Chief Operating Officer Director of Operations

Jim A. Richardson

32 Old Schoolhouse Rd, Nyack, NY 10956, (845) 358-5555,

Chief Operating Officer ▪ Director of Operations

Dynamic management career building and leading compliance and operations division in start-up, turnaround and high-growth environments. Combines strategic and tactical financial expertise with strong qualifications in program development, technology development/implementation, vendor relations and contract negotiations. Areas of expertise include:

¨ Productivity Advancement / ¨ Trade Investigation / ¨ Interdepartmental Coordination
¨ Project Management / ¨ Sales Trading / ¨ Software Development
¨ Order Management / ¨ Business Development / ¨ Front End Trading

Professional Experience

APEX Trading, a Division of Mitchell Trading, New York, NY / 2003 to Present

APEX Trading, operated as a Division of Bloom, Start & Rice from June 2003 to November 2003

Managing Director (Chief Operating Officer, Director of Compliance)

¨ Direct daily operations of Division, general operations, technology requirements and budgetary requirements. Evaluate existing technologies and processes to maximize operating and financial efficiencies; monitor and evaluate Division’s profit and loss, clearing expenses and risk management.

¨ Oversee all compliance duties of Division, analyzing and negotiating all contracts for Division with market data vendors, technology vendors, service providers and any other entities with whom the Division does business.

¨ Manage the day-to-day operational staff of three, reconciling daily transaction reports with clearing firm and customers.

¨ Participate in discussions with customers regarding business activities and operations.

¨ Play a key role in business development, strategies and policies.

Key Achievements:

¨ Grew business from zero to $17M. Negotiate all contracts including market data, business agreements, clearing agreements and vendor agreements.

¨ Involved in all phases of installing an Order Management System to increase business an estimated 30% by allowing electronic order submission by customers directly to trading desk. This system will enable more efficient management of orders/executions and evaluation future business opportunities.

AMEX Group, Inc / 1996 to 2003

Vice President, Limited Partner/Director of Operations; Capital Markets, 2000 to 2003

¨ Directed operations of division’s trading and market making activities of 5,000+ Nasdaq securities and 400 traders, assistants, sales traders and back office personnel. Monitored and evaluated division’s Profit, Loss, Commission payouts and expenses. Directed Cap Markets trading and market making compliance.

¨ Managed working groups of business and technology staff for development and implementation of technology solutions for business issues.

¨ Supervised numerous staff in different operational areas and developed and coordinated interaction between compliance, technology and operations areas, participating in development initiatives of all areas.

¨ Involved in project management and development process of software and hardware initiatives for business usage and efficiency.

Key Achievements:

¨ Evaluated and provided guidance to senior management regarding various operational and compliance areas of the Cap Markets division including P&S, Compliance, Operations, Technology, Software Development, Trading, and Sales Trading.

¨ Designed and assisted in development of proprietary software including an Order Management System and Front End Trading System.

Limited Partner/Director of Compliance, 1996 to 2000

¨ Directed compliance of trading, market making and operations activities of 5,000+ Nasdaq securities and 260 traders, assistants and sales traders. Ensured continuing education regarding firm and regulatory requirements for the entire firm.

¨ Performed educational classes and seminars for Spear, Leeds & Kellogg Capital Markets and Spear, Leeds & Kellogg employees on NASD and SEC rules and regulations.

Jim A. Richardson, Page Two

(609) 333-0002,

Professional Experience Continued

Key Achievements:

¨ Initiated and conducted compliance reviews of trading, market making and operational activities; managed responses to regulatory agencies regarding inquiries; submitted regulatory filings with NASD and SEC.

¨ Consulted on software and system development to insure compliance with NASD and SEC rules.

¨ Participated in the development and approval of Spear, Leeds & Kellogg Electronic Communications Network (“ECN”) REDIBook with NASD and SEC.

¨ Developed written supervisory and trader’s compliance procedural manuals and numerous compliance reports to be reviewed by Compliance staff during normal daily responsibilities.

¨ Performed branch audits on Capital Markets’ 4 US branches and 1 London Office.

Early Career Development

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Investigator, Market Regulation, Trading and Market Making Surveillance, 1994 to 1996 /

1992 to 1996

¨ Participated in the development and implementation of the first Market Trading and market making surveillance system.

¨ Reviewed trading activity in Nasdaq, New York Stock Exchange, and American Stock Exchange securities on The Nasdaq Stock Marketâ and member firms activity on Nasdaq systems (SOES, SelectNet and ACT).

¨ Investigated trading and market making activity for potential violations of NASD and SEC rules.

Investigator, Market Regulation (Market Services, Trading and Compliance, 1992 to 1994

¨ Reviewed and analyzed trading and trade reporting activity of Nasdaq National Market Securities, Small Cap securities, OTC securities, Convertible Debentures, Combined Quotation System Securities, High Yield Securities and the Nasdaq 100 index options.

NEWBY & COMPANY

NASDAQ Equities Trader

1992

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

1989 to 1992

Analyst, Market Regulation, Stockwatch, 1990 to 1992

Compliance Specialist, Special Registration Review/Central Registration Depository, 1989 to 1990

Certifications, Licenses and Qualifications

¨ Registered with NASD and NYSE with Series 4, 6, 7, 8, 14, 14A, 24, 55 and 63 licenses.

¨ Assistant Instructor at Johns Hopkins University, Division of Continuing Studies, Graduate Business School during summer of 1996 (Investment Analysis and Portfolio Management).

¨ Panel member and speaker for numerous SIA and NRS conferences concerning broker/dealer compliance issues.

¨ NASD Regulation, Inc., Board of Arbitrators, District 9 Committee, Vice-Chairman 2001, Chairman 2002, Hearing Panel Member Regulation Disciplinary proceedings, Advisory Council 2002 – 2004, National Adjudicatory Council Nominating Committee 2002, Consultative Committee and District 9 Nominating Committee 2003.

¨ Member (prior and current) of various Nasdaq Committees. Current member of SuperMontage “Red Team” Committee; Prior member of Decimalization Subcommittee of Quality of Markets, and Super SOES Subcommittee of Quality of Markets.

Education

¨ Master of Science, Business, Johns Hopkins University

¨ B.S., Business, University of Maryland, University College