Job Summary:
The VP Trust and Compliance (“VPTC”) of AmericanTCS Holdings, LLC (“ATCS”), reporting to the President of ATCS, is responsible for ensuring that the ATCS entities comply with internal policies, including each entity’s policies as well as those of ATCS, and with applicable requirements under relevant state and federal laws and regulatory agencies. The VPTC will serve as the ATCS expert on state and federal trust laws. The following entities are included in the ATCS organization.
- Mid Atlantic Trust Company (“MATC”) dba American Trust Custody, a South Dakota chartered non-depository trust company
- Mid Atlantic Clearing & Settlement Corporation, a securities broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”), member of the National Securities Clearing Corporation, and subsidiary of MATC
- American Trust Company (“ATC”), a Tennessee chartered non-depository trust company
- AmericanTCS Fiduciary Services, LLC (subject to ERISA but otherwise unregulated)
- AT Retirement Services, LLC (subject to ERISA but otherwise unregulated)
- AmericanTCS Technology, LLC
- Mid Atlantic FinSource / FinSource Limited (Bangladesh), an unregulated, offshore processing operation
Location: Hybrid to the Company’s office in Lexington, KY or Cordova, TN
Leadership Responsibilities:
- Oversee MATC and ATC Compliance Officers
- Oversee ATC directed trust services
- Oversee ATC collective investment trust (“CIT”) reporting and CIT investment-only processing
- Serve as an escalation resource for ATCS Trust and Compliance team members, other departments and affiliates
- Act as primary point of contact with Tennessee Department of Financial Institutions
Duties/Responsibilities – Perform and/or Manage:
- Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program, including, but not limited to, FinCEN regulations and reporting requirements, e.g., Customer Identification Program (CIP) and Due Diligence, 314(a) monitoring and reporting, SAR filings, AML training, AML testing, etc.
- Office of Foreign Assets Control (OFAC) compliance
- Gramm-Leach-Bliley Act (GLBA) – Financial Privacy Rule, Safeguards Rule, and Pretexting Protection Rule
- Trust regulatory examinations
- Maintain staff knowledge of DOL/ERISA, IRS, and SEC requirements applicable to ATCS services and products, e.g., retirement plans, individual retirement plans (IRAs), personal trusts, estates, etc. Provide regulatory requirements consulting to ATCS Operations and Product Management groups as requested
- Maintain expert collective investment trust knowledge base and consult with Operations and Investment Management groups as requested
- Investment-only CIT program – maintain documents, disclosures, and plan level records; perform investor qualification and CIP procedures for plan investors
- Prepare and file Forms 5500 DFE for all proprietary CITs
- Ensure regulatory filings are handled as required
- Collaborate with affiliate entities and other departments (Internal Audit, Operations etc.) to resolve issues, including consulting with the corporate attorney(s) as needed to resolve difficult legal compliance issues
- Provide reports on a regular basis, and as directed or requested, to keep the trust companies’ boards of directors, and executive management informed of the operation and progress of compliance efforts
- Serve on committees, as requested, that support regulatory compliance and fiduciary responsibilities
Education and Experience:
- Bachelor’s degree required. Law degree is beneficial, but not required
- 15+ years of retirement services industry experience, with at least 5 years in a trust compliance leadership role
- Compliance leadership skills
- Thorough knowledge and experience pertaining to trusts, BSA/AML, GLBA, and ERISA
- Knowledge and experience with collective investment trusts enhances qualifications
- Ability to interpret relevant regulations and address impact to the organization
- Experience in managing regulatory examinations
- Ability to serve multiple, affiliated entities and operate in a high-growth, acquisition-oriented strategy organization
- Ability to operate in a technology-enabled office environment, i.e., industry relevant software applications, computer skills, word processing. Limited use of paper documents and files.