Gary Swiman

226 West Rittenhouse Square apt 605

Philadelphia, PA 19103
11 East 1st Street Apt 714 (New York address)
New York, NY 10003
215 -847 6730 (cell) g.swiman@yahoo.com

PROFESSIONAL EXPERIENCE
Navigant Consulting, Inc. Aug 2008- Present
Associate Director- Regulatory Advisory Services Practice
* Responsible for leading teams responsible for conflicts of interest studies, d
ue diligence reviews, AML program assessments and remediation, compliance progra
m development including the drafting Compliance policies and procedures and eval
uation, and providing a wide- array risk assessment services to Investment compa
nies, Investment Advisors, Sponsors of registered and unregistered funds to ens
ure compliance with Rules 38a-1 and 206(4)-7 as applicable, Business Development
Companies, Hedge funds and Broker- Dealers including the performance of five 3
012 certifications in fiscal year in 2009.
* Responsible for assisting clients in responding to and preparing for regulator
y examinations and inquiries requiring forensic analyses and presentations to re
gulators along with conducting numerous reviews to satisfy SEC Consent order req
uirements.
* Responsible for design and implementation of government/oversight frameworks.
This includes assisting clients develop, enhance and implement compliance progra
ms as well as supporting operations and associated internal controls testing pro
grams, risk assessment methodologies, the performance of detailed forensic testi
ng and transaction/ financial statement reconciliations and other books and rec
ords.
* Responsible for business development and marketing which resulted in approxima
tely $2,000,000 in incremental revenue in fiscal year 2009.
* Responsible for presentations to Firm's Board of Directors as requested by cli
ent. Presented to client Board's four times in fiscal year 2009.
* Responsible for leading all formation , structuring , launching of start-up He
dge funds including the drafting, reviewing , negotiating of , offering memorand
a, operating agreements, investment management and advisory agreements, subscrip
tion documents, custodial agreements, prime brokerage agreements , as well as lo
an , security agreements and financing documents.
* Manage a staff of twenty five professionals.
* Published numerous articles on Regulatory topics available upon request

Aberdeen Asset Management Inc, Philadelphia, Pa

Oct 2007- May 2008
Chief Compliance Officer- Open End funds, Closed End Funds, Investment Advisor,
and Broker Dealer
* Responsible for Firm's compliance with Rule 38a-1 for both open-end and closed
-end funds under the Investment Company Act of 1940.
* Responsible for Firm's compliance with Rule 206(4)-7 under the Investment Advi
sor's Act of 1940.
* Responsible for the formation of a new limited purpose Broker- Dealer utilized
to facilitate the distribution of Open end and Close-end Funds and Private Plac
ements.
* Responsible for the drafting and implementation of the firm's Broker-Dealer ma
nual, Investment advisor manual, Open end Mutual fund Manual, and the Firm's Clo
sed end fund manual.
* Report to CEO of the United States as well as directly to the Board of Directo
rs.
* Manage staff of fifteen compliance professionals.
* Firm's designated AML officer.
* Responsible for all aspects of Firm training including annual and as needed sy
stem training on systems such as Charles River, Advent, Bloomberg, Longview.
Evercore Partners, New York, NY Nov 2006- August 2007
Chief Compliance Officer- Broker Dealer, Investment Advisor and Private Equity D
ivision
* Responsible for development of overall compliance program including the drafti
ng of compliance supervisory manual and supervisory processes for both the broke
r dealer as well as the investment advisor for leading investment banking boutiq
ue broker- dealer and asset manager which provides advisory services on mergers,
acquisitions and other strategic corporate transactions, as well as engages a s
eparate entity to manage client assets. Responsible for NASD Rule 3012-3013 comp
liance including presentation to the Board of Directors. Prepared annual Firm El
ement training.
* Implemented investment management compliance program to comply with Section 20
6(4)-7 of the Investment Advisor's Act of 1940 for the firm's, Invest Management
division, Private Equity and Venture capital funds including presentation to th
e individual Board of Directors.
* Responsible for negotiating engagement letters, confidentiality agreements, in
demnification agreements and other business agreements as needed. Member of the
Firm's Fairness and Executive committee's.
* Responsible for all interaction with the SEC and NASD.

