Dante P. Bartoletti
Founder and Managing Director
Dante P. Bartoletti, founder and Managing Director of InvestmentCare Consulting Group, Inc., manages the company’s operations, client relations, consulting services and product development. Mr. Bartoletti has more than 30 years of securities compliance, auditing and accounting experience. He specializes in compliance and regulatory areas including: supervision and oversight, books and records, anti-money laundering processes and due diligence, internal inspections, special investigations, certification of compliance/supervisory control systems and processes, business continuity, communication with the public, sales practice violations, customer complaints, the FINRA Membership Application Process and the Investment Advisor registration process. Mr. Bartoletti has extensive experience with the rules, regulations and interpretations of SEC, FINRA, the MSRB, and state jurisdictions. Complimenting his knowledge of industry rules is his hands-on experience working with both clients and regulatory staff in the practical application of these rules and interpretations. He also maintains a Series 27 Financial and Operations Principal registration.
Mr. Bartoletti assists broker/dealer, investment advisor, and fund company clients in developing supervisory systems, creating books and records maintenance and retention programs, hosting training for compliance professionals, and establishing back office processes and operations. He advises clients regarding internal operations, business processes and practices, risk management, and investment product compliance. Mr. Bartoletti also works closely with clients’ legal counsel and boards of directors conducting special investigation of compliance or operations violations to identify failure points or deficiencies and make recommendations of corrective actions. He also assists firms in reviewing, preparing, presenting and filing self-reporting of rule or regulation violations to regulatory agencies.
Prior to forming InvestmentCare, Mr. Bartoletti was a securities examiner with FINRA (f/k/a NASD) where he conducted comprehensive examinations and investigations of its member firms and registered representatives for compliance with SEC, FINRA, MSRB and state rules and regulations. During his tenure with FINRA, Mr. Bartoletti was selected to lead and participate in several formal regulatory actions involving violations of sales practice, private securities transactions, net capital, communications with the public, and supervision violations resulting in fines and sanctions. He also worked with enforcement attorneys conducting special investigations and chaired on-the-record testimonials of registered investment professionals.
Mr. Bartoletti began his career with The Dial Corporation working in the finance and accounting departments. He also worked in the customer service department for Murad, Inc. investigating credit fraud inquiries and spent one year in Paris, France working for the Baan/Aurum Business Unit of Bull Integris.
Mr. Bartoletti served in the United States Marine Corps and was honorably discharged after eight years of service. Mr. Bartoletti received his Bachelor of Arts degree in European Studies from Loyola Marymount University and his Master of International Business degree from Pepperdine University. He periodically speaks at compliance conferences and seminars across the U.S.
David P. Semak
Senior Compliance Consultant
David P. Semak is an independent consultant in securities markets regulation with more than 40 years of regulatory experience. Mr. Semak specializes in the requirements of FINRA rules 3110, 3120, 3130 and 3310, pre-audit preparation, Written Supervisory Procedures, BD compliance program evaluation, anti-money laundering processes and due diligence, trading floor-related regulatory issues, analysis and expert testimony relating to insider trading, manipulation, marking-the-close, and other potential rule violations. Mr. Semak has extensive experience with the rules and regulations of FINRA, the SEC, the MSRB, the National Futures Association, state jurisdictions, including California, and equity and options exchanges.
Mr. Semak also specializes in Investment Advisor requirements including the preparation and amending of Form ADV and related schedules, the drafting of Part 2A and Part 2B (Brochure, Wrap Brochure, and Brochure Supplement), drafting of Form CRS, preparation of the Code of Ethics, and the drafting of compliance procedures. Mr. Semak has substantial experience with the IA application process with the California Department of Corporations.
As a consultant, Mr. Semak provides services to broker/dealers, Registered Investment Advisors, domestic and foreign exchanges and law firms. Mr. Semak has completed a number of client projects involving heightened AML due diligence relating to entities and individuals in Russia and former Soviet republics, the Middle East, Malta, Luxembourg, Cayman Islands, and Brunei. Mr. Semak has testified in federal court as an expert witness regarding an insider trading case and has participated in a number of NASD/FINRA arbitrations as an expert witness.
Prior to launching his consulting business in 1999, Mr. Semak spent nearly 21 years at the Pacific Exchange in a variety of analytical and managerial positions within the Exchange's regulatory division. From 1988 through September 1999, Mr. Semak served as Vice President of Regulation and was responsible for the Exchange's equity and options surveillance; enforcement; securities qualification (listings); member examinations (financial compliance); regulatory policy; and regulatory development and oversight departments. Mr. Semak represented the Pacific Exchange on a number of national and international groups and organizations including the Intermarket Surveillance Group (ISG), NASAA, IOSCO, and FIBV.
Mr. Semak received his BA and MA degrees in history from California State University, Northridge, and was a long-time member of the Compliance & Legal Society of the Securities Industry and Financial Markets Association (SIFMA).