CARMINE E. ANGONE
SENIOR CONSULTANT
BCCP US TRISTATE DIVISION

PROFESSIONAL HIGHLIGHTS

Bekker Compliance Consulting Partners, LLC
Independent Consultant
2008 – Present

Carmine is an independent Senior Consultant under contract with Bekker Compliance Consulting Partners, LLC (BCCP). He provides regulatory compliance consulting and training to BCCP’s financial services clientele.

Invesco Institutional NA Inc.
Senior Compliance Manager
2006 – Present

Responsible for all asset management compliance activities at the New York office of INVESCO Institutional NA with $100 billion of third party institutional clients consisting of private equity, hedge fund, mutual fund, bank loan CDO and high net worth individuals. Responsibilities include partnering with various business units to provide the appropriate guidance to reasonably ensure compliance with firm wide policies and procedures. Activities include the identification of conflicts of interest that result in either revising existing or developing new processes and procedures so that all clients are treated fairly. Areas of expertise include: development of compliance programs consistent with the requirements of 206(4)-7, soft dollars, advisory marketing review, sales force product distribution, equity and fixed income trading, wrap, code of ethics, Form ADV, foreign country registration, etc. Extremely notable is a very strong understanding of the Investment Advisers Act of 1940 and Investment Company Act of 1940 with the added ability to independently interpret new and existing securities rules and regulations to formulate new policies and procedures that seek to ensure compliance through the development of innovative monitoring techniques.

Jennison Associates LLC
Vice President, Compliance
2004 – 2006

Responsibilities include development of a firm-wide compliance program, consisting of the development of policies and procedures that are reasonably designed to ensure compliance with the Investment Advisers Act of 1940 and best practices, hiring and training compliance professionals and developing a means of monitoring company investment activity to ensure compliance with procedures. The firm manages $75 billion in third-party accounts, including but not limited to, pension plans, mutual and commingled funds, managed (or wrap) accounts. Manage a staff of compliance professionals responsible for a wide range of activities including code of ethics, personal trading, inside information, proxy voting, advisory marketing and advertising review, Global Investment Performance Standards (“GIPS®”), regulatory filings, etc. Provide guidance on investment management activities to senior management on such matters as soft dollars, affiliated, opposite direction investment, wrap, linking of a GIPS® compliant firm’s composites with a non-compliance managed account division, discretionary and non-discretionary models and other investment management related activities.

New York Life Investment Management, LLC
Vice President, Investment Management Compliance
2000 – 2004

Responsible for asset management compliance at the company’s primary location with over $130 billion under management consisting of both public investment and non-investment grade fixed income, equity, convertible securities, alternative investment products, private equity, limited partnerships, mutual funds, etc. Assessed and evaluated various investment units’ risk as well as the regulatory environment in which the business units must operate. Assisted and worked with outside consulting firm’s regulatory group to perform forensic analysis on the entire company’s investment process. Formulated compliance programs to reduce risk exposure to the company and allow the company to operate within the required regulatory requirements. Primary responsibilities include, but not limited to, development and implementation of investment management and information barrier policies and procedures suitable to the company’s investment style and structure. In addition, implemented policies across business units in N.Y. and other branch offices. Prepared and filed Form ADV for several federally covered investment advisers. Also maintained and provided training on the company’s Insider Trading, Code of Ethics and Personal Trading Policy and Procedures. Developed and implemented a process to monitor compliance with investment limitations and restrictions for all third-party institutional client accounts and mutual funds. Other responsibilities include 13F&G filings. Performed due diligence on other advisory firms prior to being acquired by NYLIM. Worked with senior investment management teams to assist in bringing new products to market.

CIBC Oppenheimer
Director, Investment Partnerships
1996 – 2000

Directly responsible for the overall compliance, administration and operations of private investment partnerships registered with the SEC under the Investment Company Act of 1940 and closed-end country funds, which includes: formation and registration, setting up operations (custody, prime brokerage, trading & trade delivery, client service administration, etc.), developing compliance procedures, as well as procedures for year-end processing, ensuring for compliance with the Investment Company Act of 1940 (Rule: 17e-1, 17a-7, 10f-3, 17g-1, 17j-1, 17d, 17f-5, 23c-1 Sec’s.: 17f-1, 30d, 30f, 18f, etc.). Thorough understanding of all aspects of operations relating to finance and compliance with the Investment Company Act of 1940. Also knowledgeable in the areas of aggregation and allocation procedures, soft dollar arrangements, problem solving resulting from trading errors, and general trade support. Extremely knowledgeable in the area of corporate buy-backs and letters of tender pursuant to 10b-18, 13e-4, respectively. Good understanding of 3(c)1 and 3(c)7 issues relating to eligibility, accreditation and qualification as it relates to a Reg. D offering. Assist in preparation and review of all N-SAR, FDS, 13f, Sec. 30 and N-2 filings. Experience in dealing with SEC examiners. Oversee preparation of board books. Additionally, exceedingly strong understanding of operations in general and the fundamental way mutual funds and private investment partnerships operate.

The 44 Wall Street Group
Mutual Fund Compliance Operations Manager/Administrator
1986-1996

Responsible for two fund groups, one of which was a series fund group consisting of three separate portfolios, with exposure in the following areas:

  • Assist in the development of policies, procedures and internal controls.
  • Controlled all fund accounting, including daily NAV pricing, and accrual expense analysis.
  • Prepared all financial statements and filing of Form N-SAR.
  • Extensive knowledge of various financial products through working directly with portfolio manager.
  • Performed RIC qualifying compliance testing.
  • Monitored activities of custodians, transfer agents, independent accounts, solicitors, and tabulators.
  • Monitoring and performing Blue Sky registration renewals.
  • Completed all regulatory report filings, and interfaced with regulatory agencies and outside counsel for making recommendations and effectuate disclosure changes to Form N-1A for all funds.
  • Contract administration; involved with several mergers of regulated investment companies, including preparation and filing of Form N-14; soft dollar arrangements in accordance with 28(e); 24F-2 Notice; Code of Ethics; bonding requirements in accordance with 17g-1; leveraging pursuant to 18f of the 1940 Act; responsible for investment advisory contract and principal underwriting agreements; directed all proxy solicitations; performed trading surveillance by establishing internal trading controls with funds’ introducing broker/dealer so as not to violate I.A.A. and clearing firm agreement; prepared all material for and attended all Board of Directors meetings.

    • EDUCATION

    Bachelor of Arts, Economics, Queens College, Flushing, NY