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Administration of Code of Ethics, Policy on Insider Trading and Personal Trading Policy including: pre-clearance of employee personal trades, post-trade monitoring, quarterly and annual employee acknowledgements/attestations.
Review, analyze and respond to employee requests for personal trades that cannot be pre-cleared automatically in PTA.
Review employee brokerage accounts for appropriateness and potential conflicts of interest. Review investments in private placements.
Responsible for maintaining accurate employee records in PTA, addition and deletion of users and applicable brokerage accounts.
Post Trade Monitoring responsibilities include: reconciliations between brokerage statements/feeds to PTA, tracking receipt of confirmations and statements, as well employees' compliance with applicable blackout periods.
Review and document violations and exceptions. Conduct follow-up with the employee(s) and management as appropriate. Report to senior management quarterly.
Coordinate Quarterly and Annual employee attestations (compliance with code, personal transactions and personal brokerage accounts). Individual will need working knowledge of investments and will work closely with parent company to ensure accuracy of pre-clearance and post trade monitoring records.
Review and maintain restricted securities for personal trading.
Participate as a project team member in the implementation of new technologies (e.g. SunGard) to enhance personal trading workflow and identify opportunities to streamline processes and reporting.
Assist with conducting new hire and annual training of employees for Code of Ethics, Insider Trading & Personal Trading.
Quarterly client reporting for 17j-1 – prepare reports and certifications related to Code of Ethics and personal trading.
Assist with firm level Regulatory Filings (13f & 13g)-
Analyze holdings reports in preparation for regulatory filings.
Maintain supporting logs and records related to 13f and 13g filings.
Assist in monitoring of foreign securities holdings for potential filings in non-U.S. jurisdictions.
Assist in reviewing automated reports for Anti-money Laundering.
5+ years Compliance experience in Asset Management or related industry
Prefer experience with personal trading software (SunGard – Protogent PTA)
Analytical and detail oriented
Ability to develop effective internal/external working relationships
Leverage technical knowledge to resolve issues/problems
Learns quickly, is thorough, and can follow through on assignments and projects with minimal supervision
Creative problem-solving skills
Competency with Microsoft Office applications
Must possess strong communication, interpersonal and organizational skills
Self-motivated, willingness to work on multiple tasks and adapt to changing regulatory and business environment
Internal Number: 1018502
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