Compliance Manager

Company: Universa Investments L.P.

Reports to: Chief Compliance Officer / General Counsel

Function: Legal & Compliance

Position Summary: The Compliance Manager is responsible for the day-to-day operational execution of Universa's compliance program under the direction and supervision of the Chief Compliance Officer (CCO). Acting as the CCO's designee, the Compliance Manager owns the ongoing operation of the program — monitoring, testing, documentation, regulatory filing execution, calendar management, and the surfacing of compliance risks — while approval authority, final judgment, and privileged legal functions remain with the CCO.This role carries execution and monitoring responsibility rather than legal strategy or final policy approval. The Compliance Manager is expected to act independently on routine operational matters and to escalate interpretive, legal, and higher-risk questions to the CCO.

Key Responsibilities: Monitoring, Testing & Program Operation

• Conduct ongoing monitoring of day-to-day compliance with the firm's policies and procedures, fund governing documents, investor agreements, and other agreements, flagging exceptions to the CCO.
• Perform internal reviews and forensic testing to confirm program effectiveness and identify weaknesses; compile and analyze results. Own the first-level periodic review of trade allocation, leveling, and non-pro-rata allocations by extracting and organizing data, preparing review schedules, identifying anomalies, and escalating items for discussion with the CCO and trading desk.
• Monitor and log client registrations on an ongoing basis. Changes or concerns in registration are recorded and escalated to the CCO.
• Lead the annual compliance-program review process under Rule 206(4)-7 by collecting and analyzing the underlying data and preparing the draft review; the CCO prepares/finalizes the formal narrative, reviews the work, and certifies the annual review.
• Administer employee personal-trading pre-clearance: receive requests, run the 30-day hold, 15-day re-entry, and two-day client-blackout checks, and escalate to the CCO for approval and judgment calls.
• Collect Holdings Reports and quarterly Certificates of Compliance, process new-proprietary-account intake, and gather duplicate confirmations and brokerage statements.
• Review employee non-discretionary account representations and serve as delegated backup to the CCO when the CCO is unavailable; otherwise refer control-or-influence determinations to the CCO.
• Monitor personal securities trading, political contributions, outside business activities, and gifts and entertainment against firm policy; maintain the associated logs and escalate potential conflicts.

Key Responsibilities: Filings, Recordkeeping & Documentation

• Maintain the firm's compliance calendar, tracking all regulatory, client-reporting, and compliance deadlines.
• Own the preparation and operational execution of recurring regulatory filings, including Form ADV, Form PF, CPO-PQR, NFA-PQR, and applicable Bureau of Economic Analysis (BEA) filings, with CCO review and sign-off as required; complete recurring NFA member requirements (Annual Questionnaire, Self-Examination Questionnaire, Bylaw 1101 verification).
• Maintain the firm's compliance books and records — trading, contribution, gift, complaint, and personal-trading record sets — in accordance with the Advisers Act and firm policy.
• Administer the firm's electronic-communications supervision: Global Relay email/IM archiving, quarterly personal-device certifications, and periodic documented reviews.
• Draft proposed updates to policies and procedures and written supervisory procedures for CCO review.
• Maintain the trade-error log; conduct the initial investigation with the trading desk; and prepare error memoranda for the CCO's review and sign-off.
• Maintain the third-party vendor and service provider log; confirm due diligence schedule and pending responses with CCO.
• Track and record Taft-Hartley and government-official payments for DOL reporting, with the CCO or counsel completing the filing.

Key Responsibilities: Policy Adherence, Risk Flagging & New Programs

• Serve as the day-to-day compliance resource for staff on policy-adherence questions, including day-to-day implementation and enforcement of the firm's Artificial Intelligence policy in coordination with Information Technology; escalate interpretive, policy, or legal questions to the CCO.
• Review marketing and promotional material against SEC Marketing Rule and NFA 2-29 requirements; independently clear routine or simple material within expressly delegatedauthority and escalate higher-risk or non-routine items to the CCO, who retains final sign-off on performance and hypothetical-performance advertising and other non-delegated items.
• Review the firm's website and social media for Marketing Rule compliance (periodically and on change), maintain change logs, and retain marketing material with CCO approvals.
• Administer the firm's AML operational program as the AML Officer's designee, including OFAC/watchlist screening, suspicious-activity review, investor due-diligence review, and AML training coordination.
• Run the Identity Theft Red Flags program within the redemption/withdrawal process; monitor regulatory developments and summarize relevant changes for the CCO.
• Coordinate compliance-side information-security and privacy work with Information Technology and Operations, including WISP and incident-response readiness; perform Regulation S-P service-provider/vendor due diligence and bring results to the CCO for sign-off.
• Administer the nuts-and-bolts operation of the firm's Remote and Home Office Supervision policy, with approvals and material exceptions escalated to the CCO.
• Coordinate compliance-side maintenance and periodic testing of the Business Continuity Plan with Information Technology; document results and escalate material issues to the CCO, who retains final oversight and sign-off.

Additional Information: Universa Investments L.P. is an Equal Opportunity Employer and does not discriminate on the basis of race, color, religion, sex, age, national origin, disability, pregnancy, genetic information, sickle cell trait, marital status, familial status, veteran status, citizenship status, sexual orientation, gender identity, gender expression, actual or perceived status as a victim of domestic violence, dating violence, or stalking, or any other status entitled to protection under applicable federal, state, or local anti-discrimination laws. This job description is not an employment agreement or contract, implied or otherwise, and may be revised by the firm at any time.