Mutual Fund
Chief Compliance Officer
Compensation
THE 2015 MPI ANNUAL SURVEY
November 3, 2015
(First released June 25, 2015)
Todays Speakers
Susan Wyderko
President & CEO,
Mutual Fund
Directors Forum
(Moderator)
Meyrick Payne
Sr. Partner,
Management
Practice
Jay Keeshan
Partner,
Management
Practice
2
Agenda
Introduction/Survey Methodology
Participant Details
Executive Summary/Trends/Highlights
CCO Compensation/Structure
Other Benefits
Organizational Practices
3
Survey Methodology
10th Annual Survey- Since 2006
Data collection in spring, delivered in June
Mailed/emailed to database, distributed at ICI
conference
Full confidentiality assured
60 participants in 2015
Representative sample
4
Participant Details
Participating CCOs represented a total of $2.8 trillion in assets under
management. All regions of the U.S. were represented in the survey.
Boston 8%
New York 15%
Northeast *
12%
Northwest
4%
Southeast
4%
Midwest
31%West
20%
Southwest
6%
* excluding Boston/NYC
5
Participant Details
100% of participants are CCOs who are employed full time. 59% serve as
CCO to both the funds and the advisor. The average age was 48.
6
Respondents had the
following qualifications:
15% were CPAs
45% were lawyers
20% have MBAs
66% had some form of securities licensing
most common were the
Series 6, 7, 24, 26, 27,
63, and 65
18% have SEC/other regulatory experience
Complex assets were
represented as follows:
< $4 Billion
$4 Billion -- $15 Billion
$75 Billion+
$15 Billion -- $75 Billion
24%
17%
27%
32%
Participant Details
Independent contractors and fund only CCOs were in the minority; the
majority of CCOs were full-time, salaried employees and performed
duties for advisors as well as the funds.
3% 97%
Independent Contractors
Salaried Employees
41%
59%
Fund Only
Fund & Advisor
7
Survey Summary / Trends
After holding relatively flat through the financial crisis, many CCOs have now
seen steady increases over the past few years. In this years study the 60
participants received average total compensation of $389,402, versus
$361,110 last year, a gain of 7.8%.
A subset of the survey participants, which includes 31 participant CCOs for
whom data exists for two years (2013 and 2014), saw an increase in total
compensation of 13.1% over the previous year.
Bonuses for CCOs typically range from 25% to 100% percent of base pay.
While some of the highest-paid CCOs received as much as 200% or more
before the market meltdown, that number has been decreasing and in 2014 the
average bonus for large-fund CCOs was 59% of their base pay.
8
Total Compensation
9
Range of Compensation
The range of CCO compensation for the reporting fund families
was very wide and depended on many variables.
Geographic location, number of funds and portfolios, retail or
institutional distribution, number of sub-advisers, and mix of insurance
related products were among the numerous variables affecting pay
levels.
Many CCOs had been long term employees of the management
company, or had had many years of experience at another fund
company.
As a result, CCO compensation is often correlated with age or length of
experience.
10
SEC CommentsChief of Staff Buddy Donohue recently provided his top 9 considerations
for CCOs in a speech at a compliance conference in San Diego.
1. Laws, Regulations and other Requirements
2. Organization and Operations of the Firm
3. Conflicts of Interest
4. Clients of the Firm
5. Compliance and Other Systems
6. Policies and Procedures
7. Markets and Business Practices
8. Culture of the Firm
9. What DONT I Know?
11
Bonus as a Factor
in Total Compensation
While base salaries are relatively stable, bonuses are a significant factor in total
compensation. The proportion of bonus as a percentage of total pay often
grows with the size of the complex. CCOs at the largest complexes$75
billion and abovereceived higher percentage bonuses, typically about 50% to
100% of base pay.
$0
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
$0 to $4bn $4bn to $15bn $15bn-$75bn Above $75bn
Average CCO Compensation - 2014
Bonus
Base
12
CCO Total Compensation:
Assets up to $4 Billion
The average for this group was
$300,032 with a range of $179,634
to $420,429 within one standard
deviation.
The full range was from roughly
$140,000 to $550,000.
Bonuses for this group averaged
approximately 38% of base pay
and 26% of total pay.$0
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
$700,000
$800,000
CCO Total Compensation(AUM < $4bn)
13
$0
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
$700,000
$800,000
CCO Total Compensation(AUM $4bn - $15bn)
CCO Total Compensation:
Assets $4 Billion to $15 Billion
The average for this group was
$314,533 with a range of $202,174
to $426,891 within one standard
deviation.
The full range was from roughly
$170,000 to $630,000.
Bonuses for this group averaged
approximately 37% of base pay
and 24% of total pay.
14
$0
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
$700,000
$800,000
$900,000
CCO Total Compensation(AUM $15bn - $75bn)
CCO Total Compensation:
Assets $15 Billion to $75 Billion
The average for this group was
$506,946 with a range of $297,999
to $715,892 within one standard
deviation.
The full range was from roughly
$165,000 to $925,000.
Bonuses for this group averaged
approximately 57% of base pay
and 30% of total pay.
15
$0
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
$700,000
$800,000
$900,000
$1,000,000
CCO Total Compensation(AUM > $75bn)
CCO Total Compensation:
Assets $75 Billion +
The average for this group was
$570,800 with a range of $379,950
to $761,650 within one standard
deviation.
The full range was from roughly
$300,000 to $900,000.
Bonuses for this group averaged
approximately 59% of base pay and
30% of total pay.
16
Influence on Bonus
The vast majority of full-time CCOs (95%) receive a bonus as a part of
their total compensation. Management companies and increasingly
fund boards each have a strong influence in setting bonuses.
17
17%
89%
66%78%
96%
9%
68% 70% 70%
91%
FundPerformance
CorporatePerformance
CCOWorkplan
BoardDiscretion
ManagementDiscretion
Factors Influencing Bonus for Full Time CCOs
2014
2007
Compensation Comparisons
CCOs with different duties and backgrounds on average receive
varying levels of compensation.
$389,402
$316,958
$437,007 $437,268
$320,696$355,221 $369,703
ParticipantAverage
Fund-onlyCCOs
Advisor &Fund CCOs
Lawyers CPAs NonLawyer/CPA
SEC Exp.
Average Total Compensation
18
Other Benefits
19
Employee Benefits
The CCO position benefits are typical for an officer of his/her salary
grade (Full-time salaried employees).
33%
13%
98%
98%
22%
33%
25%
19%
57%
29%
25%
92%
98%
32%
46%
34%
26%
79%
Restricted Stock
Stock Options
Vacation for Eq. Pay Grade
Current Health Benefits
Retirement Health Benefits
Perqs. For Equiv. Pay Grade
Deferred Comp.
Defined Benefit Pension
Defined Contrib. Plan/401K
2007
2014
20
Organizational Practices
21
Additional Duties
The majority of participant CCOs perform other functions for the funds,
management, or both.
83%
36%
35%
71%
52%
72%
32%
54%
51%
Board Support
Global Responsibilities
Internal Audit
Risk Management Support
Legal Support 2007
2014
22
CCO Internal Reporting
44% of CCOs report internally to the CEO; 22%
