Compliance Officer Spotlight: Justin Hirsch
Justin Hirsch | Octagon Capital Management, LLC
How did you find yourself working in a compliance role?
My background lies in accounting, and I started out working as an auditor, then at a fund administrator, and subsequently at hedge funds. My previous firm ran a fairly lean office and we all wore multiple hats. While I focused on fund accounting and management company books and records, compliance was another part of the business that I was tasked with overseeing, eventually taking on the CCO title. I have always been super organized, which I believe is half the battle with compliance, so I looked forward to the challenge and worked to build out a robust compliance program.
What does your typical day-to-day look like?
Every day is a new trading day, and with it brings new challenges. On a daily basis, I focus on certain tasks, such as monitoring our portfolios, trade allocation, and best execution. While there are daily tasks that need to be done, I also keep a compliance calendar that specifies all of the tasks I need to accomplish throughout the year. This includes various filings, employee certifications, as well as reviewing documents and other aspects of our compliance program. I keep a copy of each month's calendar printed on my desk and review it daily to ensure that I meet all of our deadlines and fulfill my responsibilities as the CCO.
What are some of the more challenging aspects of your role as a compliance officer?
Octagon Capital newly launched, so the biggest present challenge is building a compliance program from the ground up and focusing on registration. At my previous firm, we were registered in both the United States and Canada, so I was responsible for compliance in both countries. In Canada, they don't have just one regulatory body like the SEC in the United States; each province potentially has different regulations. It is intimidating enough to learn about and understand the regulations of a foreign country, but adding the complexity of provincial differences makes that task even more daunting. It was very rewarding over my years there to gain the knowledge to be able to build a successful compliance program in both the US and Canada. Successfully passing reviews by both the SEC in the US and OSC in Canada was very gratifying and the icing on the cake.
How do you leverage Titan Regulation to assist with your duties as a compliance officer?
Titan Regulation assists us with registration, putting together documents including our compliance manual and code of ethics, performing reviews of our compliance program, and assisting with preparing certain SEC filings. At my previous firm, Titan was very involved when we were examined by the SEC, both by being in the office and with assisting in organizing the documents requested. What I like most about Titan Regulation is that they really take the time to learn and understand your business, determine what the high-risk areas are, and work together to ensure we have the necessary policies & documentation to best monitor these areas.
Titan has robust systems to help track applicable deadlines and ensure we stay well ahead of schedule. Another area where Titan was particularly additive at my previous firm was our annual compliance review. Specifically, we worked together to schedule four quarterly on-site sessions each year, over the course of which all relevant areas were subject to review. Titan helps maintain a discipline to stay on schedule, and also brings an independent, outside perspective to the reviews. For these functions, as well as other matters that arise from time to time, the Titan consultants are experienced and responsive, and are able to provide helpful guidance when questions arise.
What tools have you used that have helped you gain efficiencies in fulfilling your compliance duties? Do you have any advice you wish you could give your past self?
I believe good organization is the best way to gain efficiency as a compliance officer. You may have the best compliance program out there, but if it is not documented correctly and isn't easily accessible, it might as well not exist. Using systems for monitoring emails or personal trading obviously helps, but given the increased regulations in the past ten years, there is a lot for a compliance officer to monitor, keep track of and file. I would advise anyone in a compliance function to be diligent, not afraid to speak up, and of course, very well organized.