RIA Code of Ethics Compliance Manager

  • Competitive
  • New York, NY, USA
  • Permanent, Full time
  • New York Life Insurance Company
  • 19 Jan 18 2018-01-19

RIA Code of Ethics Compliance Manager

New York Life Insurance Company ("New York Life" or "the company") is the largest mutual life insurance company in the United States*. Founded in 1845, New York Life is headquartered in New York City, maintains offices in all fifty states, and owns Seguros Monterrey New York Life in Mexico.

New York Life is one of the most financially strong and highly capitalized insurers in the business. The company reported 2016 operating earnings of $1.954 billion. Total assets under management at year end 2016, with affiliates, totaled $538 billion. As of year-end 2016, New York Life's surplus was $23.336 billion**. New York Life holds the highest possible financial strength ratings currently awarded to any life insurer from all four of the major ratings agencies: A.M. Best, A++; Fitch AAA; Moody's Aaa; Standard & Poor's AA+. (Source: Individual Third Party Ratings Report as of 8/17/16).

Financial strength, integrity and humanity-the values upon which New York Life was founded-have guided the company's decisions and actions for over 170 years.

General Profile

This position within the Wealth Management division of New York Life will primarily lead a team of three and administer the regulatory compliance programs of the Registered Investment Advisor, Eagle Strategies.

  • Administer the Code of Ethics and personal trading program for Eagle Strategies for over 1800 individuals. This includes preclearance, blackout periods, quarterly certifications, personal statement reviews, data feed and system maintenance for Sungard PTA, training for the Field and Field Management, implementing new regulatory guidance, etc.
  • Maintain Form ADV Part2 (including Eagle's Firm and Wrap Fee Brochures, over 1,000 Form ADV Part 2Bs-for each Advisor, training for the Field, and annual mailings to Eagle clients) in compliance with SEC Rule 204-3.
  • Manage a team of 3 associates to administer Eagle's regulatory compliance programs and support Eagle's business initiatives. Set objectives for the team and provide guidance regarding job functions and projects to achieve operational excellence. Identify process improvements and develop strategies for execution. Develop a collaborative team focused on leadership, process improvements and risk mitigating controls. Handle escalated calls/issues.
  • Work closely with OGC, CCD, Senior Management and other business partners to create consensus and develop policies that align with regulatory requirements and business objectives.
  • Act as Subject Matter Expert for Eagle Strategies for a variety of intra-New York Life departments including Agency, Service, OGC, CCD, Field Management and broader Field force.
  • Develop and maintain Eagle's Policies and Procedures Manual (including appropriate policies and procedures for new product initiatives and regulatory requirements).
  • Manage Eagle's regulatory training materials (such as the annual Firm Element and Advisor Questionnaires) and track the advisors' completion of each.
  • Oversee the third party biennial audits of NYL's independent RIAs (including coordinating the audits and working with the Advisors to ensure recommendations are implemented).
  • Assist with the continued development of Eagle's portion of Agency Standards' supervisory interview and inspection (SII) form (so that Agency Standards can conduct effective annual audits of Advisors).
  • Assist with Eagle's social media policy development and review for testimonial violations.
  • Conduct Eagle's quarterly best execution reviews for Eagle's LWP platform.
  • • Coordinate and review the completion of RR's Initial Adviser Questionnaires upon registering with Eagle Strategies.
  • Lead Eagle's Form ADV Part 2 mailing to 40,000+ clients, which includes contracting a 3rd party mailing vendor, compiling the mailing lists, and writing the materials that were distributed to clients.
  • Act as relationship manager with Sungard PTA, the 3rd party vendor we use for Code of Ethics monitoring, and manage the ongoing data maintenance and creation of quarterly certifications and questionnaires for Advisors and Elkins McSherry who compiles the data for our Best Execution review.
  • Present or develop Standards training modules for new Eagle Advisors at the Advisory Foundation Program as necessary.
  • Lead the annual coordination and renewal process of Eagle's D&O and E&O insurance coverage for Eagle and its executives.
  • Perform peer benchmarking through industry connections relative to specific policies as needed. Build business cases for any changes and execute according to plan.
  • Draft communications from the Standards team when necessary.
  • Maintain the Standards requirements calendar on Agency Portal.
  • Assist with ad-hoc departmental projects as needed.

Technical Expertise

Must be able to decipher various advisory regulations such as the Investment Adviser's Act of 1940, etc and apply concepts to the business unit by working with Counsel, Corporate Compliance and Senior Agency management. Must be able to create consensus for the business case for specific policies and procedures across the Eagle enterprise (not just Securities Standards). Also must maintain Form ADV Part2(Firm and Wrap brochures) which includes all discloures and descriptions for all programs. These brochures are disctributed to all Eagle clients and filed with the SEC.

Education & Experience

  • Series 7 required
  • Series 24 prefrred
  • Series 66 preferred or must be obtaineed within 6 months
  • Minimum of 5 years relevant experience
  • Bachelors Degree Required
  • Experience with compliance, advisory regulatory, Code of Ethics or operational risk experiece in Asset/Wealth Management


Manage a team of 3 registered individuals(Series 7 and 24 mostly) who are tasked with enforcing Eagle's regulatory programs such as SEC mandated Code of Ethics, Best Execution, and onboarding IARs.

Problem Solving

Will need to navigate the everchanging regulatory environement (DOL Fiduciary rule, etc) to ensure that our policies and procedures are adequate. This will require extremely challenging conversations with seasoned executives. Must be agile enough to make quick, thoughtful but difficult decisions.

Decision Making / Nature of Impact

Entitled to make decisions that affect the viability of the compliance programs of Eagle Strategies. Failure of any of these programs is a great risk to the existence of Eagle and to a certain extent NYLIFE Securities. Must also be able to justify recommending disciplnary actions to NYL RRs that may include up to termination.

Communication Requirements

Must be able to influence others and create consensus on topics that affect the following areas: OGC, CCD, Agency, Service, Eagle (Product, Operations, Standards, Commissions, Financial Planning, Marketing, etc). There is frequent, daily interaction with Executive Officers. Must have strong oral communications to present concepts and rational to stakeholders and Eagle IARs.


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* Based on revenue as reported by "Fortune 500, ranked within Industries, Insurance: Life, Health (Mutual)," Fortune Magazine, June 17, 2016. See http://fortune.com/fortune500/ for methodology.
** Total surplus, which includes the Asset Valuation Reserve, is one of the key indicators of the company's long-term financial strength and stability and is presented on a consolidated basis of the company.

1. Operating earnings is the key measure use by management to track Company's profitability from ongoing operations and underlying profitability of the business. This indicator is based on generally accepted accounting principles in the US (GAAP), with certain adjustments Company believes to be appropriate as a measurement approach (non GAAP), primarily the removal of gains or losses on investments and related adjustments.

2. Assets under management represent Consolidated Domestic and International insurance Company Statutory assets (cash and invested assets and separate account assets) and third party assets principally managed by New York Life Investment management Holdings LLC, a wholly owned subsidiary of New York Life Insurance Company.