CARRIE F. BEKKER – Chief Executive Officer

Savvy regulatory compliance veteran, with 25 years expertise involving SEC Rules 38a-1/206(4)-7, USA PATRIOT Act, SEC Regulation S-P, Sarbanes-Oxley, as well as FINRA, .SEC 1933, 1934, 1940 and Advisers Act compliance.  Other areas of expertise include offshore and multi-state domestic entity formation and governance, as well as public and private securities offerings, Blue Sky law, mergers and acquisitions and intellectual property matters.

Professional Highlights

Bekker Compliance Consulting Partners, LLC, Los Angeles and San Diego, California – Chief Executive Officer, Managing Partner

  • BCCP is a boutique regulatory compliance consulting firm that specializes in providing proactive compliance solutions to the financial services industry. BCCP currently has about 30 regulatory compliance consultants which are located all over the country. Virtually all of BCCP’s consultants have at least 10 years regulatory compliance experience; more than half have 20 years or more experience in the financial services industry.
  • BCCP also provides consulting services pertaining to e-compliance solutions for clients who need assistance in upgrading their technology in order to automate all or a portion of their compliance programs. Because BCCP already has well-developed working relationships with many cutting-edge technology firms offering a diverse complement of e-compliance solutions, BCCP provides e-compliance consulting services in the following areas:
    • Discuss the client’s specific e-compliance needs and objectives
    • Consult with third party e-compliance vendors to determine which solutions may the best fit for the client’s needs
    • Liaise with the e-vendors to arrange demos, so that the client has the opportunity to evaluate viable e-compliance solutions within its budgetary requirements
    • Consult with and make recommendations based on the client’s unique needs.
  • BCCP’s financial services clientele include the following sectors:
    • Insurance companies with variable universal life and variable annuity products
    • SEC registered mutual funds
    • Hedge funds
    • SEC registered investment advisers
    • SEC registered hedge fund advisers that have decided to stay registered
    • Banking institutions, including MSBs
  • BCCP’s core areas of expertise including the following areas:
    • Rule 38a-1 under the Investment Company Act of 1940
    • Rule 206(4)-7 under the Investment Advisers Act of 1940
    • USA PATRIOT Act
    • SEC Regulation S-P
    • Sarbanes-Oxley Act of 2002

AIG SunAmerica Retirement Markets, Woodland Hills, California – Director of Variable Annuity Compliance

  • Responsible for running the auditing function of Rule 38a-1 of the Investment Company Act of 1940. Position involves analyzing risk by performing periodic risk assessments, determining the appropriate auditing methodology for each procedure (e.g., via walkthrough, forensic testing, or both), and auditing each of the 66 compliance procedures according on the frequency specified in the risk assessment and audit plan. In an effort to ease the burden of fellow departments having to contend with overlapping auditing walkthroughs/testing, I took the initiative to develop close relationships with the SOX Team and Internal Audit, in order to explore synergies among the three teams by meeting regularly, sharing information where appropriate, and streamlining walkthroughs and testing whenever possible.
  • Also responsible for creating, implementing and maintaining 38a-1 test plans, narratives, and audit reports; performing walkthroughs and testing; and working closely with senior management in communicating auditing results and recommendations, to build consensus and to implement any necessary action plans to ensure that recommendations are carried out in a timely fashion.
  • Work closely with the CCO, AVP and other intra-department colleagues in developing auditing results disclosure for the annual report presented to the Board of Directors.
  • As part of the Life Companies’ “culture of compliance,” explored over time various marketing concepts which ultimately resulted in the “birth” of a Compliance mascot, motto and overall campaign. The Compliance Mascot’s name is now the moniker for “The Buzz,” a bimonthly electronic publication featuring a different compliance topic in each issue.
  • Handle industry-related research, focusing on industry practices, competitor information, and regulatory updates.

AEGON/Transamerica, St. Petersburg, Florida – Assistant Vice President, Anti-Money Laundering Compliance Officer, Compliance Supervisor

  • Initially responsible for rewriting 15 variable universal life and annuity product prospectuses, from legalese into plain English, in order to comply with the SEC’s Plain English mandate. Also handled all aspects of creating new and updating existing variable product prospectuses, including certain aspects of the fund prospectuses (including fund of funds).
  • Over time, responsibilities were expanded to include analyzing and tracking fund-related SEC regulations – from reviewing the proposed rule, participating in industry-related conference calls and comment letters, and listening to SEC rulemaking webcasts, to analyzing the final SEC rule published in the Federal Register. Also took the lead in working with the business units to create and implement policies, procedures and training materials to assure full compliance before the rule’s compliance deadline. Example: Analyzed final mutual fund rules implementing USA PATRIOT Act Sections 314, 326 and 352; created comprehensive, risk-based AML policies, procedures and training materials; investigated suspicious activities, and, if necessary, creating and filing the SARs with FinCEN.
  • Took the lead in coordinating with Law Department personnel, outside counsel, senior management and departmental staff in gathering, analyzing and submitting electronic data in response to periodic SEC requests.
  • Hedge fund private placements: Drafted private placement memoranda and subscription documents. Created PowerPoint presentations and related written communications geared towards registered representatives. Assisted with broker/dealer presentations during AEGON/Transamerica’s annual registered representative conference. Handled due diligence to determine proper licensing of registered representatives; also served as custodian of incoming/outgoing private placement memoranda and subscription documents.

