Title:                 Chief Compliance Officer

Date:                 April 2020

About Gresham

We are an independent investment advisory and wealth management firm that has been serving ultra-high net worth families, family offices, foundations and endowments since 1997 as an outsourced chief investment officer and a multi-family office. Based in Chicago’s loop, we have 50+ team members dedicated to serving approximately 100 clients with approximately $6 billion in assets under management and thirty plus private funds of funds.

Job Description

This role will be responsible for the management and oversight of the firm compliance program.  Gresham is a registered Investment Adviser with the Securities and Exchange Commission, and a Commodity Pool Operator and Commodity Trading Adviser with the National Futures Association.   

Responsibilities

• Prepare all written compliance policies and procedures under both SEC and NFA regulation
• Prepare and submit all regulatory filings including Form ADV Parts 1 and 2; Form CRS; Form PF; and NFA annual updates and self-exam questionnaires
• Coordinate and manage annual custody surprise asset verification exam by third-party auditor
• Review and monitor Reg 13 filings
• Administer firm Code of Ethics including review of employee personal securities transactions; affirmations; gifts and pre-clearance requests through third-party compliance portal
• Conduct annual review and risk testing; prepare and present report annually to senior management
• Oversee capital control policies and procedures, including wire review and approval, for private funds and clients
• Review and approve marketing materials and client correspondence and monitor the distribution of restricted materials under Reg D
• Prepare and oversee private fund travel and expense policies and allocation of expenditures to private funds
• Act as Chief Information Security Officer required to develop and maintain cybersecurity policies, procedures and testing; prepare incident response plan with the assistance of firm IT consultants; responsible for the review of third-party vendors and contracts; and the implementation and oversight of employee security awareness training including phishing tests.
• Prepare and conduct annual firm wide employee compliance training
• Actively monitor regulatory updates and implement changes in policy, procedures and filings to maintain regulatory compliance.
• Respond to ad hoc requests and questions concerning all areas of compliance

Key Personality Attributes

These responsibilities require a forward-thinker, who is polished and professional. An effective communicator who is extremely proactive and anticipatory. Someone who is diligent, detail oriented and resourceful. Someone with the ability to work independently and communicate effectively across all levels of the firm.  This person must have a positive can-do attitude and remain calm and graceful under pressure.

Qualifications

• Strong knowledge and experience of the Adviser Act and its applicable rules
• Exposure to private fund investments
• Knowledge of NFA CPO and CTA requirements
• Outstanding organizational, decision-making and problem-solving skills
• Expert level written and verbal communication
• A motivated individual displaying consistently high attention to detail, accuracy and thoroughness
• Highly resourceful team player, with the ability to also be extremely effective independently
• Ability to multitask and prioritize based on urgency of assignments
• Proficient in Microsoft Office (Outlook, Word, Excel and Power Point)
• Familiarity with SharePoint, CRM and Adobe Acrobat programs is a plus

Job Requirements

• Satisfy the qualifications listed above
• 4-year college degree required; legal degree or other compliance certification a plus
• 5 or more years of experience as a Chief Compliance Officer required
• Strong work tenure
• Strong relationship-builder who maintains a positive attitude, even when under stress
• Relevant references