Principal Counsel, Ethics
- Washington, DC
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 FINRAâ€™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.Â
- 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 FINRAâ€™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 attorneyâ€™s responsibility.
- Independently conducts comprehensive investigations of potential violations of the conflicts of interest policies and related violations of FINRAâ€™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 Departmentâ€™s specific regulatory programs.
- Serves as source of expertise on one or more areas of FINRAâ€™s Ethics Program.
- Serves as liaison to senior managers of all FINRA Regulatory Departments regarding FINRAâ€™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 departmentâ€™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.Â 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 departmentâ€™s ongoing compliance with the Policy.
- Serves as enterprise-wide liaison for the FINRA Former Employee Review Policy.Â Provides expert interpretive guidance to all FINRA departments regarding the Policy, reviewing compliance by FINRA departments with the Policy, and providing direction to FINRAâ€™s HR and Registration and Disclosure departments regarding required tasks under the Policy. Â 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.Â Responsible for creation of guidance materials.Â
- Serves as the primary attorney responsible for the â€Revolving Doorâ€ policy underpinning the relevant FINRA Rules, the related guidance materials and training programs.Â Provides interpretive guidance to both external and internal constituents, including former employees, member firms, and current senior managers and employees, the Ombudsmenâ€™s office, and Corporate Communications.
- Primary attorney responsible for independently advising regulatory departments on FINRAâ€™s overarching Conflicts of Interest Policy, including working closely with departmentsâ€™ 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 departmentsâ€™ ancillary conflict of interest procedures or documents.Â
- 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 FINRAâ€™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,Â 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.Â Â
- Special projects, as assigned.
- Maintains strict confidence while performing duties and responsibilities.
- Law degree and admission to the bar.Â Top academic credentials.
- A minimum of six yearsâ€™ 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.Â
- 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.
- Normal office environment; work outside normal business hours sometimes required; occasional travel required.
- Membership in an ethics and compliance industry association will be provided.
To be considered for this position, please submit an application.
The information provided above has been designed to indicate the general nature and level of work of the position. It is not a comprehensive inventory of all duties, responsibilities and qualifications required.
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FINRA strives to make our career site accessible to all users. If you need a disability-related accommodation for completing the application process, please contact FINRAâ€™s accommodation help line at 240.386.4865. Please note that this number is exclusively for inquiries regarding application accommodations.
In addition to a competitive salary, comprehensive health and welfare benefits, and incentive compensation, FINRA offers immediate participation and vesting in a 401(k) plan with company match. You will also be eligible for participation in an additional FINRA-funded retirement contribution, our tuition reimbursement program and many other benefits. If you would like to contribute to our important mission and work collegially in a professional organization that values intelligence, integrity and initiative, consider a career with FINRA.
FINRAâ€™s Code of Conduct imposes restrictions on employeesâ€™ investments and requires financial disclosures that are uniquely related to our role as a securities regulator. FINRA employees are required to disclose to FINRA all brokerage accounts that they maintain, and those in which they control trading or have a financial interest (including any trust account of which they are a trustee or beneficiary and all accounts of a spouse, domestic partner or minor child who lives with the employee) and to authorize their broker-dealers to provide FINRA with duplicate statements for all of those accounts. All of those accounts are subject to the Codeâ€™s investment and securities account restrictions, and new employees must comply with those investment restrictionsâ€"including disposing of any security issued by a company on FINRAâ€™s Prohibited Company List or obtaining a written waiver from their Executive Vice Presidentâ€"by the date they begin employment with FINRA. Employees may only maintain securities accounts that must be disclosed to FINRA at one or more securities firms that provide an electronic feed (e-feed) of data to FINRA, and must move securities accounts from other securities firms to a firm that provides an e-feed within three months of beginning employment.
You can read more about these restrictions here.
As standard practice, employees must also execute FINRAâ€™s Employee Confidentiality and Invention Assignment Agreement without qualification or modification and comply with the companyâ€™s policy on nepotism.
Search Firm Representatives
Please be advised that FINRA is not seeking assistance or accepting unsolicited resumes from search firms for this employment opportunity. Regardless of past practice, a valid written agreement and task order must be in place before any resumes are submitted to FINRA. All resumes submitted by search firms to any employee at FINRA without a valid written agreement and task order in place will be deemed the sole property of FINRA and no fee will be paid in the event that person is hired by FINRA.
FINRA is an Equal Opportunity and Affirmative Action Employer
All qualified applicants will receive consideration for employment without regard to age, citizenship status, color, disability, marital status, national origin, race, religion, sex, sexual orientation, gender identity, veteran status or any other classification protected by federal state or local laws as appropriate, or upon the protected status of the personâ€™s relatives, friends or associates.
FINRA abides by the requirements of 41 CFR 60-741.5(a). This regulation prohibits discrimination against qualified individuals on the basis of disability, and requires affirmative action by covered prime contractors and subcontractors to employ and advance in employment qualified individuals with disabilities.
FINRA abides by the requirements of 41 CFR 60-300.5(a). This regulation prohibits discrimination against qualified protected veterans, and requires affirmative action by covered prime contractors and subcontractors to employ and advance in employment qualified protected veterans.
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