Preparing Private Funds for the Marketing Rule
In this episode, our team of private funds experts, John Gentile, Eugenie Warner and Adam DiPaolo, discuss how private funds will be affected by the new Marketing Rule and how they can start preparing for implementation now.
About Our Guest Speakers: 
John Gentile is responsible for overseeing various types of broker-dealer and investment adviser consulting engagements, including conducting SEC/FINRA internal control reviews, anti-money laundering testing, written supervisory policy and procedures testing, and other consultation services. John is a frequent speaker at industry conferences on various compliance topics, including “Effective Supervision,” “Large Firm Testing,” FINRA Supervisory Control Rules” and “Anti Money Laundering Requirements for Broker Dealers under the PATRIOT Act.” In 1987 John joined the SEC as a Securities Compliance Examiner, becoming a Branch Chief in 1991. He became Assistant Regional Director in 1993, supervising a team of 20 broker-dealer managers and examiners. He also planned and conducted financial, operational, and sales practice examinations of the largest broker dealers and was among those responsible for a review of hedge funds’ impact on broker dealer internal controls. Before joining the SEC, John was a Financial Damage Analyst with PaineWebber Inc. Most recently from 2000-2007 John was an Executive Consultant, Broker-Dealer Services, at National Regulatory Services. John has an MBA from Fordham University and a BS in Finance from Central Connecticut State University. From 1995 to 2002, John was also a member of the Securities Industry Continuing Education East Coast Content Committee.
Eugenie Warner is a Senior Consultant at CSS, bringing her legal background to the Compliance Services arena. She was previously a business litigator, including as an associate at K&L Gates LLP and Loeb and Loeb LLP. Eugenie focused on consumer protection defense, primarily against federal and state regulatory agencies in administrative, state, and federal tribunals. Additionally, she managed cases and litigated in the fields of intellectual property, employment, civil contempt, unfair business practices, and deceptive advertising. Eugenie earned a B.A. in Diplomacy and World Affairs from Occidental College in Los Angeles; and a J.D. from the University of Connecticut School of Law, where she was on the Connecticut Law Review; clerked for the United States District Court, District of Connecticut; clerked for Connecticut’s Office of the Attorney General, Antitrust Department; worked in the Criminal Clinic, Appellate Division; and studied at the University of Dublin Trinity College School of Law, for which she received UCONN’s Elihu Burritt academic success award. Currently, Eugenie’s compliance work includes, for example: annual reviews, risk assessments, mock SEC exams, and other tailored analyses; detailed registration and reporting guidance; assistance to CCOs and other C-suite executives, to enhance their respective compliance programs and risk management; and other tailored services.
Adam DiPaolo CISA, CRISC is a Section 13 Reporting Manager, Senior Consultant and Associate General Counsel at CSS. Adam designs practical solutions to manage regulatory challenges faced by hedge funds, private equity funds, funds of funds, and other investment advisers. In addition to providing compliance services such as annual compliance program reviews, risk assessments and acquisition due diligence, Adam established Section 13 reporting capabilities and EDGAR filing agent services for CSS's Compliance Services division. He drafts and maintains corporate filings ranging from Forms ADV and PF to Forms 13F and 13H. Adam also provides cybersecurity risk management services to CSS clients – ranging from network vulnerability scanning to onsite cybersecurity risk assessments to assistance in implementing the NIST cybersecurity framework. He is a Certified Information Systems Auditor (CISA®), and Certified in Risk and Information Systems Control (CRISC™). Adam practiced corporate law prior to joining CSS and has an extensive background in both the public and private sectors. Adam served as Assistant General Counsel at Capgemini – one of the world’s largest providers of Consulting, Technology and Outsourcing services. As in-house counsel to a global consulting business, he implemented pragmatic strategies to resolve complex legal and regulatory issues. Adam earned his B.A. from Pitzer College, his J.D. degree from UC Berkeley – Boalt Hall School of Law, and his LL.M. in Taxation from New York University School of Law. He is a member of the New York State Bar.
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