ABOUT THIS ROLE
About Apex Asset Management
Apex Asset Management (AAM) is a Registered Investment Adviser offering investment advisory services through three relationship types: sub-advisory, co-advisory, and solicitor/promoter. AAM provides multiple portfolio options utilizing ETFs, US-listed equities, mutual funds, and model portfolios determined by either the End Investor or the End Investor’s Investment Adviser. AAM leverages the scale and centralized support of Apex Fintech Solutions Inc.
The Opportunity
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. You will serve as the primary point of contact for regulators and internal stakeholders, establishing a robust, right-sized program aligned to the Advisers Act and industry best practices.
What You will Do
Program leadership and governance
- Design, implement, 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 a comprehensive conflicts of interest inventory and compliance risk register; run or participate in compliance and risk committee meetings; deliver regular compliance reporting/metrics to AAM and Apex leadership.
- Partner with Legal, Operations, Product, and Technology on governance, new initiatives, and regulatory requirements.
Regulatory filings and exams
- Own and maintain regulatory filings: 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.
- Serve as the lead for SEC and state examinations and inquiries: readiness, document production, interview prep, responses, and remediation.
Marketing, solicitation, and communications
- Oversee compliance with the SEC Marketing Rule (Rule 206(4)-1), including review/approval of marketing, performance presentations, testimonials/endorsements, third-party ratings, and web/social content for ETF, equity, mutual fund, and model portfolio strategies.
- Design and oversee solicitor/promoter programs: compliant agreements, disclosures, delivery/acknowledgment processes, compensation reviews, training, and ongoing monitoring.
Portfolio, trading, and code of ethics
- Oversee portfolio and trading compliance for discretionary and non-discretionary programs: 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.
- 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).
- Ensure compliant books and records (Rule 204-2), privacy and information security coordination (Reg S-P) with enterprise teams, and appropriate recordkeeping for electronic communications.
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
- 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
- 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.
- Partner with enterprise compliance to leverage shared services and ensure alignment with enterprise standards while meeting AAM’s specific regulatory obligations.
Training and culture
- Deliver targeted training for investment personnel, sales/marketing, operations, and promoters/solicitors; maintain attestation processes.
- Promote a culture of compliance that enables scale, speed to market, and strong client outcomes.
What You will Bring
- 7–10+ years of investment adviser/asset management compliance experience, including building or running Advisers Act programs.
- 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.
- Direct experience with sub-advisory and co-advisory arrangements and with solicitor/promoter programs, including agreement terms, disclosure, and oversight.
- 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.
- Experience in fintech or with broker-dealer affiliates and shared-services operating models.
- Familiarity with UMA/SMA platforms, model marketplaces, and advisor-directed programs.
#compliance #mid-senior #full-time #LI-MJ1 #APEX
Please note this job description is not designed to cover or contain a comprehensive listing of activities, duties, or responsibilities required of the employee for this job. Duties, responsibilities, and activities may change at any time with or without notice.
Our Rewards
We offer a robust package of employee perks and benefits, including healthcare benefits (medical, dental and vision, EAP), competitive PTO, 401k match, parental leave, and HSA contribution match. We also provide our employees with a paid subscription to the Calm app and offer generous external learning and tuition reimbursement benefits. At AFS , we offer a hybrid work schedule for most roles that allows employees to have the flexibility of working from home and one of our primary offices.
Salary Range
$139,600-$174,500
The annual base salary range for this position is noted above. Exact compensation offered may vary depending on job-related knowledge, skills, experience, and office location.
