Q&A: Patrick O'Leary, Compliance, BNP Paribas

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Describe your career path.

I graduated from law school in 1999 and took a job working at the SEC in corporate finance. I spent three years there; my job was reviewing documents when companies went public. I had an associate who had joined a start-up hedge fund that needed an assistant trader. So I joined the fund, spending three years as an assistant bond trader responsible for a convertible bond arbitrage portfolio. In 2005, following a market correction in convertible arbitrage, the fund lost its funding and shut down. I began to look for a compliance role that would allow me to combine my legal and trading backgrounds. I joined CooperNeff Advisors in King of Prussia, Pa. as a compliance officer in September, 2005. My job was to provide compliance support for the firm and BNP Paribas Asset Management for hedge funds and traditional asset managers. When CooperNeff, which focused on convertible arbitrage trading for hedge funds was reorganized, bond trading for the firm was shifted to New York. I then became a compliance officer for BNP Paribas, covering asset management and fund administration.

Describe your role at BNP Paribas.

I am a compliance officer responsible for asset managers within BNP Asset Management and a fund administrator, BNP Paribas Financial Services. My job is akin to that of a referee -- overseeing traders to make sure rules are followed. I work with two types of investment strategies for our asset manager: U.S. large cap equities, and European investment grade and sovereign bonds. My job is making sure our SEC compliant program is in place and evaluating best execution on a regular basis, specifically determining whether we are getting best value for client trades. Finally, I work on anti-money laundering, "Know your Customer," which is gathering documents on clients prior to accepting them. For instance, we need to make sure a client has the authority to enter into contract with us.

What is a typical day like for you?

About a quarter of my day is spent responding to questions from traders and our sales team. A lot of my job entails being a resource for people. It's important that I interact with each team, so that questions about compliance can be answered. I need to be sensitive to the needs of the business. I'll also spend time reviewing trades, which involves downloading trades in equity portfolios to make sure that, for example, if shares of a particular equity are purchased for three different client accounts that they are split properly. I'll review marketing presentations to make sure we are compliant with SEC rules concerning returns and check to see that the right disclaimers are present. And periodically I'll review client reporting. For example, with a mutual fund client, we'll compile reporting and evaluate whether the fund complies with the Investment Company Act. I also spend time reporting to our home office in Paris. Often, they'll send us documents or questionnaires to complete, about whether any compliance events have occurred, the number of clients we have, and various other reporting. BNP Paribas wants to makes sure we have an efficient compliance program in place. We'll also meet regularly with the bank's internal controls committee. We're meeting with them next week, and it will bring together business and compliance people in the U.S. to meet with senior management from Paris.

How has the world of compliance changed compared with when you first started?

Due to the increase in regulation and scrutiny of investment advisors, compliance professionals need to be vigilant and make sure business is being conducted appropriately. We're the gatekeepers -- the ones who need to have the answers if there is an audit.

What advice do you have for an up and coming compliance professional?

Practical experience is important, as it's difficult to find experienced compliance people who have this level of knowledge of markets and securities. It's especially important at BNP Paribas because of the complexity of the trades we administer for hedge funds. The top priority is to serve clients, so you need to be practical. Ideally, rather than simply telling businesspeople a particular business can't be done, compliance professionals work with the business to roll-out a particular offering in a way that is compliant with applicable regulations.

What should people wanting to work in compliance be doing to prepare?

In Philadelphia, there is a compliance roundtable, which is a free semi-annual meeting of compliance professionals. Participating in groups such as these allows you to meet with similar professionals, share ideas, and gain insights on important issues in the world of compliance.

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