Matthew Sutula
About Matthew Sutula
Matthew Sutula (born 1985) serves as Chief Compliance Officer of ALPS Advisors, Inc. and has been the Chief Compliance Officer of Liberty All-Star Growth Fund, Inc. (ASG) since 2019, with prior roles as Compliance Manager and Senior Compliance Analyst at AAI and Compliance Analyst at ALPS; before ALPS, he spent seven years at Morningstar supporting registered investment company databases . He also holds CCO roles across affiliated funds and trusts, reflecting a cross-fund compliance leadership mandate rather than portfolio or operating P&L responsibility . ASG filings do not disclose individual TSR or financial performance metrics tied to his compensation; fund documents state officers receive no compensation from the Fund (compensation is paid by AAI or affiliates) .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| ALPS Advisors, Inc. (AAI) | Chief Compliance Officer | Since 2016 | Firm-wide compliance leadership for AAI, overseeing registered investment company compliance |
| ALPS Advisors, Inc. | Compliance Manager; Senior Compliance Analyst | Prior to 2016 | Built/comanaged compliance programs prior to CCO appointment |
| ALPS Fund Services, Inc. | Compliance Analyst | Prior to 2016 | Supported fund services and compliance operations |
| Morningstar, Inc. | Analyst roles | Seven years (pre-ALPS) | Supported registered investment company databases—data accuracy and coverage |
External Roles
| Organization | Role | Status/Years | Notes |
|---|---|---|---|
| ALPS ETF Trust | Chief Compliance Officer | Current (as disclosed) | Parallel CCO remit across ETF complex |
| Principal Real Estate Income Fund | Chief Compliance Officer | Current (as disclosed) | Closed-end fund compliance oversight |
| ALPS Variable Investment Trust | Chief Compliance Officer | Current (as disclosed) | Insurance-linked variable product trust compliance |
| Liberty All-Star Equity Fund | Interim Chief Compliance Officer | As of Q4 2019 | Interim CCO designation in offering document |
Fixed Compensation
| Component | From ASG Fund | Notes |
|---|---|---|
| Base salary | $0 | “All officers of the Fund, including the Fund’s Chief Compliance Officer, are employees of AAI or its affiliates, and receive no compensation from the Fund.” |
| Target bonus % | $0 | Fund does not pay officer bonuses; compensation at AAI not disclosed in ASG filings |
| Actual bonus paid | $0 | No fund-paid bonuses disclosed |
| Perquisites | $0 from Fund | No fund-paid perquisites disclosed for officers |
ASG proxies state officers are elected annually and serve at the pleasure of the Board, with no fund-level officer compensation tables; their pay resides at AAI and is not disclosed in ASG’s proxy .
Performance Compensation
| Incentive Type | Metric | Weighting | Target | Actual | Payout | Vesting |
|---|---|---|---|---|---|---|
| Fund-paid annual incentive | N/A | N/A | N/A | N/A | $0 | N/A (no fund awards) |
| Fund-paid equity (RSUs/PSUs/options) | N/A | N/A | N/A | N/A | $0 | N/A (no fund awards) |
ASG filings do not disclose AAI-level performance plan details or metrics applicable to Sutula; no fund-level performance awards are provided to officers .
Equity Ownership & Alignment
| Date | Filing/Form | Non-Derivative Shares | Derivative Securities | Ownership Form | Notes |
|---|---|---|---|---|---|
| 2019-09-10 (event 2019-09-03) | SEC Form 3 | 0 | None reported | N/A | “No securities are beneficially owned.” Filed as Interim CCO |
No subsequent insider transactions were retrieved in our ASG document search; current beneficial ownership is not disclosed in ASG proxies. Officers receive no fund-paid equity awards .
Employment Terms
| Term | Details |
|---|---|
| Appointment and tenure | Officers are elected annually by the Board; hold office until a successor is elected and qualified, or removal/resignation/death; serve at the pleasure of the Board . |
| Role scope | CCO role spans ASG and affiliated trusts/funds under ALPS/AAI umbrella . |
| Compensation source | Officers are employees of AAI/affiliates and receive no compensation from the ASG Fund . |
Severance, change-of-control, clawbacks, non-compete/solicit, and consulting arrangements for Sutula are not disclosed in ASG proxy materials; officers are not directors and are outside ASG’s director compensation framework .
Investment Implications
- Pay-for-performance and selling pressure: With $0 fund-level compensation and no fund equity awards, ASG does not create direct stock-based incentives or vesting-related selling pressure for the CCO; initial Form 3 reported no beneficial ownership, indicating limited alignment via ASG shares and minimal insider-trading signaling from compensation mechanics .
- Retention risk: Cross-assignment as CCO across multiple ALPS/AAI complexes suggests institutional reliance and continuity; officers serve at the pleasure of the Board, but annual re-election and multi-fund roles typically stabilize retention in fund complexes .
- Governance and control: The CCO’s remit is compliance oversight, not capital allocation; thus, execution risk for ASG’s investment performance is not driven by Sutula’s incentives. Investors should evaluate manager/sub-advisor contracts and portfolio policies for performance drivers, as officer incentives are structurally decoupled from ASG returns .
- Red flags: No pledging/hedging or tax gross-ups are disclosed for fund officers; absence of fund-level equity awards and compensation tables reduces typical executive misalignment risks but also limits transparency into AAI-level incentives .
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