Pacific Life Insurance Company, Newport Beach, California – Senior Project Compliance Analyst

  • Responsible for overseeing all aspects of compliance-related projects involving the company’s variable annuity products. Such projects included: Section 38a-1 of the 1940 Act, USA PATRIOT Act, Sarbanes-Oxley, and SEC Regulation S-P (privacy). Created, implemented and documented all compliance-related project plans. Also facilitated communication with all project plan participants during the entire project life cycle.
  • Handled pilot testing of Aquilan Patriot Manager, an automated anti-money laundering compliance program designed to detect suspicious activity in variable insurance products and retail mutual funds. Analyzed and documented testing results, including recommendations for program adjustments, the reports for which were provided directly to Pacific Life’s Chief Financial Officer.

Harney, Westwood & Riegels/HWR Services Limited, British Virgin Islands -- Legal Executive, Offshore Incorporations and Mutual Funds Compliance Units

  • Department head of high-volume offshore incorporations trust company, servicing clients in Europe, the Americas, and the Far East.

  • Responsibilities included constant verbal and written communication with overseas clientele; devising departmental forms and written procedures to boost efficiency and accuracy; supervising departmental staff in the day-to-day operations; and training and mentoring staff to ensure stateside-style quality service to the trust company’s clientele.

Berman Wolfe & Rennert, P.A., Miami, Florida ● Farella Braun & Martel, San Francisco, California ● Johnson, Pope, Bokor, Ruppel & Burns, LLP, Clearwater, Florida -- Paralegal Manager and Senior Corporate Securities Paralegal

  • Specialized in all aspects of public offerings, private placements, SEC, state securities,FINRA, and stock exchange compliance; transactional, including mergers and acquisitions; and domestic/offshore corporate finance matters, from inception to liquidation.
  • Authored course materials for continuing legal education publications and newsletters for client use. Also developed and delivered in-house educational training programs covering real estate, corporate, and securities law matters.
  • Drafted offering documents, SEC reports, agreements, and closing documents. Also created and coordinated broker/dealer and investment adviser registrations.
  • Performed extensive legal research pertaining to federal and state regulatory requirements, including documentation of results. Also handled and documented client and target company due diligence.
  • Frequently presided as a guest speaker for local paralegal association meetings. Topics included federal and state securities law developments. Also created written materials for attendees.

Continuing Education

  • 1981 -- A.S. Degree, Business/Legal, cum laude, St. Petersburg College, Clearwater, Florida. Curriculum included general business, business law, business writing, and accounting courses.
  • Regularly attend conferences to stay abreast of regulatory compliance developments in the financial services industry, including trends and best practices. Conferences attended in 2006 include the following:
    • NSCP -- Annual Compliance Conference
    • NICSA -- Alternative Investments
    • NICSA -- Tech Summit
    • ACAMS -- Annual AML Conference
    • ALI-ABA -- Insurance Products
    • Institutional Investor -- Hedge Fund Compliance
    • ICI -- Securities Law Developments
Other recently attended conferences include:
    • NAVA Regulatory Affairs
    • ALI-ABA Investment Company Regulation and Compliance
    • ICI & ACAMS Anti-Money Laundering Conferences and Workshops
    • British Virgin Islands (BVI) Government -- Due Diligence for Detecting Money Laundering Activities
    • BVI in house training courses -- International Business Companies, and Offshore Trusts and Derivatives

Professional Memberships

  • National Association of Compliance Professionals (NSCP)
  • National Investment Company Services Association (NICSA)
  • Association of Certified Anti-Money Laundering Specialists (ACAMS)
  • California 1940 Acts Compliance Group
  • National Association of Variable Annuities (NAVA)

Other Memberships

  • Porter Valley Country Club
  • SurfRider Foundation

Credentials & Licenses

  • FINRA Series 6 and 26 licenses.
  • CLA (Certified Legal Assistant) since 1988. (CLA designation awarded by the National Association of Legal Assistants Certification Board after passing a two-day written examination. Areas tested included communications, human relations, ethics, legal research and writing, as well as five substantive law areas: general, corporate, contractual, administrative, and criminal law.)