Senior Manager, Compliance

At Apex Asset Management (AAM), we offer investment advisory services through three relationship types: sub-advisory, co-advisory, and solicitor/promoter. AAM leverages the scale and centralized support of Apex Fintech Solutions Inc. to provide multiple portfolio options using ETFs, US-listed equities, mutual funds, and model portfolios determined by either the End Investor or the End Investor’s Investment Adviser.

About This Role

We are seeking a Senior Manager to build, own, and operate AAM’s compliance program for a modern, fast-growing advisory business. This role is the dedicated compliance manager for AAM and partners closely with Apex Fintech Solutions’ centralized compliance team for certain shared-services support.

• Program Leadership and Governance:
• Design, Implement, and Maintain Compliance Program: Develop and maintain AAM’s Advisers Act compliance program (Rule 206(4)-7), including risk assessment, policies and procedures, compliance calendar, testing/surveillance, issues management, and the annual review with written reporting to leadership.
• Maintain Conflicts Inventory and Compliance Risk Register: Keep a comprehensive inventory of conflicts of interest and compliance risks, participate in compliance and risk committee meetings, and deliver regular compliance reporting/metrics to AAM and Apex leadership.
• Partner with Departments: Collaborate with Legal, Operations, Product, and Technology on governance, new initiatives, and regulatory requirements.
• Regulatory Filings and Exams:
• Own and Maintain Regulatory Filings: Manage Form ADV Parts 1 and 2A/2B, Form CRS (as applicable), state notice filings, IARD/CRD maintenance, and investment adviser representative registrations/updates. Manage other applicable securities filings and notifications (e.g., Section 13F; large trader) as required by AAM’s activities.
• Manage SEC and State Examinations: Prepare for and respond to SEC and state examinations and inquiries, including readiness, document production, interview prep, responses, and remediation.
• Marketing, Solicitation, and Communications:
• Compliance with SEC Marketing Rule: Review and approve marketing, performance presentations, testimonials/endorsements, third-party ratings, and web/social content for ETF, equity, mutual fund, and model portfolio strategies.
• Solicitor/Promoter Programs: Manage end-to-end referral arrangements under the Marketing Rule, including agreement terms, required disclosures, compensation structures, delivery evidence, and periodic oversight/testing.
• Portfolio, Trading, and Code of Ethics:
• Portfolio and Trading Compliance: Ensure best execution reviews, trade aggregation/allocation fairness, broker selection, use of research/soft dollars (Section 28(e)), trade error handling, and valuation governance for managed accounts.
• Code of Ethics: Maintain Code of Ethics (Rule 204A-1) and related controls: personal trading, restricted lists/MNPI, gifts and entertainment, political contributions/pay-to-play (Rule 206(4)-5).
• Relationship-Type Oversight:
• Sub-Advisory: Conduct diligence and onboarding, review IMAs and guidelines, define reporting and data-sharing protocols, monitor sub-adviser performance/controls, coordinate marketing approvals, and manage breach/incident escalation.
• Co-Advisory: Document and monitor delineation of roles/authority, disclosures regarding shared or split discretion, supervision/testing of shared activities, and operational controls across parties.
• Solicitor/Promoter: Manage end-to-end referral arrangements under the Marketing Rule, including agreement terms, required disclosures, compensation structures, delivery evidence, and periodic oversight/testing.
• Client and Model Governance:
• Controls for Programs: Establish controls for programs where the End Investor or their Investment Adviser determines the model/strategy: documentation of discretionary vs. non-discretionary authority, suitability/appropriateness workflows where applicable, client-specific restrictions, rebalancing/drift thresholds, and error-correction. Implement monitoring for guideline compliance and restriction breaches across ETFs, equities, and mutual funds.
• Third Parties, Data, and Enterprise Collaboration:
• Vendor and Service Provider Due Diligence: Lead vendor and service-provider due diligence and ongoing oversight (e.g., trading/OMS/PMS, data, tech), coordinating with Apex’s centralized vendor risk, cybersecurity, privacy, and business continuity programs.
• Enterprise Compliance Alignment: Partner with enterprise compliance to leverage shared services and ensure alignment with enterprise standards while meeting AAM’s specific regulatory obligations.
• Training and Culture:
• Training Delivery: Deliver targeted training for investment personnel, sales/marketing, operations, and promoters/solicitors; maintain attestation processes.
• Culture Promotion: Promote a culture of compliance that enables scale, speed to market, and strong client outcomes.

Qualifications

• Experience: 7–10+ years of investment adviser/asset management compliance experience, including building or running Advisers Act programs.
• Knowledge: Deep knowledge of the Investment Advisers Act and key rules: 206(4)-7 (compliance programs), 206(4)-1 (Marketing), 204-2 (books and records), 204A-1 (Code of Ethics), 206(4)-5 (Pay-to-Play); strong command of best execution, trade allocation, soft dollars, custody considerations, privacy (Reg S-P), and state notice filings.
• Experience: Direct experience with sub-advisory and co-advisory arrangements and with solicitor/promoter programs, including agreement terms, disclosure, and oversight.
• Skills: Proven ability to review and approve marketing and performance materials across ETF, equity, mutual fund, and model portfolio strategies. Hands-on leadership of SEC or state exams from readiness through remediation. Excellent policy drafting, communication, and stakeholder management skills; data-driven approach to monitoring and testing. Comfortable operating as both strategist and individual contributor; able to influence and execute in a fast-paced environment.
• Additional: Experience in fintech or with broker-dealer affiliates and shared-services operating models. Familiarity with UMA/SMA platforms, model marketplaces, and advisor-directed programs.

What You Will Bring

• Experience: 7–10+ years of investment adviser/asset management compliance experience, including building or running Advisers Act programs.
• Knowledge: Deep knowledge of the Investment Advisers Act and key rules: 206(4)-7 (compliance programs), 206(4)-1 (Marketing), 204-2 (books and records), 204A-1 (Code of Ethics), 206(4)-5 (Pay-to-Play); strong command of best execution, trade allocation, soft dollars, custody considerations, privacy (Reg S-P), and state notice filings.
• Experience: Direct experience with sub-advisory and co-advisory arrangements and with solicitor/promoter programs, including agreement terms, disclosure, and oversight.
• Skills: Proven ability to review and approve marketing and performance materials across ETF, equity, mutual fund, and model portfolio strategies. Hands-on leadership of SEC or state exams from readiness through remediation. Excellent policy drafting, communication, and stakeholder management skills; data-driven approach to monitoring and testing. Comfortable operating as both strategist and individual contributor; able to influence and execute in a fast-paced environment.
• Additional: Experience in fintech or with broker-dealer affiliates and shared-services operating models. Familiarity with UMA/SMA platforms, model marketplaces, and advisor-directed programs.

Our Rewards

• Healthcare Benefits: Medical, dental, and vision insurance, Employee Assistance Program (EAP), and competitive PTO.
• Financial Benefits: 401(k) match, parental leave, and HSA contribution match.
• Other Perks: Paid subscription to the Calm app, external learning and tuition reimbursement benefits, and a hybrid work schedule for most roles.

EEO Statement

Apex Fintech Solutions is an equal opportunity employer that does not discriminate on the basis of race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age, disability, veteran status, marital status, or any other protected characteristic. Our hiring practices ensure that all qualified applicants receive fair consideration without regard to these characteristics.

Disability Statement

Apex Fintech Solutions is committed to creating an inclusive and accessible workplace for all candidates, including those with disabilities. We are dedicated to ensuring equal employment opportunities and providing reasonable accommodations to qualified individuals with disabilities.