Erik Barrios

About Erik Barrios

Erik G. Barrios (born 1978) is Chief Compliance Officer (CCO) of Crescent Capital BDC, Inc. (CCAP) since 2022; he is also CCO of Crescent Private Credit Income Corp. (CPCI) and CCS IX BDC, and serves as Senior Vice President, Legal Counsel and Deputy Compliance Officer at Crescent (the external adviser to CCAP) . He holds a J.D. from Boston College Law School and a B.S. from Georgetown University . As of the 2025 proxy record date, he beneficially owned 2,068 CCAP shares (<0.1%); company policy prohibits pledging, hedging or shorting CCAP stock by officers, which reduces misalignment risk from leverage or hedging . CCAP’s executives receive no direct compensation from the BDC; instead, CCAP reimburses the Administrator for an allocable portion of compensation for the CFO, CCO and other officers—indicating limited direct pay-for-performance linkage at the CCAP entity level .

Past Roles

External Roles

Fixed Compensation

• Structure: CCAP’s executive officers (including the CCO) receive no direct compensation from CCAP; CCAP reimburses the Administrator for its allocable portion of compensation paid to the CFO, CCO and other officers/staff who provide services to CCAP .
• Implication: Because compensation is paid by affiliates and reimbursed, disclosure of base salary, target bonus and individual equity awards for the CCO is not provided at CCAP, limiting transparency into pay-for-performance at the individual level .

Performance Compensation

• CCAP discloses no individual performance incentive plan (metrics/weightings) for the CCO; executives are not directly compensated by CCAP, and there are no CCAP stock option/RSU/PSU grants disclosed for the CCO .
• Context: At the entity level, CCAP’s Advisor is compensated via a 1.25% base management fee on gross assets (ex-cash) and a two-part incentive fee (income fee with 7% annualized hurdle and 17.5% split; and a 17.5% capital gains incentive fee on cumulative realized gains), with certain voluntary waivers—these are Advisor-level economics, not individual executive awards .

Equity Ownership & Alignment

• Hedging/pledging: CCAP’s Insider Trading Policy and Rule 17j-1 Code of Ethics prohibit hedging, short sales, margin accounts, and pledging of CCAP securities by directors and officers—strong alignment and low pledging risk .
• Ownership guidelines: No officer stock ownership guideline or status was disclosed for executive officers; director dollar ranges are disclosed separately .

Insider Transactions (CCAP common)

Employment Terms

• Appointment and tenure: CCO since 2022; the Board meets with the CCO periodically and at least annually to review the CCO’s annual report and risk-based analysis, indicating formalized oversight and reporting cadence .
• Removal: The CCO “may only be removed from his office in accordance with Rule 38a-1 under the 1940 Act,” signaling regulatory protections around the compliance function .
• Severance/change-of-control: No individual employment agreement, severance formulas, change-of-control triggers, accelerated vesting, or clawback provisions were disclosed for the CCO in CCAP’s proxy .
• Policies: Insider Trading and Code of Ethics restrict hedging, shorting, margin and pledging of CCAP stock by officers; helps mitigate misalignment and inappropriate risk-taking signals .

Risk Indicators and Governance Notes

• Section 16 compliance: CCAP reported that directors and executive officers complied with Section 16(a) filing requirements for FY2023 (indicates procedural discipline) .
• Legal proceedings: The company disclosed routine legal matters in normal course; no material impact expected; no individual proceedings involving the CCO were disclosed .
• Compensation Committee: Independent directors oversee executive compensation matters paid directly by CCAP (if any) and have authority to retain advisors; however, executives receive no direct comp from CCAP, limiting committee leverage over individual executive pay alignment .

Investment Implications

• Alignment and selling pressure: Barrios has accumulated CCAP shares since joining (open-market buys in 2022; higher reported ownership into 2025), with no disclosed sales—benign to supportive for insider-sentiment screens; pledging/hedging is prohibited, lowering overhang risk .
• Pay-for-performance linkage: Because executive compensation is paid by Crescent affiliates and reimbursed, individual incentive metrics, vesting, or equity grants tied to CCAP performance are not disclosed—limiting direct incentive alignment and reducing visibility for pay analysis; investors should focus on Advisor fee terms and waivers for economic alignment at the entity level .
• Retention risk: Role spans CCAP, CPCI, and CCS IX BDC within Crescent, suggesting organizational embed and multi-entity responsibility; Rule 38a-1 removal protections and Board oversight of the CCO function support continuity, but lack of disclosed severance/CoC terms means retention economics are opaque .
• Execution risk: As CCO, Barrios’ impact centers on regulatory compliance and risk control rather than portfolio returns; Board-CCO engagement and policy restrictions are designed to constrain compliance risk, which is critical for BDC leverage, co-investment, and 1940 Act requirements .