A few final questions to ask when assessing the status of the legal and compliance role.
• Who does the general counsel and/or CCO report to (i.e., who hires/fires and determines annual compensation)? The Founder/PM or some intermediary? If to an intermediary, what is the Founder/PM’s rationale? And If to an intermediary, does the firm claim some sort of “dotted line” reporting?
• How much does the GC and/or CCO get compensated, and how does that compare to peer firms, as well as to other senior personnel within the firm?
• Where does the GC and/or CCO sit, literally? Next to the Founder/PM, down the hall, on another floor, or in another building?
• How often does the Founder/PM meet with the GC and/or CCO, and do they meet one-on-one?
• Does the GC and/or CCO the GC/COO participate on all significant firm committees?
• Does the GC and/or CCO make the decision on hiring outside counsel and/or compliance consultants? Or is that authority retained by someone else?
• In the event of turnover at the GC and/or CCO level, how “promptly” does the firm inform the SEC by amending its Form ADV, and does the firm inform its investors, also promptly?