Private Fund Compliance Manager

NISA Investment Advisors, LLC•Clayton, MO

About The Position

NISA Investment Advisors, LLC (NISA) is seeking a Private Fund Compliance Manager to serve as the compliance lead for its private fund platform. The role partners across the organization to extend NISA’s established compliance framework into a growing business area, designing, implementing, and overseeing compliance for private fund vehicles. It integrates requirements across the SEC, CFTC, NFA, and offshore regulatory regimes throughout the fund lifecycle, with coverage spanning investor onboarding, marketing and distribution review, regulatory filings, compliance testing, governance, and audit support. The manager will shape the private fund compliance workstream while receiving support from NISA’s firm-wide Compliance program. The position owns private fund filing processes and supports regulatory programs, fund governance, investor onboarding, offshore compliance, testing and surveillance, and relationships with fund administrators, auditors, prime brokers, and offshore service providers. The role also contributes private fund sections to compliance program reviews, updates, risk assessments, policies, and procedures. NISA describes its culture as collaborative and innovative, with opportunities for learning, personal development, and meaningful work. The company offers a range of employee benefits and is an equal opportunity employer.

Requirements

Three or more years of investment adviser or private fund compliance experience, including experience at a private fund adviser and hands-on responsibility for regulatory filings.
Working knowledge of the Investment Advisers Act of 1940, the Commodity Exchange Act and CFTC Part 4 regulations, and NFA rules.
Experience with the SEC Marketing Rule and performance presentation review.
Strong drafting, testing, and documentation skills, with the ability to work directly with fund administrators and auditors.
Experience with Cayman Islands fund structures and offshore AML, regulatory, FATCA, and CRS regimes.
Experience onboarding a variety of investor types, including large institutional investors and state and ERISA-covered plans.
Familiarity with master-feeder and onshore-offshore fund complexes and side letters.

Responsibilities

Serve as the compliance lead for NISA’s private fund platform and design, implement, and oversee compliance for private fund vehicles.
Own the private fund regulatory filing calendar, coordinate preparation and submission with fund administrators, maintain procedures, and ensure filings are accurate and timely.
Maintain private fund reporting in Section 7.B of Schedule D of Form ADV, including PFIDs, and prepare annual and other-than-annual amendments as fund facts change.
Prepare quarterly and annual Form PF filings, including applicable event-based current reporting, coordinating data with the fund administrator.
Prepare initial and annual Form D amendments and related state blue sky filings.
Prepare CFTC and NFA filings, including Form CPO-PQR and Form CTA-PR through NFA EasyFile; assist with NFA self-examinations and annual membership and registration renewals; and maintain Regulation 4.7 claims and supporting records.
Support Forms 13F and 13H and CFTC large-trader and ownership-and-control reporting, such as Form 40, where fund positions aggregate into firm-level filings.
Coordinate FATCA and CRS returns and other periodic filings, such as TIC reports, as applicable.
Maintain filing workpapers, supporting documentation, and audit trails, and reconcile filed data with fund administrator and accounting records.
Maintain CFTC Regulation 4.7 exemption eligibility and related recordkeeping, and monitor investor eligibility during onboarding.
Assist in reviewing fund promotional materials under NFA Compliance Rule 2-29, including required disclaimers and internal review routing.
Support NFA self-examinations, regulatory inquiries, and related correspondence.
Assist in reviewing fund pitch materials, prospect letters, and investor communications under the SEC Marketing Rule, including performance presentation and fair-and-balanced requirements.
Support custody rule compliance for pooled vehicles, including annual delivery of audited financial statements.
Support governance of master-feeder and onshore-offshore structures, including governing-body materials and service provider oversight.
Oversee investor eligibility and onboarding for investor types including large institutional investors and state and ERISA-covered plans.
Administer subscription and AML onboarding, side letter compliance, and most-favored-nation tracking.
Coordinate Cayman Islands AML and sanctions compliance, regulatory filings, and FATCA and CRS obligations with offshore counsel and administrators.
Execute private fund compliance testing, including independent recalculation of management and performance fees, expense allocation, and trade allocation.
Support valuation controls and MNPI controls, including information barriers.
Manage compliance touchpoints with fund administrators, auditors, prime brokers, and offshore service providers.
Contribute private fund sections to the annual compliance program review, quarterly compliance updates, and risk assessment, and maintain related policies and procedures.