Tito Pombra is the founder and president of ACC. He has extensive experience in the global asset management industry, which includes 25 years in the investment company/investment adviser and international compliance areas. His areas of expertise include regulatory exams, outsourced CCO support, annual reviews, mock SEC exams, creating a strong culture of compliance, policies and procedures development, advertising and marketing reviews, NFA/CFTC compliance, and mentoring and training compliance professionals.
Before founding ACC, Tito was president of Core Compliance and Legal Services, where he led the compliance consulting practice to identify and execute new business strategies that resulted in significant new client acquisitions and growth. In addition, he provided proactive compliance advice to clients on Rule 206(4)-7, Rule 38a-1 and private fund compliance programs. He also established policies and procedures, completed annual reviews, and provided mock SEC exams, risk assessments and compliance training for a variety of investment advisers.
From 2005 to 2018, Tito served as chief compliance officer of Matthews International Capital Management, LLC (Matthews Asia) and Matthews International Funds (DBA Matthews Asia Funds). As CCO for Matthews Asia and Matthews Asia Funds, he was responsible for creating and managing the compliance and anti-money laundering programs of the investment company, investment adviser and offshore funds, and assisted with the compliance programs of Matthews Global Investors’ Hong Kong and U.K. registered broker-dealers. In addition, he oversaw the Matthews Asia Funds service provider’s compliance program under Rule 38a-1. During his tenure, Tito was also the AML Officer for the Matthews Asia Funds and MLRO for the Matthews Asia Funds (Luxembourg).
Tito has held various senior compliance and accounting positions at Franklin Templeton Investments and Dreyfus Funds. He graduated from Queens College in 1987 with a bachelor’s in accounting and economics.
Over the past 23 years, Tito has become a thought leader on compliance best practices. He is co-chair of the San Francisco Bay Area CCO Committee and a former member of the board of directors of the National Society of Compliance Professionals (NSCP) and the Investment Company Institute’s (ICI) CCO committee.
In 2008, Tito was named as a Top 20 Rising Star for “Who’s Who” in Upcoming Compliance Professionals by Compliance Reporter magazine. He frequently speaks at industry conferences, including those hosted by NSCP, Investment Company Institute, Investment Adviser Association, IA Watch and Private Equity Institute.
Julie Walsh is ACC’s director of SEC and NFA Compliance. She has more than 25 years of experience in the investment company/investment adviser and NFA/CFTC compliance areas.
Julie specializes in investment company and investment adviser regulatory compliance programs, as well as programs for commodity pool operators and commodity trading advisers. Her areas of expertise include regulatory exams, annual reviews, mock SEC exams, creating a strong culture of compliance, policies and procedures development, advertising and marketing reviews, and mentoring and training compliance professionals.
Her expertise benefits our clients as she develops compliance programs in an efficient and cost-effective manner. She often conducts gap analyses at the outset of relationships with new clients to capitalize on their existing regulatory/compliance programs (as relevant) and leverage any existing programs and infrastructure. She also engages these efforts in a cross-disciplinary manner — for various regulatory regimes when relevant. Julie is acutely aware that our clients’ core competence is investment management, and she works to judiciously administer programs that are robust and comprehensive and uninstrusive.
Prior to her work with ACC, Julie served as a managing director for more than nine years. During that tenure, she was designated as the outsourced fund CCO for four distinct investment company operations, including a closed-end private equity interval fund, and served as outsourced AMLCO for two open-end investment companies. In carrying out her fund officer delegations, Julie reported directly to each fund’s board of directors. During this time, she also founded the firm’s NFA/CFTC compliance program consultation offerings, and led efforts to train and supervise internal resources in this area.
Earlier in her career, Julie spent 15 years at a Boston-based institutional asset management firm where she served as global adviser CCO, headed the compliance team, and oversaw dozens of open-end investment companies, several hedge funds and private funds, and hundreds of separately managed, dedicated and asset allocation accounts in the institutional space, with assets under management totaling greater than $150 billion.
Julie has a Bachelor of Arts in English and a Master of Education in Secondary Education from Boston College. She is also a member of NSCP, NEBDIAA, SIFMA and ACAMS.
Giselle Casella is a senior compliance consultant at ACC. She has more than 20 years of SEC regulatory compliance experience with registered investment advisers.