Merrill Lynch Pierce Fenner & Smith, New York, NY 2000 to 2006
Director Office of General Counsel

* Firm's designated AML officer. Implemented Mantas AML System including selecti
ng scenarios, responsible for final sign off on all SAR filings Set-up new CIP r
equirements across the branch network as well as set up a repository for all SAR
supporting documentation. Developed Firm element module yearly on AML given to
every registered person. Worked with FBI and Sec on 8 AML matters.
* Manage staff of ninety compliance and regulatory professionals in areas such a
s U.S training to forty thousand employees, internal branch examinations, and in
teraction with all regulatory bodies through Enforcement process, as well as, U.
S policies and procedures.
* Primary Firm liaison with the SEC, NYSE, NASD, CBOE State Securities Commissio
ners on all regulatory examinations. Accountable for timely response and resolu
tion of investigations.
* Negotiate with regulatory officials to reduce penalties against the Firm for r
ule violations.
* Report to the heads of Global Compliance and Global Regulatory Affairs on all
regulatory
issues and provide guidance to Firm's Senior Management including reporting to t
he MLPF's Board of directors annually.
* Represent senior business executives before the SEC, NYSE and NASD in matters
involving formal and informal testimony. Educate executives and Compliance Depa
rtment on new and existing policies as they relate to business practices.
* Testify on behalf of the Firm on regulatory topics before Enforcement and Mark
et surveillance areas of SEC and SRO's.
* Authorize all new compliance policies and changes to pre-existing policies. R
esponsibilities include drafting upwards of 100 original policies per year on be
half of Global Compliance Department, thereby ensuring adherence to rules and re
gulations.
* in setting the direction of the Firm's Office of General Counsel as it relate
s to policy structure and personnel, via membership in the Office of General Cou
nsel Operating Committee.
* Appointed to the Firm's Acquisition Committee with was charged with responsib
ilities of determining adequacy of a newly acquired Firm's books and records an
d ensuring all processes are regulatory compliant prior to finalization of acqui
sitions.
* Advise firm's media relations department in their dealings with the financial
press as relates to regulatory incidents.

Gary Swiman Page 2

Nomura Securities, New York NY 1995-1997, 1998-2000
Director of Internal Audit; Assistant Director of Compliance
* Responsible for Audit Departments based in United States and London. Served a
s primary regulatory contact for compliance side of business.
* Managed relationships with key regulators and drafted compliance policies.
* Appointed to the Firm's Global Audit and Global Compliance Management Committe
es.
* Dually reported to US Chief Executive Officer and Japan's Director of Complian
ce.
* Supervised staff of thirty professionals based in multiple offices throughout
the U.S. and Europe
Bright Trading / Smith Barney, Scottsdale, Arizona 1997
Director of Compliance
* Managed all aspects of Compliance Department including adherence to all applic
able equity trading rules and regulations.
* Extensive interaction with NASD Market Regulation.
Price Waterhouse LLC, New York, NY 1993 to 1995
Senior Securities / Broker Dealer Audit Group
* Senior Accountant- Broker/Dealer Audit
Deloitte Haskins and Sells, New York, NY 1987 to 1990
Senior Accountant, Broker Dealer Audit Group

CREDENTIALS
Juris Doctor (JD) Certified Public Accountant (CPA).
Securities licenses: 7,8,3,4,14,16,24,27,55,63,65.
CFE, CFF, CAMS certified

EDUCATION
Juris Doctor, Fordham Law School, 1993
Graduated Cum Laude * GPA 3.65
Bachelor of Business Administration, Hofstra University, 1987
Graduated Magna Cum Laude * GPA 3.85 * Public Accounting Major

References available upon request.