About

Why I Founded No Bad Acts LLC

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I find what other consultants miss.

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That's not a marketing line. It's the product of a career spent on both sides of the regulatory table.

 

I began at the SEC as a securities compliance examiner, conducting examinations of investment advisers ranging from small emerging managers to multi-billion-dollar fund complexes. I learned how examiners think, what they prioritize, and -- just as importantly -- what makes them look harder. That experience doesn't come from a textbook or a checklist. It comes from doing the work.

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After leaving the SEC, I spent 25 years inside some of the world's leading asset managers -- JPMorgan, Morgan Stanley, GIC, and others -- building and running compliance programs that had to actually work under real regulatory scrutiny. At GIC I led the compliance function across the Americas for seven years, advising deal teams across private equity, venture, infrastructure, and public markets. As CCO of a global private equity firm I led a comprehensive SEC examination to a successful conclusion with no findings -- managing every aspect from document production through examiner interviews. I know what it takes to get that outcome because I've delivered it.

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I founded No Bad Acts because I kept seeing the same problem: firms investing in compliance programs that looked right on paper but wouldn't hold up when tested. Thick compliance manuals that nobody read after the annual review. Policies that weren't connected to how the business actually operated. Consultants who delivered a report and moved on.

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That's not how I work.

 

When I come into a firm I'm not looking to update your manual and hand you an invoice. I'm looking for what the SEC would find -- and then helping you fix it in a way that actually sticks. That means translating findings into changes your team understands and can sustain. It means helping compliance work alongside the business rather than around it. And it means being direct with you about what I see, even when that's uncomfortable.

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I dispense tough love. Not to be difficult, but because I genuinely want your firm to operate in a way that meets regulatory expectations, earns investor trust, and gives your employees a clear framework for doing the right thing. That matters to me.

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I'm also a licensed attorney admitted to the New York State Bar, which means I bring both legal and regulatory judgment to every engagement -- not just compliance process.

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If you're looking for someone to tell you everything looks fine, I'm probably not your person. If you want to know where you actually stand and what to do about it, let's talk.

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