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Executive Director
Canadian Imperial Bank of Commerce
New York, NY, United States
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Description
JOB PURPOSE
The U.S. Capital Markets Compliance Officer is responsible for performing important advisory and surveillance functions to support CIBC’s US Compliance program. The Compliance Officer 1) administers key policies; 2) monitors activities to ensure compliance with CIBC policies and industry regulatory requirements; 3) advises employees on specific regulatory requirements; and 4) maintains procedures to ensure that certain controls are appropriately documented and performed.
KEY ACCOUNTABILITIES
The U.S. Capital Markets Compliance Officer is primarily accountable for:
• Providing ongoing Compliance advisory services to the U.S. Capital Markets Prime Brokerage business, which includes liaising with external regulators (e.g. FINRA, Federal Reserve), internal infrastructure support and front office personnel, in the development and implementation of CIBC’s new prime brokerage product offering;
• Providing ongoing Compliance advisory services to sales and trading personnel within U.S. Capital Markets Equity Derivatives Business. This includes providing real-time advisory support to the respective desk and collaborating with the Head of US Equity Derivatives Trading and the Regulatory Supervision team;
• Providing ongoing Compliance advisory services to infrastructure support teams in Finance, Operations, Client Services, Trade Control and Technology, covering operational requirements such as Net Capital (15c3-1), Customer Protection (15c3-3), Margin (Reg T and Reg U), Reg SHO, 10b-10 confirms, Prospectus Delivery, Unregistered Offerings;
• Providing ongoing advisory services and monitoring of CIBC’s regulatory reporting, including, but not limited to, FINRA INSITE, Form Custody, FOCUS Filings, Reg-T Extensions, Short Interest Reporting, EBS, OATS, LOPR (OTC & Listed), CAT NMS (upon go-live) and Section 13 Filings.
• Monitoring the activities of CIBC’s Prime Brokerage and Equity Derivatives businesses to assess overall compliance with regulatory rules;
• Drafting and maintaining key policies and procedures;
• Collaborating with Technology and front office personnel on the development and implementation of solutions to address new regulatory requirements, second line of defense monitoring and surveillance capabilities ;
• Assisting senior Compliance officers in coordinating U.S. regulatory exams by regulators such as FINRA, CFTC, SEC and the Chicago Federal Reserve and audits of Compliance by Internal Audit;
• Performing risk assessments of U.S. regulatory requirement group topics to determine risk ratings under CIBC’s Legislative Compliance Management framework;
• Performing electronic communications surveillance of U.S. Capital Markets personnel to identify issues of potential regulatory concern;
• Evaluating new business initiatives, regulatory developments and proposing customized compliance solutions within the firm’s risk tolerance and regulatory requirements
• Identify potential areas of compliance vulnerability, risks and developments and lead projects related to the enhancement of the compliance program and strategic initiatives;
CROSS-FUNCTIONAL RELATIONSHIPS
This job requires interaction with:
• Line of business staff to inquire about issues of potential regulatory concern and to advise on Compliance related matters;
• Infrastructure support groups (e.g., Finance and Operations) to collaborate on control issues;
• US Legal to seek interpretive guidance on technical regulatory requirements;
• U.S. regulators and CIBC Internal Audit staff during regulatory exams and audits; and
• Technology in order to continually evaluate and enhance systems to address specific regulatory requirements and surveillance reports to achieve optimal efficiency and ensure accurate criteria;
COMPLIANCE REQUIREMENTS/RESPONSIBILITIES
• As an employee of CIBC, the incumbent must comply with all applicable CIBC and Line of Business policies, standards, guidelines and controls.
• As a Compliance Officer, this job is accountable for reviewing the work of others in the business unit to ensure adherence with all CIBC and LOB governance requirements;
• As an employee of CIBC, the incumbent must complete all annual training requirements
AUTHORITIES/DECISION RIGHTS
As a key contributor to Compliance, this job has:
• The authority to recommend changes to U.S. policies and procedures to ensure that relevant regulatory requirements are properly documented and processes are developed and implemented done in the most effective and efficient manner to achieve regulatory compliance;
• The authority to represent Compliance on internal projects relating to the development and implementation of trading and trade reporting systems for derivatives and related cash products
KNOWLEDGE AND SKILLS
• 4-year undergraduate degree;
• Subject matter expertise on rules and regulations pertaining to prime brokerage, equity finance and securities lending businesses required;
• Subject matter expertise on SEC, FINRA, OCC and Options Exchange rule requirements pertaining to CIBC’s Equity Derivatives business required;
• Minimum 7 years of experience in Legal, Compliance or Regulatory role required;
• Understanding of portfolio margining and synthetic prime brokerage a plus;
• Understanding of U.S. regulatory landscape, with a familiarity with the Volcker Rule and CFTC/SEC swaps rules a plus;
• Strong interpersonal skills in order to maintain working relationships;
• Excellent verbal and writing skills;
• Series 7 preferred, (Series 3, 4, 24, 30, 57 licenses are a plus)