Giselle provides outsourced CCO services to RIAs, as well as a full suite of compliance services, including annual compliance reviews, SEC mock audits, compliance testing, regulatory filings and disclosures, code of ethics administration, trade surveillance, policy drafting and updates, email and social media surveillance, compliance training, marketing material review and SEC examination support. She partners with compliance personnel, employees and third-party vendors to develop and oversee compliance programs tailored to each RIA’s unique business. She also currently serves as an adjunct professor at Utica College, where she teaches online graduate courses on compliance.
Giselle began her career in 1999 as an SEC investment adviser examiner. After the SEC, she spent nearly 10 years doing in-house compliance for various large, diversified financial institutions, including AIG, Prudential, UBS, Allianz and Deutsche Bank. During this time, she was responsible for the annual CCO review, oversight of global policies and procedures, preparing regulatory filings and disclosures, trade surveillance, subadvisor due diligence, anti-bribery oversight for gifts and entertainment, as well as political and charitable contributions, employee training and conflicts-of-interest oversight. She also spent nine years as a senior principal consultant for ACA Group, where she provided custom compliance solutions to RIAs.
Giselle has a Bachelor of Business Administration in Finance from Pace University, a Master of Business Administration in Business from Regis University and a Master of Science in Cybersecurity from Utica College. She is a current member of NSCP and former Series 7, 24, and 65 license holder.
Mark De Angelis is a senior compliance consultant at ACC. During his career, he has held senior compliance positions, including CCO and deputy CCO, at Morgan Stanley and T. Rowe Price. He has 22 years of experience in the global asset management industry, most of which was spent as a regulator with FINRA or a compliance officer at an investment adviser or brokerage division of a major financial services organization. More recently, Mark served as an in-house consultant to Belpointe Services, where he used his expertise to assist startup and seasoned investment advisers.
Prior to joining ACC, Mark was a compliance director with a national compliance consulting firm, where he led teams administering compliance programs for investment advisers, registered investment companies and private funds, wealth management advisers, fintech companies and family offices. He also provided proactive compliance management for Rule 206(4)-7 reviews, Rule 38a-1 reviews, private fund compliance programs, as well as service provider monitoring. Mark has led numerous regulatory exams, completed annual reviews, risk assessments and compliance training for variety of investment advisers.
From 1999-2006, Mark served as an analyst and then investigator with FINRA in the advertising regulation and market regulation departments.
During his time as a consultant or in-house compliance officer, Mark has served as CCO for approximately 20 registered investment advisers, broker-dealers and commodity pool operators. As a CCO, he has shown versality in adapting to investment management of clients – whether they’re traditional wealth advisers, mutual funds/ETF sponsors or private fund advisers.
Mark has a Bachelor of Science in Business Administration from the University of Maryland-Towson.
Kate Wittemann is a compliance consultant at ACC. She began her career in finance in 2003 with the oversight and reconciliation of accounts receivable for an independent television station based in Atlantic City.
In 2007, she joined AXA Equitable and, after successfully completing all FINRA licensing requirements in four months, she was promoted to senior branch controls (BCM) manager of the Baltimore branch. During her tenure as senior BCM, the branch received top honors for being the number one performing branch in the country for multiple years. In 2012, Kate was awarded the AXA Equitable Rising Star Award for her success in redefining and streamlining the compliance and controls procedures for the branch. As senior BCM, Kate improved office workflow efficiency and security by including a direct focus on improving the AML compliance. She worked to support the written guidelines with the improvement of the client onboarding process, preforming ongoing training and conducting due diligence meetings with staff and branch management.
In 2013, Kate joined Morgan Stanley as a manager in their wealth management/branch exams division where she provided internal oversight and conducted branch examinations nationwide to ensure compliance with regulatory and firm procedures and policies.
At both firms, Kate conducted regulatory-required annual financial advisor compliance interviews/audits, including assessing, quantifying, testing and implementing controls to ensure compliance with internal business process rules, and monitoring high-risk operations such as AML. By working across departments to identify and assess risk, she assisted senior management in ensuring all personnel were knowledgeable in identifying vulnerabilities, and supported a compliance and AML program tailored to manage the risks.
Kip is a licensed CPA, an Investment Adviser Certified Compliance Professional and an adjunct college accounting instructor. He has a CFA Institute Investment Foundations Certificate and passed the Securities Industry Essentials exam. He is an arbitrator with FINRA Dispute Resolution Services and the National Futures Association. Kip has a Masters of Business Administration in Finance from Thomas Jefferson University and a Bachelor of Science in Accountancy from The College of New Jersey.
Kip is a member of the Business + Innovation Department Advisory Board at Bucks County Community College and serves as the finance officer for the Sons of the American Legion Post 798.