Reporting to the Chief Compliance Officer (CCO), position is responsible for creating and managing an effective compliance program for CIM Group as required by applicable statutory, regulatory and ethical requirements including, among other things, the Investment Advisers Act of 1940, as amended (IA Act), the Foreign Corrupt Practices Act of 1977, as amended and the Securities Exchange Act of 1934, as amended.
Compliance Policies. Having principal responsibility for promulgating and administering compliance policies for CIM, including:
- Promulgating, revising and updating policies;
- Communicating the policies to all appropriate employees;
- Providing employees with advice on interpreting the policies; and
- Taking such actions as may be appropriate to ensure compliance with policies, including investigations of violations and making enforcement recommendations to the CCO.
The GC/CCO will be responsible for implementing and conducting an effective compliance training and communications program for CIM, including:
- Providing compliance related training for all levels of employees appropriate to their respective roles and responsibilities;
- Providing training for agents and service providers, as necessary; and
- Disseminating communications as appropriate to convey and reinforce applicable laws and regulations, ethical standards, and compliance policies.
Senior Management Responsibilities: Acting as the liaison with senior management, including:
- Keeping them apprised of their obligations under the compliance program;
Establishing and maintaining a “culture of compliance”;
- Assisting and coordinating with them to implement compliance activities in their business operations; and
- Evaluating their compliance related performance.
Risk Assessment: Directing and/or participating in regular risk assessments of the activities and operations of CIM in order to establish or modify the components of the compliance program from time to time as appropriate, including:
- Promulgating and revising as necessary a risk map and risk matrix for CIM Group;
- Preparing a comprehensive Compliance testing program based on the foregoing risk assessment; and
- Overseeing periodic testing.
Maintenance, Modification and Assessment of the Compliance Program: Undertaking such actions as are necessary to assure the continued effectiveness of the compliance program, including:
- Modifying the Compliance Program to reflect new laws and regulations applicable to CIM, new operations and activities, and such other changes as may require modification;
- Modifying the compliance program after misconduct has been identified to enhance prevention and detection activities so that similar misconduct will not occur in the future;
- Undertaking monitoring activities designed to prevent and detect misconduct including violations of the Compliance Program; and
- Coordinate mandatory yearly audits with outside consultants.
Regulatory Filings, Document Retention and Exams: Responsible for ensuring that required filings under the IA Act are complete, accurate and timely, that required documents are retained, and coordinating responses to regulatory exams and information requests, including:
- Keeping abreast of all filing and document retention requirements applicable to the company based on its operations and applicable law;
- Developing a communications program to advise responsible employees of reporting and document retention obligations;
- Providing advice to responsible employees in interpreting filing and document retention obligations;
- Taking such actions as may be necessary to ensure filing and document retention requirements are being followed, including conducting periodic testing and recommending enforcement actions for non-compliance, as necessary to Senior Management and the CCO;
- Supervising outside counsel and/or consultants as necessary;
- Preparing filings, including coordinating internal reviews of filings, as appropriate; and
EDUCATION/EXPERIENCE REQUIREMENTS: (including certification, licenses, etc.)
- JD degree required
- Minimum 7 years’ legal experience at a regulatory agency or in-house, with at least 4 years’ experience in-house at an SEC registered alternative investment adviser as a head or deputy supervisor of an IA compliance program (CCO or deputy CCO) or with the SEC.
- Demonstrated knowledge of legal and compliance terminology and concepts
Please send all resumes to:
Compliance Search Group
Compliance/Legal Executive Recruiter
Asset Management Practice Leader
450 Seventh Avenue
New York, NY 10123