Managing Director and Chief Compliance Officer—Manulife Investment Management Private Markets Registered Funds and CQS (US), LLC

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Job Description:

Based in New York City or Boston, the role of Chief Compliance Officer—Manulife Investment Management Private Markets Registered Funds and CQS (US), LLC has the following two principal responsibilities.

Responsible for the design and management of a SEC Rule 38a-1 compliance program for two registered investment companies, a business development company, and future private markets funds regulated under the Investment Company Act of 1940 (the “RICs”). The RICs currently invest in privately originated middle market senior loans and US commercial mortgage real estate loans. 

Responsible for the design and management of a SEC 206(4)-7 compliance program for CQS (US), LLC (“CQS (US)”).  CQS (US) provides investment management services to certain privately offered onshore and offshore pooled investment vehicles investing in alternative credit, including asset-backed securities, investment grade and high yield corporate credit (including senior secured loans and convertible bonds), and equities. 

Addition to reporting to the Global Chief Compliance Officer—Manulife Investment Management Private Markets and Manulife General Account Investments, the person will also report to external boards of trustees of the RICs as well as the Global Chief Compliance Officer—CQS.

Responsibilities:

Manulife Investment Management Private Markets 38a-1 Compliance Program

• Responsible for the adoption, implementation, testing, and oversight of each RIC’s 38a-1 compliance program as well as supporting the associated investment adviser SEC Rule 206(4)-7 related compliance program elements.
• Conduct required reviews of the RICs and their service providers’ policies and procedures to ensure they adequately address legal obligations as well as existing and potential risks and conflicts of interests associated with the operation of the RICs, reviews will include compliance-related due diligence activities.
• Conduct manual pre-transaction compliance reviews and analysis of commercial mortgage loan and senior loan transactions for compliance with the terms of each RIC’s investment guidelines, the firm’s SEC 17(d) co-investment exemptive order, and Investment Company Act requirements.
• Prepare quarterly and annual compliance-related reporting and updates to various constituencies, including the boards of each RIC, Manulife management, and various investment adviser oversight governance committees.
• Work closely with law, compliance, finance, operations, and portfolio management functions to develop, document, and administer policies and procedures to assure they are (and continue to be) reasonably designed to prevent, detect, and promptly correct violations of the federal securities laws by the RICs and its service providers.

CQS US 206(4)-7 Compliance Program

• Provide compliance leadership and manage a sound Rule 206(4)-7 compliance program for CQS (US), including testing, management of regulatory examinations, training, conflict management, and regulatory filings. CQS (US) currently provides discretionary and non-discretionary investment services to certain privately offered pooled investment vehicles under the laws of (among others) the Cayman Islands, Delaware, and Ireland.  Certain sub-advisory services are provided to registered investment companies.
• Work closely with executive management, legal, and portfolio management functions to proactively address private transaction and capital position potential conflicts of interest.

Support Corporate and Other Compliance Initiatives

• Provide compliance leadership and support for ad hoc and regular Manulife/CQS corporate and compliance initiatives, including policy development, oversight committee management, internal investigations, and training development.

Job Requirements:

• A senior compliance leader with investment management experience, practical commercial instincts, and a demonstrable track record of working successfully with investment, operations, finance, legal, and compliance professionals as well as executive leadership and boards of directors. 
• Substantial experience providing compliance and/or legal support to one or more of the following investment programs, direct commercial mortgage lending, asset-backed securities, investment grade and high yield corporate credit (including senior secured loans and convertible bonds) and/or equities. 
• Strong SEC regulatory experience and an understanding of interplay of US investment management requirements with foreign regulatory r