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COMMENT LETTERS - REGULATORY COMPLIANCE INFORMATION

Paige W. Pierce - Biography (posted for 2018 FINRA Board Election)

PAIGE W. PIERCE    paige@paige-pierce.com | (801) 733-9909

Biography
Paige W. Pierce brings over 30 years of senior level investment industry experience with small firms and major corporate entities in the North American capital markets to her regulatory and business development work with Larimer Capital. She has extensive trading and sales, compliance, operational, financial control, business management and regulatory compliance consulting, as well as strategic partner development experience both domestically and internationally. 

Ms. Pierce is known as a leader of leaders who has made a difference by seeing landscapes in ways no one else can. She has played principal roles in multiple startups, guiding them to profitable exits, and realized equal success turning around underperforming organizations and helping growing concerns figure out “What’s next?” In addition to her work with Larimer Capital, Ms. Pierce helps small businesses overcome efficiency and growth obstacles and assists clients in navigating regulatory compliance challenges.  She is further an in-demand strategist working with securities counsel and industry member clients on FINRA-related inquiries, investigations and enforcement matters.

Nowhere is Ms. Pierce’s ability to navigate changing markets more apparent than with her tenure at RW Smith & Associates, a Fixed Income Interdealer Broker (IDB). A Founding Principal of the firm, she returned to the business as a consultant in 2001, positively resolving a critical regulatory issue and revamping compliance in the wake of the 2001 recession and the regulatory repercussions of the Arthur Andersen scandal.

As President & CEO of RW Smith (2005 to 2017), and in previous leadership roles (2001 to 2004), Ms. Pierce responded to downward margin pressures and an unfavorable regulatory environment by leading the evolution of both the firm’s business model and the regulators’ view of small firms. Internally, she resolved market and cash flow challenges by twice negotiating the sale of the firm, once to a venture capitalist and later in parts to complementary businesses. She also revamped product offerings to increase top-line sales 600%.

On the regulatory and legislative front, Ms. Pierce spent the better part of 20 years advocating on behalf of small firms with purpose and passion, working to advance regulatory and legislative understanding of these important market participants and the challenges they face. Currently, she is working tirelessly on behalf of small firms leading the effort in Washington, DC working with Congress, the SEC, PCAOB and FINRA, amongst others, to obtain exemptive relief for small, non-public, non-custodial brokers and dealers from PCAOB audits.

As an advocate for small businesses, Ms. Pierce has been invited to the Federal Reserve, offices of State and Congressional legislators, the Securities and Exchange Commission, FINRA and other regulatory agencies, and has been included in many important policy discussions. She was the first IDB representative in many FINRA groups, including the National Adjudicatory Council, Fixed Income Committee, and Small Firm Advisory Board, the latter as elected Chair in 2017.

Ms. Pierce also organized previously siloed firms, contributing actively to professional organizations and co-founding the BMA/SIFMA Municipal Securities Broker’s Broker Committee, the Municipal Bond Information Service company, and the Bond Dealers of America Small Firm Division.She has built unique and lasting relationships through the course of her career.

Ms. Pierce was the CFO, Operating Officer, and a Founding Principal of Agincourt, Ltd. (1994 to 2000), a Bermuda-based broker/dealer focused on creating structured products for the fixed income institutional market. She spearheaded the creation of strategy, financial controls, and systems overseeing Bermuda-, UK-, and US-based activities for this Bermuda-based broker/dealer, ultimately engineering a successful exit.

An early career in banking and finance formed the foundation of Ms. Pierce’s lead-from-the-front style. Her approach led to repeated promotions and upward recruitment. Representative accomplishments include the recapture of millions of dollars for two of LaSalle Bank’s operating units, the transformation of one of their cost centers into a profit center, and success in PaineWebber’s fast-paced, high-stakes Municipal Trading Division. 

