Chief Compliance Officer (CCO) for Swap Execution Facility (SEF)
Principal Duties Responsibilities:
- CCO has oversight authority over all compliance functions and staff acting in furtherance of those compliance functions.
- CCO's authority also extends to any activities performed by the SEF to verify that other entities are in compliance with applicable laws and regulations (such as the verification of the timeliness of reporting certain swap data).
- CCO must supervise a SEF's self-regulatory program with respect to:
- trade practice surveillance;
- market surveillance;
- real-time market monitoring;
- compliance with audit trail requirements;
- enforcement and disciplinary proceedings; and
- audits, examinations and other regulatory responsibilities with respect to members and market participants.
- CCO must also supervise the effectiveness and sufficiency of any regulatory services provided to the SEF by a registered futures association or other registered entity.
- CCO must:
- establish and administer a written code of ethics, and policies and procedures, designed to prevent violations of the CEA and CFTC regulations;
- establish and administer written policies and procedures, including a compliance manual, designed to prevent violations of the CEA and CFTC regulations;
- establish and follow procedures for the remediation and closing of any noncompliance issues that are identified;
- prepare and submit to the CFTC an annual compliance report, which must include:
- a description of the SEF's written policies and procedures, code of ethics and conflicts of interest policies;
- a detailed review of the SEF's compliance with Section 5h of the CEA, including an assessment by the CCO of the effectiveness of the SEF's policies and procedures in ensuring compliance with Section 5h and a discussion of areas for improvement;
- a description of any material changes to the policies and procedures that were made since the last compliance report;
- a description of the financial, operational and staffing resources set aside for the SEF's compliance program, including a description of the SEF's compliance program, describing resources set aside for the SEF's self-regulatory responsibilities;
- a detailed description and review of the SEF's self-regulatory program, including: a description of staff associated with self-regulation; a catalogue of investigations and disciplinary actions taken; and a review of the performance of disciplinary committees and panels;
- a description of any material compliance matters, including instances of noncompliance, that were identified in the year prior to the filing of the report; and
- any objections to the annual compliance report by the SEF's board of directors or senior officer.
- meet at least annually with the board of directors to discuss the effectiveness of the CCO's administration of the SEF's compliance policies;
- meet at least quarterly with the board's Regulatory Oversight Committee ("ROC") to share information and discuss matters of mutual concern;
- liaise with regulatory service providers; and
- oversee SEF compliance with core principles, specified by 17 CFR Part 37.
Critical Knowledge, Skills Experience:
- Have substantial knowledge of, and experience with, exchange/self-regulatory organization compliance requirements, preferably obtained through management-level position(s) with one or more exchanges, SROs, or regulatory agencies.
- Five years Compliance experience at a CFTC or SEC regulated financial institution
- Knowledge of Dodd-Frank, Title VII thereunder and relevant CFTC rules
- Knowledge of OTC swaps
- Knowledge of exchange trading and the regulation thereof
- Must be able to successfully identify, implement and manage required policies, procedures, and processes
- Fundamental understanding of regulatory issues that could affect the firm
- Self-starter and able to work with other departments and build smooth working relationships
- Team player and able to prioritize in a fast moving, constantly changing environment
- Strong research skills; analytical and problem solving skills; and attention to detail
- Highly developed written and oral communication skills, and interpersonal skills
- Excellent organizational skills and ability to manage multiple tasks
Interfacing with:
- Company Executives
- Internal/External Audit
- Information Technology
- Regulatory Bodies
- Marketing, Sales and Systems Trading teams
- Product launch teams and other business units
- Strong computer skills and proficiency in Microsoft Word and Excel
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