Organizational Background and Objective/Purpose:
First Republic Investment Management (“FRIM”) is an investment adviser registered with the SEC. FRIM has an affiliated broker-dealer, First Republic Securities Company LLC, and is a wholly owned subsidiary of First Republic Bank. “Altair” is FRIM’s private investment fund platform. First Republic’s Private Wealth Management platform had approximately $74B in AUM (as of 12/31/2017), with approximately $4B in alternative investments on its Altair platform. The Compliance Department provides advice and guidance to the business partners regarding the applicability of rules and regulations, policies, procedures and controls, compliance monitoring and assistance with supervisory reviews in order to ensure compliance with all federal and state securities laws and regulations.
Brief Description of Role:
The Compliance Manager will contribute to the enhancement and implementation of FRIM’s alternatives compliance program and ensure compliance with applicable regulations and best practices. The Compliance Manager will manage important elements of the program, including SEC, FINRA, NFA/CFTC elements. FRIM’s alternatives platform includes (1) FRIM’s proprietary Altair private funds, which are generally structured as feeder funds or fund-of-funds that invest in private funds managed by third-party investment advisers, and (2) “direct” investments in private funds that are managed by third-party investment advisers. This position will play a key role in conducting compliance due diligence on these third-party investment advisers. This position will also include advising business clients on regulations and related compliance policies, and maintaining and developing (as needed) compliance policies and procedures in an effort to establish industry best practices around alternatives.
The ideal candidate will have previous compliance experience with alternative investments in a high-touch/high-client-experience-expectation organization within a registered investment adviser.
Duties and responsibilities include, but are not limited to:
• Lead due diligence reviews on third-party asset managers and assist with the enhancement of the compliance due diligence program of the Altair funds’ sub-advisers, underlying fund managers, and service providers
• Manage the oversight process for third-party managers, including direct fund advisers and advisers on the Altair platform
• Interact directly with third-party managers to address follow up matters resulting from the initial due diligence reviews and oversight process
• Assist with maintaining compliance with the Volcker Rule, including responding to regulatory and internal audit requests
• Develop and conduct alternative-investment-specific training sessions
• Manage the filing process for required SEC and NFA-related regulatory filings (e.g., Form PF, CTO-PQR, CTA-PR, etc.) and assist with gathering data for other regulatory filings (e.g., Form ADV, Form PF, etc.), as needed
• Assist with ensuring compliance with NFA/CFTC, FINRA and SEC requirements, including such items as performance of the annual NFA self-exam, suitability, bad actor reviews, etc.
• Monitoring/testing of compliance program related policies and procedures (e.g., expense allocation, etc.)
• Manage the review process of alternative-related marketing materials to ensure compliance with regulatory guidelines and best practices
• Maintenance and development of compliance policies and procedures related to the alternatives platform
• Perform periodic risk assessments of the alternatives business to identify gaps and strengthen controls
• Proactively identify and champion opportunities to improve compliance efficiencies and minimize risks
• Strong knowledge of the Investment Advisers Act of 1940 and CFTC/NFA requirements, and working knowledge of FINRA, federal securities regulations and securities industry practices
• Experience performing operational/compliance due diligence on private equity/hedge fund managers
• Experience in service provider oversight (e.g., sub-advisers, fund administrators, etc.)
• Excellent client focus, accurate and logical problem solving, strong written and oral communication skills
• Good team player; able to work well with team members
• Strong leadership and management skills; able to obtain buy-in from relevant stakeholders
• Self-motivated. Ability to work independently, on multiple deadline-orientated tasks in a high energy environment, and prioritize based on regulatory/operating risk and business needs
• Strong interpersonal skills; able to work with all levels of staff and Management.
• Build and maintain good relationships with internal and external business partners.
• Good organizational and time management skills. Ability to work under pressure and deliver assignments on schedule
• 5-7 years of experience in the financial services industry
• Bachelor's degree
• JD, MBA, or other advanced degree strongly preferred