Ms. Pierce is an active member of YPO (Young President’s Organization) and is an Honorary Commander and Falcon with the 388th FW out of Hill Air Force Base in Utah, supporting the airmen/women who serve our great country. 

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REGULATORY ADDENDUM

Advocacy with Regulators and Legislators

Ms. Pierce has significant regulatory and legislative experience lobbying members of U.S. Congress, Congressional staff, and regulators, and has vast Executive Committee experience serving on numerous corporate, regulatory, and industry association boards, committees, and councils. She is also a frequent speaker and panelist at industry events.

H.R. 6021 / S. 3004 – the Small Business Audit Correction Act: Leading the 2017-18 Congressional and regulatory effort to obtain an exemption for small, non-public, non-custodial FINRA member firms from the requirement to use a PCAOB-registered audit firm for our annual audits.

National Council of Insurance Legislators: Testified in 2018 support of the resolution to advance H.R. 6021 and S. 3004 in Congress.

FINRA:

Small Firm Advisory Board (2016 to Present, Chair 2017): As chair, and first IDB on Board, revamped process to send unified message from small firms and enable action on FINRA’s part. Provide rigorous review of all regulatory initiatives brought before the SFAB. Ensure small firm interests are communicated to the FINRA Board of Governors. First IDB elected.

National Adjudicatory Council (2013 to 2015, 2018 to Present): Represent 3400+ small firm members reviewing all disciplinary hearing panel decisions on NAC. (Should I be elected to the Board, I will resign my position on the NAC.)

Fixed Income Committee (2010 to 2016): Member of FINRA Fixed Income Committee advising on regulatory initiatives, rules and policies, and public policy issues concerning fixed income transactions, fixed income market participants, transaction reporting, transparency and pricing, suitability, and more within the debt securities business. First IDB.

District 3 Committee (2016 to 2018, 2008 to 2010, Chair 2010): Curated and communicated industry trends and regulatory concerns to FINRA, providing feedback on proposed policies and rule changes, and serving on disciplinary hearing panels.

Additionally, frequent speaker and panelist at industry events and represent the Small Firm sector of the investment industry in meetings with the Chair and Governors of the Federal Reserve, members of Congress, SEC Commissioners, FINRA, the MSRB, and other regulatory agencies.

BMA (Bond Market Association)/SIFMA (Securities Industry & Financial Markets Association) Multiple Committees (2005 to 2017): Municipal Executive Committee, Municipal Executive Steering Committee (Elected 2008-11, 2015-17), Municipal Operations Committee, Membership Committee (Chair), Small Firms Committee, Emergency Markets & Calendar Committee, Interdealer Advisory Committee.

SIFMA Co-founder of Municipal Securities Broker Committee (2006 to 2017, Chair 2008 to 2011, 2015 to 2017): Unified players in highly competitive industry in order to build and manage important relationships with regulatory agencies. Built shared resources for business development and an industry resource for up-to-date regulatory information, including proposed and final rules.  

Bond Dealers of America (BDA) Small Firm Division: Executive Committee Member (2016 to 2017): Co-founded BDA Small Firm Division to provide direct regulatory and legislative advocacy in Washington, DC for smaller (<150 employees) firms in the US fixed income markets.

National Association of Independent Broker Dealers (NAIBD)Executive Committee Member (2014 to 2017): Worked with the board to redefine the NAIBD and its role within the investment industry. Directed Board on implementation of improved corporate governance standards.

Municipal Bond Information Services (MBIS): Founding Member, Regulatory Affairs Committee Member (2013 to 2017): Worked to create a consortium of municipal interdealer brokerage firms in order to aggregate market data generated to improve municipal market price transparency.

Director Experience: RW Smith & Associates, Municipal Bond Information Services, Bond Dealers of America/SFD, TWL Holdings, Young Presidents' Organization/Utah, RWS Acquisition Corp., National Association of Independent Broker Dealers, CHOICE Humanitarian, and Judge Memorial High School.


 

Paige Pierce