Reporting to the Deputy Chief Compliance Officer (Deputy CCO), position is responsible for fulfilling the day-to-day responsibilities of the compliance program for CIM’s registered and non-registered advisers, as required by applicable statutory, regulatory and ethical requirements.
Essential Functions:Compliance Policies. Monitoring, promulgating and administering compliance policies, including 1) Updating and enhancing existing policies, from time to time as may be appropriate; and 2) Providing employees with advice on interpreting the policiesCode of Ethics and Code of Conduct. Overseeing certain day to day activities, including: 1) Managing related disclosures and preapproval requests; and 2) Investigating violations and making enforcement recommendations to the CCOTraining, Communications and Enforcement. Implementing and conducting an effective compliance training, communications and enforcement program, including: 1) Providing certain compliance related training for all levels of employees appropriate to their respective roles and responsibilities; 2) Providing training for agents and service providers, as necessary; 3) Disseminating communications as appropriate to convey and reinforce applicable laws and regulations, ethical standards, and compliance policies to establish a “culture of compliance”; and 4) Undertaking monitoring activities designed to prevent and detect misconduct involving violations of the Compliance ProgramRFP and DDQ Responses. Serving as the point of contact for compliance responses for RFPs, DDQs and Investor certificationsAML Review. Collecting and processing information in conjunction with CIM’s KYC and AML policies and procedures
Supervisory Responsibilities:Managing relationships with outside compliance vendors including but not limited to supporting the vetting of vendors Supervising assigned compliance personnel.
Educational/Experience Requirements:Bachelor of Arts or Bachelor of Science degreeMinimum 6 years’ experience in Investment Adviser complianceKnowledge of legal and compliance terminology and concepts Knowledge of Investment Advisers Act of 1940 and Investment Company Act 1940Knowledge of Securities Exchange Act of 1934Knowledge of Bank Secrecy Act