Tito Pombra, President and Founder
Tito Pombra is the Founder and President of Adviser Compliance Consulting Inc. (ACC) a compliance consultation firm which services, registered investment advisers, hedge funds, private funds, investment companies, financial professionals, global managers and CPOs. Over the years, Mr. Pombra has garnered extensive experience in the global asset management industry, which includes twenty-three years in the investment Company/investment adviser and international compliance areas. His practice is focused on the areas of regulatory exams, acting as outsource CCO, annual reviews, mock SEC exams, creating a strong culture of compliance, policies and procedures development, advertising and marketing reviews, NFA/CFTC compliance and mentoring and training compliance professionals.
Before founding ACC, Mr. Pombra was President of Core Compliance and Legal Services, where he led the compliance consulting practice to identify and execute new business strategies that resulted in significant new client’s acquisition and growth. In addition, he provided proactive compliance advice to clients on Investment Adviser (Rule 206(4)-7), Investment Company (Rule 38a-1) and Private Fund Compliance Programs. Established policies and procedures, completed annual reviews, mock SEC exams, risk assessments and compliance training for variety of investment advisers.
From 2005 thru 2018, Mr. Pombra was Chief Compliance Officer of Matthews International Capital Management, LLC (“Matthews Asia”) and Matthews International Funds (d/b/a Matthews Asia Funds). As CCO for Matthews Asia and Matthews Funds, he was responsible for creating and managing the compliance and anti-money laundering programs of the Investment Company, Investment Adviser and offshore funds, and assisted with the compliance programs of Matthews Global Investors, Hong Kong and UK, registered broker dealers. In addition, he oversaw the Matthews Asia Funds service provider’s compliance program under Rule 38a-1. During his tenure, Mr. Pombra was also the AML Officer for the Matthews Asia Funds and MLRO for the Matthews Asia Funds (Luxembourg).
Mr. Pombra also held various senior compliance and accounting positions at Franklin Templeton Investments and Dreyfus Funds. He graduated from Queens College, NY (1987) with bachelor’s in accounting and economics.
Over the past 23 years, Mr. Pombra has established an influence in the industry as a thought leader on best compliance practices. He is Co-Chair of the San Francisco Bay Area CCO Committee and a former member of the Board of Directors of the National Society of Compliance Professionals (NSCP) and the Investment Company Institute’s (ICI) CCO committee.
In 2008, Mr. Pombra was named as a Top 20 Rising Star for “Who’s Who” in Upcoming Compliance Professionals by Compliance Reporter magazine. He frequently speaks at industry conferences such as NSCP, Investment Company Institute, Investment Adviser Association, IA Watch, Private Equity Institute, and many others on a wide variety of compliance related subjects.
B.A., Accounting and Economics, Queens College, NY
Co-Chair of the San Francisco Bay Area CCO Committee
Former Board of Director, National Society of Compliance Professionals (NSCP) and current member of NSCP
Former member, Investment Company Institute’s (ICI) CCO Committee
Former CCO of large investment adviser and mutual fund
Julie Walsh, Senior Compliance Consultant
- Investment Adviser (Rule 206(4)-7), Investment Company (Rule 38a1), and Private Fund Compliance Programs
- NFA Member Programs for CPOs and CTAs, including registration, development of Written Supervisory Procedures, Mock NFA Audits, Ongoing Compliance Maintenance Programs
- Outsourced NFA Specialist encompassing all facets of CPO and CTA compliance, including Compliance Training (including mandatory NFA Ethics Training), NFA Audit Preparedness, NFA and CFTC filing requirements, Self-Examination Questionnaires, Vendor Due Diligence, and NFA Audit assistance
- Investment Company Act of 1940, as amended – all requirements
- Outsource Fund Chief Compliance Officer Services (including open-end investment companies, closed-end investment companies, and interval funds composed of private equity investments)
- Outsource Adviser Chief Compliance Officer Services
- Outsource Anti-Money Laundering Compliance Officer services
- Anti-Money Laundering Programs for U.S registered Investment Companies, Private Funds and International Funds
- Policies and Procedures, Annual Reviews, Mock SEC Examinations, Risk Assessments and Compliance Training
- Implementation of Compliance Technology
- Vendor Due Diligence Programs – conducted on behalf of Advisers, Funds, and other entities
Julie Walsh is a Senior Consultant with Adviser Compliance Consulting (ACC) a compliance consultation firm which services registered investment advisers, registered investment companies, hedge funds, private funds, NFA/CFTC clients registered as Commodity Pool Operators and Commodity Trading Advisors, financial professionals and global managers. Over the years, Ms. Walsh has gained extensive experience in the global asset management industry, which includes over twenty-five years in the Investment Company/Investment Adviser and NFA/CFTC compliance areas. Ms. Walsh’s uniquely broad experience benefits our clients as
she aims to develop programs with efficiency and does so in a cost-effective manner. For example, she often conducts gap analyses at the outset of relationships with our new clients with a view toward capitalizing on their existing regulatory/compliance programs, as relevant, to leverage in all possible instances existing programs and infrastructure. She engages these efforts in a crossdisciplinary manner — across various regulatory regimes when relevant. She is
aware that our clients’ core competence is investment management and works to judiciously administer programs that, while robust and comprehensive, do not take away from our client’s endeavors to serve their clients by virtue of maintaining focus. Her approach often results in a reduction of time required of in-house personnel as she capitalizes on existing infrastructure and program elements. She
works to deploy multi-disciplinary programs with efficiency and in a manner most useful to unique nature of each individual client.
Ms. Walsh specializes in investment company and investment adviser regulatory compliance programs as well as programs for Commodity Pool Operators and Commodity Trading Advisors. Her consultation practice is focused on the areas of regulatory exams, annual reviews, Mock SEC exams, creating a strong culture of compliance, policies and procedures development, advertising and marketing reviews, and mentoring and training compliance professionals.
Prior to her work with ACC, Ms. Walsh served as the Managing Director of at her most recent employer – for over 9 years. During that tenure, Ms. Walsh was designated as the outsourced Fund CCO for four distinct investment company operations, including a closed-end private equity interval fund, and served as outsourced AMLCO for two open-end investment companies. In carrying out her Fund Officer delegations, Ms. Walsh reported directly to each Fund’s Board of Directors. Also during this time period, Ms. Walsh founded the firm’s NFA/CFTC compliance program consultation offerings and led efforts to train and supervise internal resources in this area, and to Core Compliance’s clients she brings decades of experience in providing comprehensive, tailored compliance services to CPOs and CTAs.
Earlier in her career, Ms. Walsh spent 15 years at a Boston-based institutional asset management firm where she served as Global Adviser CCO, headed the compliance team, and oversaw dozens of open-end investment companies, several hedge funds and private funds, and several hundred separately managed dedicated and asset allocation accounts in the institutional space, with assets under management totaling greater than $150 billion.
Ms. Walsh has also presented on many issues within the industry pertaining to investment adviser, investment company and commodity pool/commodity trading advisers.
M.Ed., Secondary Education
Boston College, Chestnut Hill, MA
PROFESSIONAL AFFILIATIONS & CERTIFICATIONS
Member of NEBDIAA
Member of SIFMA
Member of ACAMS