Eric Pinero
About Eric Pinero
Eric A. Pinero, age 49, is Chief Legal Officer of CĪON Investment Corporation, serving since November 2021. He has been Senior Director and Counsel of CION Investment Group and affiliates since July 2013, advising on legal, compliance, and regulatory matters across corporate and securities law for CION and sponsored products. He holds a B.S. in Political Science and History from Roger Williams University and a J.D. from Brooklyn Law School . CION’s proxy does not disclose officer-specific TSR, revenue, or EBITDA performance metrics tied to Mr. Pinero; executive officers do not receive direct compensation from the Company and are compensated at the external adviser, CION Investment Management (CIM) .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| CĪON Investment Corporation | Chief Legal Officer | 2021–present | Leads legal, compliance, and regulatory matters for the Company . |
| CION Investment Group (and affiliates) | Senior Director and Counsel | 2013–present | Advises on corporate/securities law compliance for CIG’s sponsored alternative products, including CION . |
| Several regional law firms | Attorney (issuers/underwriters) | pre-2013 | Represented issuers and underwriters on securities law compliance, public/private offerings, M&A, and corporate transactions . |
External Roles
| Organization | Role | Years | Notes |
|---|---|---|---|
| None disclosed | — | — | No public directorships held by officer during past 5 years . |
Fixed Compensation
| Component | Disclosure | Notes |
|---|---|---|
| Base Salary | Not disclosed | CION executive officers do not receive direct compensation from the Company; compensation is paid by CIM under advisory/administration arrangements . |
| Target Bonus % | Not disclosed | Not paid directly by CION; no officer-level bonus disclosure in proxy . |
| Actual Bonus Paid | Not disclosed | Not paid directly by CION; no officer-level bonus disclosure in proxy . |
| Cash Retainers (Directors) | Not applicable to officer | Directors, not officers, receive cash (no stock/options) in 2024 . |
Performance Compensation
| Incentive Type | Metric | Weighting | Target | Actual | Payout | Vesting | Notes |
|---|---|---|---|---|---|---|---|
| Company equity awards (RSUs/PSUs) | — | — | — | — | — | — | Not disclosed; Company did not award directors stock/options in 2024; executive officers are not compensated directly by CION . |
| Options | — | — | — | — | — | — | Not disclosed; no option grants reported to directors in 2024; officer pay occurs at CIM . |
Equity Ownership & Alignment
| Item | Amount/Policy | Notes |
|---|---|---|
| Beneficial ownership (shares) | 9,499.36 | Includes 2,209.36 shares via DRIP . |
| Shares outstanding (record date) | 52,591,682 | As of May 30, 2025 . |
| Ownership as % of shares outstanding | ~0.018% | Calculated from 9,499.36 / 52,591,682; table classifies as <1% . |
| Vested vs unvested shares | Not disclosed | No vesting schedules disclosed for officers in proxy . |
| Options (exercisable/unexercisable) | Not disclosed | No option positions disclosed for officers . |
| Pledged shares | Not disclosed | No pledging policy disclosure; proxy includes hedging restrictions (pre-approval required) . |
| Hedging/monetization policy | Prior approval required | Hedging or monetization transactions require CCO approval . |
| Insider trading policy | Adopted | Statement of policy on insider trading filed with 10-K; Section 16 filings reported timely based on public info . |
| Stock ownership guidelines | Not disclosed | No officer ownership guideline disclosure in proxy . |
Employment Terms
| Term | Detail | Notes |
|---|---|---|
| Employment start date at CION | November 2021 | Chief Legal Officer . |
| Years in current role | Since 2021 | Tenure indicated; proxy does not compute years . |
| Contract term/expiration | Not disclosed | Officers are employed by CIM; no individual CION officer contracts disclosed . |
| Severance/change-of-control | Not disclosed | No officer-level severance or CoC terms disclosed; advisory agreements indemnify CIM and affiliates under specified conditions . |
| Non-compete/non-solicit | Not disclosed | No officer-level restrictive covenants disclosed in proxy . |
| Garden leave/post-termination consulting | Not disclosed | No disclosure . |
Compensation Committee Analysis
- Committee composition: Independent directors Breakstone, Finlay, Schwartz, Hedin, Choi, Estrada; no chairperson .
- Scope: Determines or recommends compensation of co-CEOs and other executive officers; however, CION executive officers do not receive direct compensation from the Company .
- 2024 activity: The compensation committee did not hold formal meetings in 2024 .
- Director pay: Independent directors received cash retainers/meeting fees; no stock/options awarded for 2024 .
Related Party and Adviser Economics (Context)
- CIM earned base management fees of ~$27 million and incentive fees of ~$20 million for FY 2024; CION reimbursed ~$5 million for administrative services .
- Messrs. Gatto and Reisner (co-CEOs) indirectly own interests in CIM via CION Investment Group and are “interested persons” under the 1940 Act .
Investment Implications
- Alignment: Mr. Pinero’s direct equity stake in CION is small (~0.018% of shares outstanding), and executive officers are compensated at CIM, not by CION; thus, observable pay-for-performance alignment at the Company level is limited from public disclosures .
- Selling pressure and pledging: The proxy prohibits hedging/monetization absent CCO approval, reducing near-term hedging-related selling risks; no pledging policy or pledged shares are disclosed for Mr. Pinero, leaving collateralization risks unassessed .
- Retention risk: Tenure at CIG since 2013 and role continuity since 2021 suggest institutional knowledge and stability; absence of severance/CoC disclosures for officers means retention economics are opaque to public shareholders .
- Trading signals: Section 16 compliance was timely based on public information, and no insider-trading policy exceptions are noted; lack of disclosed equity incentives or vesting schedules reduces event-driven signals tied to officer compensation .