Reporting to the Chief Compliance Officer (CCO), position is responsible for managing and fulfilling certain of the day-to-day responsibilities of the compliance programs of CIM Group and an affiliated company, OFS Management, as required by applicable statutory, regulatory and ethical requirements, and serving as the primary compliance resource for the firms’ credit-related investment activities.
ESSENTIAL FUNCTIONS:Investment Compliance. Conducting compliance oversight of credit investment activities and providing guidance regarding applicable policies, procedures and laws, including the Investment Company Act of 1940 and the Investment Advisers Act of 1940.Risk Assessment and Testing. Directing and/or participating in regular risk assessments of the activities and operations of assigned entities to establish or modify the components of the compliance program from time to time as appropriate, including:Assisting with the promulgation and revision of the risk map and risk matrix, as necessary;Preparing and implementing a comprehensive compliance testing programs based on the foregoing risk assessment; andCoordinating compliance audits with outside consultants.Compliance Policies . Promulgating and administering compliance policies, including:Drafting new and updating existing policies, from time to time as may be appropriate; andProviding employees with advice on interpreting the policies.Reviewing Code of Ethics-related disclosures and pre-clearance requests Training, Communications and Enforcement. Implementing and conducting an effective compliance training, communications and enforcement program, 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; Disseminating communications as appropriate to convey and reinforce applicable laws and regulations, ethical standards, and compliance policies to establish a “culture of compliance”; Undertaking monitoring activities designed to prevent and detect misconduct involving violations of the Compliance Program; andInvestigating violations and making enforcement recommendations to the CCO.Marketing and Advertising Review. Reviewing marketing and advertising materials, including flipbooks and Due Diligence Questionnaires, to ensure compliance with applicable rules and regulations.Regulatory Filings and Exams. Making required filings under the Investment Advisors Act and coordinating responses to regulatory exams and information requests. Board Reporting. Assisting the CCO with quarterly and annual reporting to the boards of firm-managed registered investment companies. VC Compliance. Conducting oversight of the day-to-day compliance of an affiliated non-registered adviser to a venture capital fund.
EDUCATION/EXPERIENCE REQUIREMENTSMinimum 10 years’ compliance experience at a regulatory agency or SEC registered investment adviser as a member of an IA compliance program.Demonstrated knowledge of compliance terminology and concepts.JD degree a plus.Proficiency in Microsoft Office including Word, Excel and OutlookAbility to read and comprehend applicable statutes, rules and regulationsAbility to draft compliance policies and procedures Ability to develop and maintain effective working relationships, including but not limited to maintaining strict confidentiality and appropriate judgment and discretion in handling highly sensitive and confidential matters. Ability to communicate, orally and in writing, with individuals at all levels within various organizations to which the position provides compliance related services and with outside law firms, consultants and regulatory agencies on technical legal and compliance issues