Bill leverages his examination expertise and relationships with state and federal regulators and self-regulatory organizations to guide broker-dealers and investment advisers through both proactive and reactive regulatory processes and compliance issues. Among others Bill conducts FINRA Rule 3120, Supervisory Control Reviews, Annual Compliance Reviews for federally and state-covered investment advisers, creates and/or updates policies and procedures for opening and monitoring senior and vulnerable adult client accounts, has been retained as an expert witness by law firms representing industry participants in arbitrations and regulatory matters, updates policies and procedures for both broker dealer and investment advisers, and acts as an independent third party in reviewing firm activity prior to and as a result of regulatory actions and settlements.
- Creates and/or updates policies and procedures for opening and monitoring senior and vulnerable adult client accounts, including the Disbursement Hold regulations adopted by FINRA and state securities regulators and reporting suspected financial exploitation, abuse or neglect to state securities commissions and adult protective services agencies for broker-dealers and investment advisers.
- Identifies policies and procedures for industry registrants and conducts due diligence on digital assets and distributed ledger firms.
- Retained as an expert in two arbitration cases to provide testimony that a broker dealer had conducted adequate and ongoing due diligence for a federally-covered investment adviser that was executing transactions for advisory clients via the broker dealers trading platform.
- Retained as an expert to provide testimony in an arbitration that a broker-dealer failed to follow procedures governing the use of Letters of Authorization.
- Retained as an expert in two arbitration cases to provide testimony that a broker dealer had conducted adequate and ongoing due diligence for an unregistered investment adviser that was executing transactions for advisory clients via the broker dealer’s trading platform.
- Retained in conjunction with a review by a federally-covered registered investment adviser to update the firm’s policies and procedures for registering investment adviser representatives with states and resolve unregistered activity with state securities regulators. Only one of 11 states which could have initiated formal action resolved the matter for a minimal fine against the firm.
- Retained by law firms, broker-dealers, investment advisers and individuals in regulatory matters related to potential cease and desist orders, fines, denial, restriction or revocation of registration, by negotiating the most beneficial resolution for the client(s).
- Retained by a broker-dealer that successfully obtained a waiver from the prohibition of concurrent dual registration of registered representatives with more than one broker-dealer from the Massachusetts Secretary of State.
- Conducts, during the course of and pursuant to regulatory settlements, third-party reviews of and makes recommendations for updating broker-dealer WSPs.
- Conducts gap analysis reviews and makes updates to the firm’s WSPs.
- Conducts gap analysis reviews and updates to Policies and Procedures Manuals for investment advisors, in the normal course of business and pursuant to regulatory settlements.
- Conducts FINRA Rule 3120, Supervisory Control Reviews.
- Conducts Annual Compliance Reviews for federally and state-covered investment advisers.
- Conducts independent third party and firm required branch office examinations for broker-dealers and investment advisers.
Florida Office of Financial Regulation
- Responsible for all aspects of the broker-dealer and investment adviser examination program which required the direct/indirect supervision of 50+ examination staff that conducted examinations, investigations and handled investor complaints.
- Led and participated in numerous national examination sweeps involving heightened supervision, books and records, free lunch seminars, penny stocks, auction rate securities, and structured products.
- Appointed by NASAA to be the state’s representative to work with the industry and SEC on the amendments to the books and records requirements of SEC Rules 17(a)-3 and 17(a)-4 which became effective in May 2003.
- Appointed by NASAA to be the initial state representative to the Content Committee for the Securities Industry/Regulatory Council on Continuing Education. created written scenarios for the Series 101, 201 and 206.
- Contributor to the NASAA model rule on the use of senior certifications and designations by individuals associated with broker-dealers and investment advisers.
- Appointed by former Florida Chief Financial Officer Alex Sink to the Safeguard Our Seniors Task Force with a mission to make recommendations to curb sales practice abuses by insurance industry professionals against seniors. After statewide hearings concluded, meaningful legislation to curb these abuses was passed by the Florida Legislature.
- Participated in a joint NASAA/SEC/FINRA initiative to identify “best practices” adopted by the industry to address the handling of accounts held by senior investors.
- Acted as Florida and NASAA liaison to AARP in the “Free Lunch” Monitor Program in which elderly “mystery shoppers” attended seminars and reported their concerns to state securities regulators for possible review of the broker-dealer.
- Co-creator and administrator for the Disciplinary Guidelines Rule and Sanctions Matrix for the Division of Securities, Office of Financial Regulation.
- Associate Director, Oyster Consulting, LLC
- Chief, Bureau of Securities Regulation, Division of Securities, Florida Office of Financial Regulation
- Co-Interim Director, Florida Division of Securities, 2010
- Chair, NASAA Broker-Dealer Operations Committee
- Frequent Speaker at industry and regulatory training programs and conferences, as well as Investor Outreach Programs
Education, Accolades and Affiliations
- Bachelor of Arts, Political Science, University of Florida
- Certified Financial Planner (CFP) Disciplinary Hearing Panel Member (2014)
- Advisory Board Member, Florida Securities Dealers Association 2013 – 2017
- Chair, Industry, Elder and Teen Financial Literacy Outreach Committees, Florida Securities Dealers Association 2015 – 2016
- State and Federal Legislative Committee, Florida Securities Dealers Association 2014 to present
- Industry Outreach Committee, Florida Securities Dealers Association 2017 – 2018
- NASD Phase I Examiner Training Program
- NASAA Outstanding Service Awards in 1996, 2001 and 2012
Publications and Presentations
Reg BI – The Care Obligation – Oyster Stew Podcast, October 23, 2019
Reg BI – Conflicts of Interest Obligation – Oyster Stew Podcast, October 16, 2019
Avoid Broker-Dealer Consolidated Enforcement Actions – Blog, August 8, 2019
FINRA Seeks Feedback on Business Continuity Plans – Blog Post, April 9, 2019
NASAA & FINRA Reports Point to Regulatory Expectations for Heightened Supervision – Blog Post, February 5, 2019
Digital Asset Regulatory Challenges – Bill Reilly and Don Horwitz, NSCP Currents Magazine, July, 2018
Practical Considerations for Firms with Clients in Digital Assets Markets – Blog Post, June 21, 2018
Digital Assets and State Regulatory Challenges – Blog Post, June 7, 2018
Cryptocurrencies and the Regulatory Challenges Around Them – Blog Post, May 29, 2018
State of Florida Offers Relief for Office Locations Affected by Hurricane Irma – Blog Post, September 13, 2017
The SECS 2017 Priorities: What They Are and What Compliance Professionals Need to Know– NSCP Currents, February, 2017.
NASAA Legislation – Protecting Vulnerable Adults from Financial Exploitation – Blog Post, February 25, 2016
Webinar: Creating and Executing Effective, Customized Branch Examinations September 15, 2016. NSCP/Oyster Consulting, Raymond James & Associates, Inc.