This individual will serve as the Chief Compliance Officer for a business development company (“BDC”) platform within the Private Credit business. The BDC platform is a middle-market debt platform currently with four business development companies that have elected or intend to elect to be regulated under the Investment Company Act of 1940 (“1940 Act”). This person is primarily responsible for the day-to-day implementation and maintenance of the compliance program for the BDC platform including, among other things, developing and implementing BDC-related policies, procedures and processes, conducting risk assessment analyses, supervising compliance testing, reviewing and approving BDC transactions on a pre-trade basis, compliance reporting to the BDC boards, advising investment professionals on 1940 Act compliance, reviewing marketing materials, training Private Credit personnel on compliance matters, and reviewing and analysing applicable laws and regulations and keeping updated on regulatory guidance to determine whether changes or enhancements should be made to the BDC compliance program. This person will collaborate with the senior management of Private Credit as well as senior management of the wider Global Credit business on various matters affecting Private Credit, including the development and integration of new funds and strategies.
BDC Chief Compliance Officer:
- Serve as Chief Compliance Officer for BDC platform, which includes reviewing and approving transactions on a pre-trade basis, monitoring and advising on allocation of investments across the platform (including oversight of compliance with SEC exemptive order), advising BDC investment professionals on 1940 Act compliance, responsibility for regulatory reporting and filings, advising the BDC boards of directors on all BDC compliance matters including quarterly and annual compliance reporting and administering BDC policies and procedures.
- Oversee the maintenance of books and records for the BDC platform.
- Serve as the BDC compliance liaison with the centralized Compliance team.
- Consider complex investment allocation issues and other potential conflicts among advisory clients as Private Credit platform grows.
- Coordinate with Global CCO on SEC regulatory inspections.
- Coordinate with the company’s Internal Audit function on internal audits relating to the Private Credit platform.
- Assist, as necessary, in the review, approval and retention of marketing materials for Private Credit funds (including world sky considerations).
Oversee, develop and implement training of Private Credit personnel on relevant compliance policies and procedures.
- 8-10 years of compliance experience at another asset manager, a law firm, an accountancy firm, the SEC or a regulatory consulting firm.
- Strong understanding of credit asset management.
- A thorough understanding of U.S. securities laws, particularly the Investment Company Act of 1940.
- Ability to comprehend and apply other applicable laws and regulations.
- A proven ability to effectively and clearly identify issues and communicate findings to other members of the team.
Please send resumes to Jack Kelly – Jack@ComplianceSearch.com