading platforms, fintechs, and other financial firms to identify control weaknesses. The team provides recommendations to remediate identified issues and conducts follow-ups to ensure successful remediation.
The team works with executives to prepare clients for examinations by U.S. banking regulators, the Consumer Financial Protection Bureau, the Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, the Financial Industry Regulatory Association, the National Futures Association, the Securities and Exchange Commission, and other authorities.
Examples of the Patomak Global Partners’ risk management and compliance engagement include:
- Served as an independent compliance consultant for a broker-dealer pursuant to an SEC order focusing on controls and procedures regarding Rules 15c3-1 (Net Capital) and 15c3-3 (Customer Protection).
- Audited board/management governance, BSA/AML, UDAAP, and fair lending risks of a bank’s relationship with its third-party customers and vendors.
- Reviewed all aspects of enterprise risk management for global financial institutions, across all risks, including culture and tone at the top, governance and structure, risk measurement, monitoring and reporting and management, control and mitigation, and independent review functions.
- Served as an implementation partner for multiple firms on swap dealer registration and end-to-end implementation of a compliance program spanning SDR reporting, trade surveillance, margin, capital reporting, risk management, and client onboarding.
- Provided strategic advice and compliance support to several broker-dealers, pre-settlement, regarding off-channel communications and record retention requirements, including recommendations for vendor solutions, policies, procedures, control assessments, sample testing, communication channel inventories, and implementation.
- Conducted for a large financial institution with multiple broker-dealers first an independent review and, thereafter, annual reviews to support chief executive certification regarding SEC Rule 15c3-5 (Market Access Rule) compliance, including financial, regulatory, and other risk management controls and supervisory procedures.
- Analyzed swap data repository reporting for a large global swap dealer, assessing compliance with CFTC Parts 43 and 45 regulations.
- Served as an independent compliance consultant pursuant to FINRA enforcement actions regarding a broker-dealer’s compliance with blue sheets and TRACE reporting.
- Advised a corporate issuer on responding to globally coordinated enforcement actions related to manipulating commodities and securities markets.
- Reviewed the end-to-end capital calculation and related regulatory filings of an international bank and assisted with the remediation of identified issues.
- Conducted five risk assessments for a financial institution, analyzing the likelihood of risk events associated with each risk area, provided inherent risk ratings and customized methodologies, and recommended enhancements to its internal controls.