Job Details

Principal Counsel, Ethics (R-001661)

Company name

FINRA.

Organization Type

In-House

Job Type

Attorney

Date Last Verified

Oct 06, 2020

Posted on

Aug 21, 2020

Years of Experience

Min 6 yrs required

Location

Washington, DC, United States

Industry

Legal
Practice Area
Corporate >> Corporate
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Additional Locations: New York, NY & Rockville, MD

Job Summary:

The Ethics / Code of Conduct Office (the Ethics Office) is responsible for ensuring that FINRA executes its regulatory responsibilities in an ethical manner promoting confidence in FINRA’s independence. This attorney position is responsible for creating, interpreting, advising on, monitoring and maintaining various conflicts-of-interest programs at FINRA, at all times acting in an independent and confidential manner.

This is senior-level professional work in which the incumbent is developing their assigned roles, increasing their skills, assuming increased responsibility, and working under general guidance of the Ethics Director and VP.

Essential Job Functions:

  • Independently counsels senior executives and senior managers in departments across the company regarding complex conflicts of interest questions raised to the Ethics Office. 
  • Presents recommendations regarding solutions and outcomes for significant conflicts issues to the Ethics Director and VP; takes a leadership role in proactively identifying patterns and systemic issues in the FINRA’s conflicts-of-interest policies; proposes and manages implementation of necessary modifications to such programs; reports to the Ethics Director and VP on a periodic basis on the status of the programs under the attorney’s responsibility.
  • Independently conducts comprehensive investigations of potential violations of the conflicts of interest policies and related violations of FINRA’s Code of Conduct, including interviewing relevant players, drafting summaries for case files, and working with relevant control departments to determine outcomes.
  • Demonstrates expert-level knowledge and familiarity with the parameters and nature of each FINRA Regulatory Department’s specific regulatory programs.
  • Serves as source of expertise on one or more areas of FINRA’s Ethics Program.
  • Serves as liaison to senior managers of all FINRA Regulatory Departments regarding FINRA’s Conflicts of Interest Waiver Policy; exercises independent judgment in evaluating suggested changes by regulatory departments to same; identifies and presents original, creative, innovative and sophisticated solutions for changes to the policy which reflect the intricacies and nuances of each department’s regulatory program and mission, including streamlining compliance tasks and changes necessary to accommodate changes in the regulatory program or structure; responsible for creation of related guidance materials.  Provides nuanced review and guidance to regulatory departments regarding permissibility of proposed conflicts of interest waivers, being mindful of precedent and future oversight by the SEC; responsible for monitoring each department’s ongoing compliance with the Policy.
  • Serves as enterprise-wide liaison for the FINRA Former Employee Review Policy.  Provides expert interpretive guidance to all FINRA departments regarding the Policy, reviewing compliance by FINRA departments with the Policy, and providing direction to FINRA’s HR and Registration and Disclosure departments regarding required tasks under the Policy.  Identifies and presents original, creative, innovative and sophisticated solutions for changes to the existing policy, including streamlining compliance tasks or reflecting changes to departmental programs.  Responsible for creation of guidance materials. 
  • Serves as the primary attorney responsible for the “Revolving Door” policy underpinning the relevant FINRA Rules, the related guidance materials and training programs.  Provides interpretive guidance to both external and internal constituents, including former employees, member firms, and current senior managers and employees, the Ombudsmen’s office, and Corporate Communications.
  • Primary attorney responsible for independently advising regulatory departments on FINRA’s overarching Conflicts of Interest Policy, including working closely with departments’ senior managers to ensure compliance with the policy and timely, innovative, and creative solutions to complex issues posed by the differing regulatory programs. Reviews and provides legal expertise regarding departments’ ancillary conflict of interest procedures or documents. 
  • Conducts review and planning with FINRA Technology in the prioritization and implementation of the road-map for enhancements and new development for the Conflicts of Interest Certification (COIC) system used by the Regulatory Departments.
  • Serves as the subject matter expert for Internal Audit and SEC oversight inspections of the Ethics Office, as well as OCIE Inspections of other FINRA offices, on FINRA’s cross-departmental conflicts policies. Participates in and organizes documentation for responses to the SEC Office of Compliance and Inspection, including annual reports under FSIO or other similar SEC programs.
  • Provides direction to the other Ethics Office Advisory & Communications team members on all activities associated with the conflict of interest programs, including coaching Advisory staff on conflict policy requirements,  determining appropriate responses to employee questions and help-line matters, reviewing annually the conflict of interest sections of the Code and supplemental guidance documents for accuracy, involvement in enterprise-wide training and communication efforts, and management of conflicts program periodic certifications and other recurring activities, and related responsibilities as directed by the Ethics Director.   
  • Special projects, as assigned.
  • Maintains strict confidence while performing duties and responsibilities.

Education/Experience Requirements:

  • Law degree and admission to the bar.  Top academic credentials.
  • A minimum of six years’ experience in a legal compliance or ethics, investigator, and/or analytical capacity, preferably in a regulatory environment; corporate ethics and compliance program experience highly desirable.
  • Excellent oral/written communication, critical thinking, research and analytical skills.
  • Project management experience desirable. 
  • Experience handling sensitive or confidential information.
  • Working knowledge of financial services accounts and securities products highly desirable.
  • Must have demonstrated experience effectively managing multiple deadlines and priorities; excellent organizational skill is required.
  • Ability to function effectively in a team environment is required.
  • Proficiency in the use of Microsoft Word, Microsoft Excel and Microsoft Outlook required; experience with Microsoft Access or other database software, as well as Microsoft PowerPoint and Adobe Acrobat, is preferred.

Work Conditions:

  • Normal office environment; work outside normal business hours sometimes required; occasional travel required.
  • Membership in an ethics and compliance industry association will be provided.

Company info

FINRA.

Company Profile

FINRA is an independent, non-governmental regulator for all securities firms doing business with the public in the United States. FINRA works to protect investors and maintain market integrity in a public-private partnership with the Securities and Exchange Commission (SEC), while also benefiting from the SEC’s oversight. In its role as investor guardian, FINRA is informed, but not influenced, by the industry that it regulates. FINRA’s independent regulation plays a critical role in America’s financial system–all at no cost to taxpayers. FINRA touches virtually every aspect of the securities business—from registering and educating industry participants to examining securities firms; writing rules; enforcing those rules and the federal securities laws; informing and educating the investing public; providing trade reporting and other industry utilities; and administering the largest dispute resolution forum for investors and registered firms. FINRA uses technology powerful enough to look across markets and detect potential abuses. Using a variety of data gathering techniques, we work to detect insider trading and any strategies firms or individuals use to gain an unfair advantage.

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