Chief Compliance Officer, GAM US

BMO • New York, NY

1d • $120,000 - $250,000

About The Position

The Chief Compliance Officer leads the development, implementation, maintenance, and administration of the regulatory compliance program for a U.S. registered investment adviser (RIA). The role oversees a comprehensive compliance framework in connection with the RIA’s SEC registration and the development and launch of investment products and funds. It provides regulatory compliance advice and oversight for investment advisory activities, fund operations, and related business initiatives, while serving as the RIA’s designated CCO under Rule 206(4)-7 of the Investment Advisers Act of 1940.

The CCO administers the RIA’s compliance policies and procedures in accordance with applicable SEC requirements and ensures the program remains effective and aligned with the BMO Compliance Program. This includes leading compliance risk assessments, monitoring, testing, surveillance, issue management, reporting, regulatory filings, and required annual reviews. The role also advises business and senior leaders on regulatory developments, new products, investment strategies, and business initiatives; oversees implementation of appropriate policies, procedures, and controls; and provides independent oversight and effective challenge to help manage regulatory compliance risk and meet business objectives.

The position supports the structuring, development, and launch of investment funds, including products offered or registered under the Securities Act of 1933 and funds registered under the Investment Company Act of 1940. It works closely with business management, Legal, Risk, Operations, Finance, Technology, fund boards and service providers, external counsel, regulators, auditors, and other stakeholders. The CCO represents the RIA in regulatory examinations and inquiries, promotes a strong culture of compliance and accountability, and operates as a specialist resource to senior leaders in a developing business within a larger financial institution’s governance and control framework. Broader work or accountabilities may be assigned as needed.

Requirements

• Typically, 10 or more years of relevant experience in U.S. investment management regulatory compliance, including experience with SEC-registered investment advisers.
• Post-secondary degree in a related field of study, or an equivalent combination of education and experience.
• Significant experience developing, implementing, and overseeing regulatory compliance programs for SEC-registered investment advisers.
• Demonstrated knowledge of the Investment Advisers Act of 1940, Investment Company Act of 1940, Securities Act of 1933, and applicable SEC rules, regulations, and guidance.
• Experience establishing or materially enhancing an investment adviser compliance program, including policies and procedures, regulatory risk assessments, monitoring and testing, regulatory reporting, and governance processes.
• Knowledge of compliance requirements applicable to U.S. registered investment funds, including fund formation, launch, governance, operations, and ongoing regulatory obligations.
• Experience with investment management compliance matters, including fiduciary duties, conflicts of interest, investment restrictions, personal trading, marketing, custody, best execution, trade allocation, and regulatory recordkeeping.
• Experience managing SEC regulatory examinations, inquiries, and compliance reviews.
• Experience working collaboratively with Legal, Risk, business management, external counsel, and other internal and external stakeholders.
• Ability to independently establish and manage a compliance function within a developing business while operating within a larger financial institution’s governance and control framework.
• Strong business acumen and ability to provide practical, risk-based compliance advice in support of business objectives.
• Strong communication, critical thinking, relationship management, and project management skills.
• Verbal and written communication skills at an in-depth/expert level.
• Analytical and problem-solving skills at an in-depth/expert level.
• Influence and effective-challenge skills at an in-depth/expert level.
• Collaboration and cross-group teamwork skills at an in-depth/expert level.
• Regulatory risk assessment, monitoring, and testing skills at an in-depth/expert level.
• Ability to manage ambiguity and competing priorities.
• Data-driven decision-making skills at an in-depth/expert level.
• Seasoned professional with a combination of education, experience, and industry knowledge.

Nice To Haves

• Prior experience as a Chief Compliance Officer, Deputy Chief Compliance Officer, or senior compliance leader within a U.S. investment management business.
• Experience supporting SEC investment adviser registration, including Form ADV preparation and related regulatory requirements.
• Experience with investment company compliance programs under Rule 38a-1 of the Investment Company Act of 1940.
• Familiarity with regulatory and governance requirements for bank-owned investment management businesses, including enterprise compliance frameworks and the three lines of defense.
• Recognized compliance certification, such as Certified Investment Management Compliance Professional (IACCP), or equivalent.

