Chief Compliance Officer

About the Firm:

Fuller & Thaler Asset Management, Inc. (“FullerThaler”) is a 100% employee-owned boutique asset manager founded in 1993 and headquartered in San Mateo, California. The firm applies behavioral finance, including Nobel Prize-winning research by co-founder Dr. Richard Thaler, to long-only U.S. equity strategies across mutual funds, ETFs and separately managed accounts. With approximately 30 employees and over $38 billion in assets under management and advisement, we serve institutional and retail investors, including ERISA plan sponsors.

The firm ranks #4 in market share in fully active US small cap funds, based on firm-level aggregate AUM.  We have been the #1 market-share gainer in the category over the last five years. As a 100% employee-owned firm, FullerThaler values its reputation and offers a distinctive ownership culture focused on long-term success, collaboration, and intellectual curiosity.

Position Overview:

The CCO will serve as the firm's sole, enterprise-wide compliance professional and own the SEC Rule 206(4)-7 compliance program. This hands-on senior role requires a self-directed CCO who can independently manage the program, work with FullerThaler personnel who contribute inputs and oversee outsourced support, coordinate with fund CCOs, and apply sound judgment across adviser, fund, ERISA, marketing, trading, and all communications. The CCO is expected to support business objectives while maintaining regulatory standards and independent judgment.  Depending on how soon the new CCO can start, there is an opportunity to overlap with the departing CCO to transition responsibilities seamlessly.

FullerThaler advises funds within the Capitol Series Trust and serves as sub-adviser to a J.P. Morgan fund. The CCO will coordinate with each fund complex's Rule 38a-1 CCO on board reporting, filings, certifications, examinations, and adviser-level compliance matters affecting the funds.

This role reports to the Managing Partner with dotted-line to the Board.

Depending on the background and skills of the person filling this position, there is an opportunity to take on broader responsibilities over time across legal, operations, risk or tax as the firm grows and your expertise deepens.

Core Responsibilities:

Adviser Compliance Program (Investment Advisers Act of 1940)

• Design, maintain, test, and enforce written compliance policies and procedures under Rule 206(4)-7.
• Administer the Code of Ethics under Rule 204A-1, including personal trading, holdings and transaction reporting, gifts and entertainment, outside business activities, and political contributions.
• Prepare and oversee adviser regulatory filings, including Form ADV, Section 13 filings, Schedule 13 ownership reports, and state notice filings.
• Maintain books and records under SEC Rule 204-2.
• Conduct the annual compliance review and report results to senior management.
• Monitor portfolio management and trading for conflicts, best execution, trade allocation, soft-dollar arrangements, and conformity with investment guidelines.
• Review, recommend alternative/narrower phrasing as needed, and approve marketing materials, website content, performance presentations, RFP responses, and client communications under the SEC Marketing Rule (Rule 206(4)-1), including GIPS® composites with third-party verification.
• Oversee privacy, electronic communications, cybersecurity, business continuity, vendor due diligence, and related policies, including Reg S-P and Reg S-ID.
• Manage outside compliance counsel, outsourced compliance service providers, and compliance technology vendors.  Work with FullerThaler personnel who contribute inputs to the compliance program.
• Serve as primary contact for SEC examinations and state inquiries.

Coordination with Fund Complex CCOs (Investment Company Act of 1940)

FullerThaler's mutual funds and ETFs are series of the Capitol Series Trust, and the firm also serves as sub-adviser to a J.P. Morgan fund. The adviser CCO will:

• Coordinate with Capitol Series Trust and J.P. Morgan fund CCOs by providing timely certifications, compliance information, testing results, and access to the adviser compliance program.
• Support annual fund CCO reports, fund board reporting, and the 15(c) contract renewal process.
• Ensure adviser compliance with applicable Investment Company Act requirements, including affiliated-transaction restrictions and other fund-related obligations.
• Monitor ETF-specific requirements under Rule 6c-11 and applicable listing exchange rules.

