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 assisting with 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 professional level work in which the incumbent is defining their assigned roles, increasing their skills, and working under general guidance of senior attorneys.
Essential Job Functions:
- Interacts with mid-level managers and employees in all departments across the company regarding complex conflicts of interest questions raised to the Ethics Office, and logs interactions in accordance with Office procedures.
- Escalates conflicts issues to the senior ethics attorney, Ethics Director and VP and presents possible outcomes; demonstrates increased proficiency in identifying patterns and systemic issues in the FINRA’s conflicts-of-interest policies and makes recommendations to the senior ethics attorney, Ethics Director and VP.
- With the support of the senior ethics attorney and Ethics Director, conducts comprehensive investigations of potential violations of the conflicts of interest policies and related violations of FINRA’s Code of Conduct, including participating in interviews with relevant players, creating draft summaries for case files, and working with relevant control departments to determine outcomes.
- Works to increase proficiency in the understanding of the various regulatory programs under FINRA’s responsibility, with a focus on two to three of the programs.
- Supports the Office’s maintenance of the FINRA Conflicts of Interest Waiver Policy applying to all FINRA regulatory departments; supports the senior ethics attorney in developing guidance materials, and demonstrates a growing understanding of the complexities of the policy’s application to the varying regulatory programs. Together with the senior ethics attorney, works closely with senior and mid-level managers in the regulatory departments regarding permissibility of proposed conflicts of interest waivers, evaluating inquiries and providing guidance to regulatory departments regarding the Policy’s requirements, reviewing the departments’ ongoing compliance with the Policy.
- Supports the Office’s enterprise-wide FINRA Former Employee Review Policy. Assists in drafting of related guidance materials. Demonstrates increased proficiency in evaluating and providing interpretive guidance to FINRA departments regarding the Policy. Together with the senior attorney, reviews compliance by FINRA departments with the Policy, and interfaces with FINRA’s HR and Registration and Disclosure departments regarding required tasks under the Policy.
- Supports the Office’s management of the “Revolving Door” policy underpinning the relevant FINRA Rules, the related guidance materials and training programs. This includes evaluating and providing interpretive guidance to former employees, member firms, and current senior managers and employees regarding applicability of the relevant FINRA rules.
- As directed by the senior ethics attorney, assists in the review and modification of FINRA’s overarching Conflicts of Interest Certification Policy and other conflict of interest procedures or documents used across the regulatory groups.
- 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.
- Works closely with other team members on all activities associated with the conflict of interest programs, including 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 management of conflicts program periodic certifications and other recurring activities, and related responsibilities as directed by the Ethics Director.
- Maintains strict confidence while performing duties and responsibilities.
- Law degree and admission to the bar. Top academic credentials.
- A minimum of two 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.
- Normal office environment; work outside normal business hours sometimes required; occasional travel required.
- Membership in an ethics and compliance industry association will be provided.