Responsibilities

• Lead the development and implementation of the RIA’s regulatory compliance program, including policies, procedures, controls, governance arrangements, monitoring, and testing.
• Lead the compliance workstream for the RIA’s SEC registration, including preparation and review of Form ADV, regulatory disclosures, and related documentation.
• Serve as the RIA’s designated Chief Compliance Officer pursuant to Rule 206(4)-7 under the Investment Advisers Act of 1940.
• Oversee ongoing compliance program administration and effectiveness, including annual reviews, regulatory filings, monitoring, testing, issue management, and reporting.
• Advise and influence business and group management on solutions aligned with regulatory requirements and risk appetite.
• Provide subject-matter expertise on U.S. investment adviser regulation, including fiduciary obligations, conflicts of interest, custody, marketing, personal trading, and recordkeeping.
• Provide compliance advice and oversight for structuring, developing, and launching investment funds and products.
• Consult on new products, investment strategies, services, distribution arrangements, and automated systems to incorporate compliance requirements into business initiatives.
• Oversee compliance policies and controls for investment management activities, including portfolio management, trading, allocation, best execution, valuation, conflicts of interest, and client disclosures.
• Advise on investment fund compliance requirements, including fund governance, disclosure, investment restrictions, service-provider oversight, and regulatory reporting.
• Support compliance arrangements for funds subject to the Investment Company Act of 1940, including coordination with fund boards, fund compliance personnel, and external service providers as applicable.
• Recommend strategies, initiatives, and regulatory risk management approaches to senior leaders.
• Lead or participate in compliance risk assessments, monitoring, testing, surveillance, and reporting processes.
• Challenge business and group risk assessments and help identify and implement appropriate compliance controls.
• Perform and oversee monitoring and testing to assess the design and operating effectiveness of regulatory compliance controls.
• Identify, assess, challenge, and oversee resolution of compliance issues, including remediation plan development and validation.
• Escalate material compliance issues and regulatory risks to management, senior Compliance leadership, and governance committees.
• Develop and maintain compliance management information, metrics, and reporting for management, Compliance leadership, and governance bodies.
• Establish and maintain relationships with the SEC and other applicable regulators, and coordinate responses to inquiries, examinations, and information requests.
• Represent the RIA and interact with examiners and auditors during regulatory examinations and internal and external audits.
• Maintain expertise in applicable U.S. securities laws, regulations, SEC rules, regulatory guidance, and industry practices.
• Monitor regulatory developments affecting investment advisers, investment products, and registered investment companies, and advise management of their implications.
• Oversee implementation of revised compliance policies, procedures, and controls in response to regulatory or business changes.
• Provide compliance advice and oversight for marketing, advertising, investor communications, and distribution activities.
• Identify compliance training needs and develop or coordinate appropriate employee training.
• Collaborate with internal and external stakeholders, including Legal, Risk, Operations, Finance, Technology, external counsel, compliance consultants, regulators, and fund service providers.
• Integrate the RIA’s compliance framework with the BMO Compliance Program and enterprise governance, policies, procedures, and risk management requirements.
• Communicate the roles and responsibilities of the three lines of defense and promote a culture of compliance and accountability.
• Serve as a specialist resource to senior leaders and stakeholders, applying judgment to complex, emerging, or ambiguous regulatory matters.
• Carry out broader work or accountabilities as assigned.

Benefits

• Health insurance
• Tuition reimbursement
• Accident and life insurance
• Retirement savings plans
• Performance-based incentives and discretionary bonuses may be included in the total compensation package, depending on pay type.

What This Job Offers

• Job Type: Full-time
• Career Level: Executive