Institutional, Wrap Fee, and Model Delivery Compliance

• Monitor institutional separate account guidelines, restrictions, and client-specific mandates.
• Oversee ERISA fiduciary compliance for retirement plan clients, including fiduciary-status documentation, DOL investment-advice rules, and prohibited transaction rules and exemptions.
• Oversee compliance for wrap-fee and model-delivery relationships, including agreements, disclosures, best execution considerations, information barriers, and model dissemination timing.

Review and Advice for Agreements

• Review and advise on terms of advisory and sub-advisory agreements, prospectuses, and related compliance provisions to meet client and regulatory needs while minimizing operational cost/complexity.

Employment Law Compliance

• Oversee the firm’s compliance with applicable federal, state, and local employment laws and workplace regulatory requirements.
• Maintain and periodically review employee policies, codes of conduct, and mandatory training programs (harassment and violence prevention, cybersecurity, ethics, etc.).
• Coordinate with outside employment counsel and HR advisors regarding workplace investigations, employee relations matters, and regulatory risk management.

Tax Compliance

• Oversee compliance with tax laws for separate accounts and pooled vehicles, including redemption-in-kind and custom baskets for mutual funds and ETFs.

Monitoring and Training

• Oversee incident reporting, breach resolution, risk escalation, remediation plans, and control enhancements.
• Design and deliver firmwide compliance training on the Code of Ethics, insider trading, marketing, privacy/cybersecurity, and ERISA fiduciary topics.  Foster a culture of compliance and ethical conduct throughout the organization.
• Track relevant SEC, DOL, GIPS, ETF, enforcement, risk-alert, and industry developments and translate them into practical program updates.

Potential Expanded Scope

• Depending on background, interests, and firm needs, the role may expand over time into legal, operations, tax, and/or or risk-governance responsibilities.

Qualifications:

Required

• 7-10+ years of progressively responsible compliance experience at an SEC-registered investment adviser, including meaningful exposure to the Investment Company Act and registered fund structures.
• Demonstrated ability to operate independently as the sole compliance officer or a "department of one" managing a full adviser compliance program without dedicated staff.
• Deep working knowledge of the Investment Advisers 1940 Act and related SEC rules. Solid familiarity with the Investment Company 1940 Act, including adviser CCO and fund CCO roles under Rules 206(4)-7 and 38a-1.
• Working knowledge of ERISA fiduciary standards, DOL investment-advice rules, and prohibited transaction rules.
• Experience with GIPS compliance, including composite construction, performance presentation requirements, and third-party verifier coordination.
• Direct experience with SEC examination processes.
• Familiarity with equity portfolio management, trading operations, and investment guideline monitoring in a long-only equity context.
• Experience reviewing marketing materials and performance presentations.
• Excellent written and verbal communication skills with fund boards, fund CCOs, regulators, outside counsel, and senior management.
• Strong judgment, integrity, confidence to raise issues, and ability to balance regulatory obligations with business objectives while maintaining independent judgment.
• Willing to relocate to (or already based in) the San Francisco Bay Area.

Preferred

• JD, required if the title includes Senior Counsel.
• Relevant credentials such as IACCP/CSCP, CFA, CPA, CRCM, or MBA.
• Experience with ETF-specific compliance requirements, including Rule 6c-11, custom basket policies, and authorized participant agreements.
• Experience with compliance and OMS technology (e.g., Orion/BasisCode, LiqudityBook), GIPS verification, outsourced service-provider oversight, or international or long-short equity asset management.
• Interest in responsibly using AI and workflow automation (e.g., Claude Cowork, etc.) to improve compliance processes, with appropriate controls for accuracy, confidentiality, and hallucination risk.

What We Offer:

• A senior, visible role at a 100% employee-owned firm with a distinctive investment culture grounded in Nobel Prize–winning research.
• Direct interaction with senior leadership and fund-board engagement through fund CCO relationships.
• Competitive compensation, including base salary in the range of $250,000 to $325,000, annual performance bonus, and eligibility for equity ownership.  Pay is based on a number of factors including education, job-related knowledge, skills, and experience, certifications, and other job and business-related factors.
• Comprehensive benefits and a collaborative, intellectually curious, collegial work environment.

A background check will be conducted after a conditional offer of employment. Please refer to our Applicant Privacy Notice which contains important information on how we handle your nonpublic personal information.