Andrew Santulli Email and Phone Number

Responsible for Investment Advisory and Investment Company compliance oversight of approximately 70 Fixed Income accounts, including 1940 Act Mutual Funds, separately managed institutional accounts, UCIT Funds and German KAGB Funds. Investment strategies include Emerging Market Debt, High Yield Bond, Short Duration and Liquidity.*Assist the Chief Compliance Officer in developing policies, procedures, monitoring processes and controls to address compliance matters and compliance gaps within the organization.*Perform daily review of post-trade compliance reports to verify that accounts are compliant with investment guidelines and regulatory requirements utilizing the Bloomberg AIM compliance system.*Provide real time advice to portfolio managers and traders to ensure compliance with regulatory and investment account mandates. Approve trade overrides within the compliance system for daily trading activity on a pre-trade basis.*Participate in the account opening process, including review of investment management agreements and prospectuses, to confirm that investment guidelines are properly coded in the compliance system.*Assist in annual testing of compliance policies and procedures pursuant to Rule 38a-1 of the Investment Company Act and Rule 206(4)-7 of the Investment Advisers Act. *Review allocations of trading activity and perform post-trade conflict review for Side by Side Monitoring of performance fee accounts to ensure fairness and reasonableness across all client accounts.*Monitor Window Dressing and Portfolio Pumping to detect any signs of deceptive trading practices and market manipulation.*Participate in performing due diligence and oversight of third party sub-advisers and their compliance programs.*Assist in monitoring of employee personal trading by reviewing trade requests to certify compliance with Code of Ethics and federal securities laws.

Was responsible for reporting and monitoring of client, regulatory and firm guidelines for equity institutional accounts utilizing the Charles River Development and Linedata portfolio compliance systems.*Provided daily support and monitoring of Institutional Management and Private Bank equity client account guidelines to ensure compliance.*Analyzed daily post-trade compliance alerts to determine root causes and remediation.*Partnered with business client portfolio managers and portfolio managers to validate compliance breaches.*Maintained restricted security lists to ensure compliance with firm’s restricted security thresholds.*Performed other miscellaneous surveillance functions and ad hoc assignments.

Trained and managed a staff of 2 compliance professionals in overseeing Investment Advisory and Investment Company Compliance for approximately 25 proprietary/sub-advised funds, 200 separately managed institutional accounts, and 5 hedge fund accounts. *Assisted the Chief Compliance Officer in developing policies, procedures, monitoring processes and controls to address compliance matters and compliance gaps within the organization.*Worked closely with senior management, including portfolio managers, traders and research analysts to provide advice and guidance on compliance related matters pertaining to all product types, including equity, fixed-income and derivative securities.*Conducted annual testing of compliance policies and procedures pursuant to Rule 38a-1 of the Investment Company Act and Rule 206(4)-7 of the Investment Advisers Act. Prepared written documentation of results for submission to the Chief Compliance Officer.*Reviewed client investment advisory contract guidelines and restrictions, including soft dollar guidelines and directed trading and coded accounts accordingly.*Defined compliance requirements and certified that accounts were compliant with prospectus guidelines as well as SEC and IRS regulations. *Validated all trading errors and investment guideline breaches ensuring that appropriate measures were taken for timely resolution, reporting and remediation in order to fulfill fiduciary duty to all client accounts.*Reviewed allocations of trading activity to ensure fairness and reasonableness across all client accounts.*Served as member of the Best Execution Committee to ensure investment adviser's achievement of best execution.*Acted as liaison with outside auditors (SAS 70 reviews, mutual fund CCO reviews, and mutual fund audits) in addressing and resolving all compliance related issues.

Trained and managed a staff of 4 compliance professionals in overseeing daily post-trade compliance monitoring for the J.P. Morgan Funds consisting of approximately 150 mutual funds utilizing the Charles River Development portfolio compliance system.*Defined compliance requirements and verified that all applicable investment guidelines as well as SEC and IRS requirements were met, including rule 2a-7 of the Investment Company Act of 1940.*Reviewed monthly checklists to document compliance with all applicable fund guidelines and restrictions. Implemented improvements to checklist templates in order to enhance the compliance review process.*Interacted closely with Legal and Investment Team to ensure that updates to fund prospectuses and SAIs were made in a timely manner. *Conducted Investment Company Act training for Investment Team to confirm that portfolio managers were aware of all compliance regulations.*Prepared quarterly board materials, including 17a-7, 17e-1, and 10f -3 transactions for quarterly board meetings.*Coordinated closely with Products Team in the development and launch of new fund products.

Trained and managed a staff of 10 compliance professionals in overseeing daily post-trade compliance monitoring as an outside service provider for approximately 125 mutual funds and ETFs utilizing the Charles River Development portfolio compliance system.*Defined compliance requirements in order to verify that fund prospectus restrictions as well as SEC and IRS requirements were met.*Worked closely with legal counsel and fund auditors in preparing annual N-1A updates.*Reviewed monthly checklists to document compliance and to ensure that monthly client deliverables were met on a timely basis.

Managed the production of annual and semi-annual shareholder reports for several mutual fund and variable annuity fund groups as an outside service provider. Worked closely with fund auditors and printers in performing these functions.*Prepared updates to Form N-1A, Form N-SAR and 24f-2 filings ensuring that filings were made in a timely manner.*Evaluated fund expense accruals and authorized fund expense payments, including asset based fees.*Calculated monthly and annualized total returns for funds.

Monitored daily fund accounting performed by an outside service provider for a series of mutual funds, including equity, money market and mortgage-backed security funds. Trained and supervised a staff of 4 fund accountants in this role.*Prepared shareholder and board of directors' reports as well as updates for regulatory filings, including Forms N-SAR and N-1A ensuring that key deliverables were met in a timely manner.*Authorized fund expense disbursements and analyzed fund expense accruals.