This position will also be responsible for the Compliance Program of Kaspick. The position will also support Endowments business and other aspects of TIAA-CREF's investment adviser Compliance Program. The position will be located on-site at one of Kaspick's offices. The position will report into Asset Management Compliance.
There will be a heavy focus on reviewing marketing materials and other communications.
In addition, the position will require managing compliance responsibilities such as portfolio management (allocation), pricing and valuation, performance reporting, accuracy of client disclosures (Form ADVs), marketing and advertising, and oversight of certain other service providers(custodians, accountants, etc.). Moreover, the position will be responsible for the design, implementation and execution of a compliance program which adheres to Rule 206(4)-7 of the Investment Advisers Act of 1940.
The position requires partnering with the business unit(s) to:
· Assist with the preparation, review, and implementation of policies, procedures, training materials and other communications to ensure employees meet and maintain compliance requirements.
· Resolve issues and assist with the remediation of deficiencies.
· Assist with the design, development and execution of compliance testing strategies and methodologies.
· Provide compliance advice and support for product development, projects and corporate initiatives.
· Draft and participate in the reporting to management and board reports on the compliance program.
· Assist in coordination of federal and state regulatory examinations conducted by external parties as needed.
· Review financial and marketing materials, including those of the sub-advisers.
· Conduct oversight and on-site visits of sub-advisers.
· Lead the implementation of new compliance controls to meet new regulatory requirements
· Support and assist with compliance reporting to management and board reports.
· Assist with federal and state regulatory examinations conducted by external parties as needed.
· Propose and assist with the implementation of new compliance controls to meet new regulatory requirements.
Responsibilities:
· Responsible for managing the Compliance Program for Kaspick.
· Assist the senior Compliance Officer(s) with managing and executing the compliance program for the Endowments business.
· Responsible for compliance monitoring and testing related to Rule 206(4)-7.
· Coordinate the review of Adviser Marketing materials and other communications across several entities.
· Design, develop and manage a robust, risk based compliance testing & reporting framework; identifying potential compliance and/or control risks and opportunities for compliance checks and control enhancements; investigating causes of unusual trends or activities that can be indicative of compliance problems; communicating results of surveillance activities to Compliance and business management for proper escalation of issues.
· Spearhead the review, development, reporting, maintenance, archival, and discovery of our employee surveillance systems (i.e. information barriers, portfolio monitoring and trading oversight)
· Actively identify risks and facilitate their mitigation to acceptable levels. Coordinate with the business to ensure effective controls are in place to meet federal and state insurance laws; provide advice to management on how to comply with the laws and regulations; monitor the business units' performance with compliance, alert management to compliance gaps and issues, and assist with responses to regulatory exams.
· Manage the implementation of new regulatory requirements.
· Participate in business and compliance oversight committees such as the Mutual Fund disclosure meetings, Market Timing Compliance Working Group, Anti-Money Laundering Committee.
· Prepare program plans, objectives and metrics according to the needs and risks of businesses. Manage the program according to the regulations and internal policies governing the businesses. Establish compliance policies and procedures for improved governance.
·Provide advice to management on how to comply with the laws and regulations; monitor the business units' performance with compliance, alert management to compliance gaps and issues.
· Support board reporting requirements, including preparation of periodic CCO reports, and the annual 206(4)-7 report.