1st Vice President, Compliance (OFS)

POSITION PURPOSE:

The 1st Vice President, Compliance for CIM is responsible for supporting the CCO of CIM and a CIM affiliate, OFS Management (“OFS”), in ensuring that OFS maintains a compliance program reasonably designed to comply with applicable federal, state and local laws, rules and regulations. The 1st VP, Compliance is responsible for the day-to-day management of the OFS compliance program, including oversight of a team of two compliance professionals.  The 1st VP, Compliance assists the CCO of OFS-managed registered investment companies in maintaining their compliance programs, including their 38a-1 manuals and reports to the relevant boards, with the expectation that the 1st VP, Compliance assumes the role of CCO of at least one of the investment companies. The 1st VP, Compliance is also committed to the highest ethical standards and constant reinforcement of CIM’s and OFS’ uncompromising culture of compliance. 

RESPONSIBILITIES:

• 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 and testing of the activities and operations of OFS and its managed investment companies.
• Compliance Policies. Promulgating and administering compliance policies, including drafting new and updating existing policies and addressing associated staff inquiries.
• Code of Ethics.  Reviewing Code of Ethics-related disclosures and pre-clearance requests.
• Training.  Providing compliance-related training for all levels of employees, appropriate to their respective roles and responsibilities.
• 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 Advisers 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.
• Regulatory requests/exams.  Supporting the CCO in successfully managing all periodic and any special regulatory examinations of OFS and registered investment companies.

SUPERVISORY RESPONSIBILITIES:

• Manage the OFS Compliance team, including but not limited to work assignment, performance expectations, performance feedback, training, performance coaching and guidance.
• Serve as team lead on inter-departmental compliance-related projects.

EDUCATION/EXPERIENCE REQUIREMENTS:

• 10+ years’ experience as a compliance professional at an SEC-registered investment manager and/or staff member at the Securities and Exchange Commission.
• 3+ years’ experience in investment company compliance.
• Credit investment (e.g., CLOs, BSLs, CMBS, direct lending) experience.
• Trade compliance experience a plus.

ABOUT YOU:

• Working knowledge of Investment Advisers Act of 1940 and Investment Company Act of 1940.
• Professional and effective communicator.
• Ability to read, analyze and interpret complex agreements.
• Adept at conflicts identification, assessment and resolution.
• Proficiency in policy development and drafting.
• Detail-oriented with the ability to multitask.
• Excellent organizational and project management skills.

Actual base salary considers several factors including but not limited to geography, job-related knowledge, experience, and budget. The start of the salary range is typically associated with the minimum experience required. At CIM, base pay is one part of the total compensation package. This role is eligible for bonus pay in addition to base salary.  The anticipated base salary range for the position in Chicago, IL is $200,000 - $270,000.