HIGHTOWER ADVISORS, LLC & HIGHTOWER ADVISORS, LLC [Dually-Registered]
Advised Compliance leadership across Hightower’s dual adviser / broker-dealer operating model as the firm delivered equity, fixed income, multi-asset, and private-market solutions through its Investment Solutions platform, while Hightower Advisors, LLC provided discretionary and non-discretionary advisory services and Hightower Securities, LLC operated as an affiliated introducing broker-dealer offering brokerage in equities, listed options, fixed income, mutual funds, and variable insurance products. Provided an integrated SEC RIA and FINRA broker-dealer compliance program that aligned fiduciary advice, product governance, conflict management, and supervisory controls across both channels.
• Designed the adviser-side compliance framework for discretionary and non-discretionary portfolios, wrap programs, and advisory recommendations—strengthening governance around fiduciary obligations, Form ADV and Form CRS disclosures, discretionary-authority controls, fee oversight, proxy governance, and supervision across proprietary and non-proprietary offerings.
• Established product and conflicts governance across Hightower’s equity, fixed income, multi-asset, and private-market solutions, as well as affiliated managers, third-party managers, and pooled vehicles—tightening due diligence, allocation oversight, private-fund reviews, and disclosures where Hightower or its affiliates could earn additional fees.
• Built the broker-dealer supervision program for transaction-based recommendations, commissions and markups/markdowns, mutual fund and 529 share classes, variable insurance, placement-agent activity, revenue sharing, margin, and riskless-principal conflicts—aligning surveillance, representative oversight, and supervisory controls to HTS’s FINRA-regulated introducing-broker model.
Outcomes:
• Strengthened dual-regulatory governance by aligning SEC adviser and FINRA broker-dealer controls across advisory portfolios, private-market solutions, and brokerage activity under one coordinated compliance operating model.
• Reduced regulatory and reputational risk by tightening conflicts management, disclosures, and supervisory evidence around affiliated managers, private funds, commissions, revenue sharing, placement activity, and transaction-based compensation.
• Improved exam readiness, advisor supervision, and management reporting through more consistent testing, documentation, and escalation across fiduciary, conduct, and brokerage obligations.
PITON INVESTEMENT MANAGEMENT
Built the Chief Compliance Officer function for Piton as Merchant expanded a complex multi-affiliate investment platform spanning fixed income, equities, derivatives, private funds, separately managed accounts, and broker-dealer activity. Established an integrated compliance operating model across 12 affiliates and more than $23.6B in RAUM to support registrations, fund and advisory governance, trading oversight, financial-crimes controls, and regulatory readiness under SEC, FINRA, and CFTC expectations.
• Established the firmwide compliance program and advised 12 Merchant affiliates across fund and portfolio operations, RIA umbrella registrations, Form ADV and Form BD filings, IARD and Web CRD administration, and the transition roadmap for private-fund and separately managed account structures.
• Designed risk-based testing, surveillance, and control frameworks across trade compliance, sales practices, anti-fraud monitoring, BSA/AML, best execution, personal trading, soft dollars, political contributions, books and records, cybersecurity, business continuity, and third-party/vendor oversight.
• Directed post-trade surveillance in Bloomberg AIM and Sentry PM, quarterly monitoring across sales, portfolio management, and finance, annual compliance assessments, management reporting, employee training, and regulatory exam support for SEC, FINRA, and CFTC inquiries.
Outcomes:
• Stood up a scalable compliance program across 12 affiliates and $23.6B+ in RAUM, creating a consistent supervisory and governance framework across adviser and broker-dealer activities.
• Identified control gaps and executed a remediation roadmap aligned to SEC and FINRA expectations, strengthening internal controls, regulatory filings, and exam readiness.
• Implemented a repeatable testing, reporting, and training model that improved oversight of trading, marketing, vendor, and employee-conduct risks while reinforcing accountability across the business.