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Latam Chaperone

Bank of America

Bank of America

São Paulo, SP, Brazil
Posted on Tuesday, April 11, 2023

Job Description:

In April 2003, the SEC, the New York State Attorney General and other securities regulators announced a global settlement with 10 investment banks relating to enforcement actions brought against the investment banks for certain Investment Banking and Equity Research practices (the “Global Settlement”). Pursuant to the Global Settlement, all pre-approved communications between Investment Banking and Equity Research must occur in the presence of, and be monitored by, a Chaperone or another designated Legal or Compliance representative.


The Brazil Chaperone will play a critical role in helping confirm compliance by BofA with the Global Settlement by approving, facilitating, monitoring and recording all permissible communications. The role of the Chaperone Team as outlined below includes the following:

  • Engage with other Compliance and Operational Risk officers, Enterprise Areas of Coverage roles, and horizontal function roles to provide oversight of Brazil Investment Banking and Research activities
  • Chaperone communications between Equity Research and Banking personnel to ensure independence and integrity of the research function, proper business practices are followed, compliance with policies and information barriers are functioning
  • Provide guidance on research matters to Research and Investment Banking Management/teams (including GCIB, GCM, GCB), Business Controls, other GBAM LOB Compliance teams, Enterprise Areas of Coverage (AIM, Control Room, GFCC) and Legal (Research and Capital Markets)
  • Coordinate Research wall crossings. This involves liaising with Research Management, Research Analysts Capital Markets and Control Room.
  • Provide guidance to Research Management and analysts during the vetting process for capital markets transactions (i.e. IPO’s and other capital raising transactions)
  • Provide feedback on proposed transaction guidelines/timelines. Provide guidance on vetting procedures and review pre-deal research. This involves liaising with Research Management, the vetting Research Analyst, Research Editors & Supervisory Analyst and internal & external legal counsels.
  • Chaperone calls and presentations between GCIB and fundamental Equity Research analysts related to vettings, industry discussions, and sales force presentations. Step in to coach participants on applicable laws, rules, and regulations or stop conversation as needed if the potential violative conversation is severe.
  • Set up calls between Banking and Research for vettings and industry discussions.
  • Review communications between Investment Banking and fundamental Equity Research related to vettings to ensure that the information is appropriate for research.
  • Conduct compliance and operational risk assessments of Brazil Research
  • Contribute to monitoring and testing coverage plans and related metrics for Brazil Research
  • Identify compliance and operational risk training needs, provide subject matter expertise to support development of training curriculum and monitor Brazil Research participation
  • Preparing and delivering in-person Research Compliance and Operational Risk training: new hire, annual, ad hoc, remedial etc.
  • Assist business leaders in preparations for regulatory exams and audits for Brazil Research and related Enterprise Areas of Coverage.

Core Skills and requirements:

  • Minimum of 5-10 years of prior experience within Compliance & Operational Risk of Financial Institutions
  • Relevant experience working in Compliance Control Room or Business Control related functions
  • Bachelor degree in Law, Business or Economics
  • Ability to make decisions when required and to escalate when necessary
  • A flexible and solution driven perspective, able to solve problems and a determination to seek answers to complex issues.
  • Strong written and verbal communication skills
  • Proficient in MS Office Suite applications
  • Team player, willing to collaborate with the team on initiatives, projects and issues
  • Fluency in Portuguese and English required. Fluency in Spanish will be a plus.

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