Patricia Cerny
Downers Grove,IL
Summary
Detail-oriented Compliance Officer dedicated to improving policies and procedures in all business areas. Hardworking and driven with quality-focused and proactive approach. Bringing 25+ years of experience in the securities industry.
Overview
34
34
years of professional experience
Work History
Independent Compliance Consultant & Owner
Command Line Compliance, Inc.
03.2015 - Current
- Independent compliance consultant serving registered broker-dealers including proprietary, market-maker and agency execution firms
- Formed Command Line Compliance, Inc
- (“CLC”) in 2017, a boutique compliance consulting firm offering services for registered broker dealers and futures trading firms
- CLC provides compliance related services in the following areas: develop and maintain written supervisory procedures, implement internal surveillance reviews and controls; assist newly formed entities through the FINRA new membership process; conduct independent AML reviews, assist new entities forms a broker-dealer through the process of filing Form BD with the SEC and obtaining Exchange and/or FINRA membership
- Provide Chief Compliance Officer services and ongoing support of a Firm’s compliance program (e.g
- Maintain WSPs, conduct internal surveillance of trading activities, respond to regulatory inquiries and FINRA exams, support CAT audit trail reporting and FINRA registration services
- Refer to the Firm’s website — www.commandlinecompliance.com for detailed information regarding services provided.
Chief Compliance Officer & AML Officer
CITIGROUP
01.2005 - 03.2015
- Manage the compliance program for one of the top five (5) derivatives trading firms consisting of a $1 billion portfolio of equity, index, energy, agricultural, notes, bonds and currency options, futures, ETFs and other related products
- Oversee and enforce all aspects of the Firm’s business related to electronic and CME floor trading to ensure compliance with internal standards, SEC, CFTC, CME, ICE Europe and US Exchange regulations
- Answer compliance questions and provide guidance with respect to the regulatory implications of new business strategies or investments
- Complete annual compliance exams(s) and audits pursuant to CBOE, CME and US Options Exchange Rules
- Conduct TAG 50 and CTI code reviews to ensure the integrity of the Firm’s audit trail
- Administer the Firm’s general books & records retention program for trading related documents
- Prepare written reports, review internal testing results and present final written material/results to Chief Operating Officer
- Develop and enhance surveillance reports to monitor the Firm’s electronic trading related to market access and high frequency type trading rules
- Developed real time position limit monitoring report for commodity products; Monitor position limits, process hedge exemption requests for CME products as applicable; Respond to desk inquiries regarding derivative rules, position limit, block trades and EFRPs; Draft compliance manuals, training materials and policy statements, compliance bulletins and rule interpretation(s)
- Evaluate new rules/regulations and apply to current business lines; modify written supervisory procedures and controls to meet regulatory standards
- Respond to external regulatory inquiries; interact with senior government regulatory authorities and senior Exchange officers on a regular basis
- Execute project work for new business iniatives that involves interaction with all levels of colleagues across the Firm (i.e
- Trading, business development, legal, accounting and operations).
Compliance Officer
Automated Trading Desk Financial Services, LLC (Citigroup affiliate)
01.2005 - 01.2015
- Provide compliance support for the customer agency execution business
- Monitor clearing corporation position movements, error account and client accommodation trades
- Assist in the opening of client accounts, perform AML checks, maintain KYC policies and procedures and conduct surveillance of equity and derivatives execution business
- Review client sales literature as needed
- Assist the Chief Compliance Officer with the annual testing and certification process for SEC Rule 15c3-5 (market access)
- Research and respond to customer complaints, process regulatory inquiries and financial/operational oversight exams.
Chief Compliance Officer
Citadel Investment Group
01.2004 - 01.2005
- Chief Compliance Officer for broker dealer and hedge fund trading activities
- Supervised a staff of four (4) compliance professionals that were responsible for administering the Firm’s compliance programs for the securities, fixed income, investment advisory and commodities business lines
- On boarded new hedge fund investors, processed applications, conducted AML/KYC reviews.
Director of Market Regulation
Chicago Board Options Exchange; CBOE Futures Exchange
01.1990 - 01.2004
- Managed a team of ten (10) professional staff with respect to enforcing SEC, CFTC and Exchange Rules
- Drafted examination reports, Exchange rule filings and regulatory circulars
- Developed the surveillance and compliance program(s) required to achieve CFTC approval to launch the CBOE Futures Exchange
- Developed new surveillance procedures or enhanced existing surveillance programs to enforce Exchange Rules
- Member of the Intermarket Surveillance Meetings (“ISG”) a working group comprised of domestic and foreign regulators
- Collaborated with the ISG to implement new processes to achieve consistent regulatory and surveillance policies across boarders
- Worked with the ISG sub-group to develop and implement a Consolidated Audit Trail for derivatives products across US markets
- Completed a rule change at the SEC level to adopt an industry wide delta-based position limit approach for derivative products.
Education
Bachelor of Arts - Business
Depaul University
Chicago, ILSkills
- Securities Licenses held: 4, 7, 14, 24, and 57
- Internal Controls
- Compliance Monitoring
- Compliance Reporting
- Audit & Exam Coordination
- Development of Internal Surveillance Processes
Timeline
Independent Compliance Consultant & Owner
Command Line Compliance, Inc.
03.2015 - Current
Chief Compliance Officer & AML Officer
CITIGROUP
01.2005 - 03.2015
Compliance Officer
Automated Trading Desk Financial Services, LLC (Citigroup affiliate)
01.2005 - 01.2015
Chief Compliance Officer
Citadel Investment Group
01.2004 - 01.2005
Director of Market Regulation
Chicago Board Options Exchange; CBOE Futures Exchange
01.1990 - 01.2004
Bachelor of Arts - Business
Depaul University
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