Chief Compliance Officer
Galliard Capital Management
Exclusive Q&A with Jennifer Lammers from Galliard Capital Management
Hi Jennifer, can you tell us a bit about yourself and your role as Chief Compliance Officer at Galliard Capital Management?
Galliard Capital Management is an institutional investment adviser specializing in stable value and fixed income investment management. Stable value is utilized by qualified plans (such as pension and 401k). I came to Galliard after twenty years in financial services in finance and compliance. I’ve run a mutual fund group and been a CFO as well as a CCO for investment advisers, mutual funds and private equity funds.
On this side of the Atlantic, MiFID II is now in place. Its reach does of course stretch further than Europe’s borders, and is affecting US managers to varying degrees. How has the directive impacted you & Galliard so far?
The implementation of MiFID II has been interesting in that as a U.S. manager, with only U.S. operations and clients one would think that MiFID II would have no impact. However, as the large counterparties are multinational, working through confirming the inapplicability of requirements has taken more time and discussion than we expected.
Is there a US or North American domestic regulation that you would classify as a MiFID II equivalent? If not, do you believe there could be one in store for the future?
Currently I don’t think there is anything on the US side quite comparable to MiFID II. However, the Fiduciary Rule from the U.S. Department of Labor, despite the changes in timing and scope is quite significant for advisers who are not already fiduciaries. On the counterparty side, the implementation of MSFTA agreements for certain types of trades has also had some impact.
What other directives and compliance matters are consuming the majority of your team’s time and resources currently?
Although there hasn’t been one single directive or regulation that has had a major impact, each new regulation or regulatory guidance requires review and a determination of impact, even if that impact is only as a best practice rather than a requirement. And of course, if there is impact, incorporating necessary changes to a compliance program can be time consuming. In addition to MiFID II and the DOL fiduciary rule, there has been the recent custody guidance from the SEC and the liquidity rule for mutual funds.
At TSAM New York, you’ll be delivering a presentation on What the Future Holds for Compliance in Asset Management. Can you give us a little insight into what you’re keen to convey to the audience in this session?
Although it has been almost 15 years since the SEC released Rule 206(4)-7, the role of Chief Compliance Officer is even more challenging today than it was then. Staying current with industry and operational changes, new regulatory requirements, and balancing the role’s required independence with the effectiveness gained from being a trusted partner are daily challenges that can easily become overwhelming. Ideas on how to address these challenges effectively and develop necessary resources and support is my focus for me and my industry peers.
Come and see Jennifer’s presentation on What the Future Holds for Compliance in Asset Management at TSAM New York on the 13th June 2018.
Visit https://www.tsamnewyork.com/ for more details and to book your place.