Ryan Del Giudice
About Ryan Del Giudice
Ryan Del Giudice is Vice President and Chief Compliance Officer (CCO) of MidCap Financial Investment Corporation (MFIC). He joined Apollo in 2022 and was appointed MFIC’s CCO effective March 16, 2023; the 2024–2025 proxies list his age as 34 and detail a compliance-focused career across Apollo’s registered funds complex . He holds a BS in Business Administration and Finance from St. Joseph’s University . MFIC discloses that executive officers, including the CCO, do not receive direct compensation from the Company; compensation for the CCO is set by the Administrator, subject to Company reimbursement of an allocable portion and Board approval (including a majority of Independent Directors) per Rule 38a‑1 under the 1940 Act . As of each proxy record date in 2023, 2024, and 2025, the Company reports that its Directors and Executive Officers as a group owned less than 1% of shares, with no shares shown for Del Giudice individually .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Griffin Capital interval fund platform and RIA subsidiaries | Chief Compliance Officer and SVP of Operations | 2017–2022 | Led compliance and operations for interval fund platform; built governance for registered products . |
| Cipperman Compliance Services (acquired by Foreside) | Vice President; CCO and/or consultant to funds/BDCs/alt managers | Pre‑2017 (years not specified) | Provided outsourced CCO services and compliance consulting across registered investment companies and BDCs . |
External Roles
| Entity | Role | Years |
|---|---|---|
| Apollo Diversified Real Estate Fund | Chief Compliance Officer | 2022–present . |
| Apollo Diversified Credit Fund | Chief Compliance Officer | 2022–present . |
| Apollo Debt Solutions BDC | Chief Compliance Officer | 2022–present . |
| MidCap Financial Investment Corporation | Chief Compliance Officer | 2022–present; appointed 3/16/2023 . |
| Apollo S3 Private Markets Fund | Chief Compliance Officer | 2023/2024–present (disclosed in 2024–2025 proxies) . |
| Middle/MidCap Apollo Institutional Private Lending | Chief Compliance Officer | 2024–present . |
| Apollo Senior Floating Rate Fund Inc. | Chief Compliance Officer | 2022–2024 . |
| Apollo Tactical Income Fund, Inc. | Chief Compliance Officer | 2022–2024 . |
| Apollo Origination II (Levered) Capital Trust | Chief Compliance Officer | 2025–present . |
| Apollo Origination II (UL) Capital Trust | Chief Compliance Officer | 2025–present . |
Fixed Compensation
- MFIC discloses that none of its executive officers receive direct compensation from the Company .
- Compensation for the Chief Compliance Officer is set by the Administrator, subject to reimbursement by the Company of the allocable portion for services rendered; the Board (including a majority of Independent Directors) approves CCO compensation in accordance with Rule 38a‑1 under the 1940 Act .
- The proxy compensation table for executive officers shows “None” across categories for 2022 (nine‑month stub) and 2023, reinforcing no direct Company-paid salary/bonus/equity to MFIC executives .
Performance Compensation
- MFIC’s proxies do not disclose Company‑granted equity (RSUs/PSUs/options), performance metrics, targets, or vesting schedules for executive officers; MFIC indicates executive compensation is not paid directly by the Company and, for the CCO, is governed via the Administrator with Board oversight (Rule 38a‑1) .
- No MFIC‑level incentive plan details (metric, weighting, target, payout, vesting) are provided for Del Giudice in the Company’s filings; therefore, no pay‑for‑performance linkage is disclosed at the MFIC entity level .
Equity Ownership & Alignment
| Year | Shares Beneficially Owned | % of Shares Outstanding | Notes |
|---|---|---|---|
| 2023 | – | * (group <1%) | Executive officer table lists “Ryan Del Giudice –”; no individual holdings disclosed . |
| 2024 | – | * (group <1%) | Executive officer table lists “Ryan Del Giudice –”; no individual holdings disclosed . |
| 2025 | – | * (group <1%; 93,303,622 shares outstanding) | Executive officer table lists “Ryan Del Giudice –”; shares outstanding disclosed for percent context . |
- Pledging/hedging: MFIC’s Code of Ethics and insider trading policies apply to officers and employees; no pledging by Del Giudice is disclosed .
- Ownership guidelines: Not disclosed for executive officers in MFIC proxies .
Employment Terms
| Item | Disclosure |
|---|---|
| Appointment date | Board appointed Del Giudice as MFIC’s Chief Compliance Officer effective March 16, 2023 . |
| Role scope | CCO responsibilities span MFIC and multiple Apollo registered products/funds as disclosed in 2024–2025 proxies . |
| Compensation governance | CCO compensation set by Administrator; Company reimburses allocable portion; Board (majority independent) approves per Rule 38a‑1 under the 1940 Act . |
| Code of Ethics/Conduct | MFIC has a Rule 17j‑1 Code of Ethics and a Code of Conduct covering executive officers; accessible via Company website and filed with 10‑K . |
| Proxy authority | Named as a proxy (with Kristin Hester) for the 2025 Annual Meeting proxy card . |
| Attorney‑in‑fact authority | Named as an attorney-in-fact for SEC filings in a 2025 Power of Attorney exhibit . |
| Severance / change-of-control | Not disclosed for Del Giudice in MFIC filings . |
| Non‑compete / non‑solicit | Not disclosed in MFIC filings . |
Investment Implications
- Compensation alignment: MFIC pays no direct executive compensation; CCO pay is set externally by the Administrator and approved by the Board, limiting traditional MFIC pay‑for‑performance levers and reducing equity‑based dilution risk. For investors, this structure shifts evaluation toward governance efficacy and Administrator alignment rather than Company incentive plan design .
- Insider selling pressure: With no reported share ownership for Del Giudice across multiple proxy record dates, near‑term selling pressure from his personal holdings appears negligible; monitoring future Forms 3/4/5 remains prudent .
- Retention/transition risk: As a cross‑complex CCO covering many Apollo vehicles, retention dynamics likely relate to Administrator‑level compensation and career trajectory; MFIC Board oversight of CCO pay under Rule 38a‑1 provides an additional governance check, though severance/CIC protections are not disclosed at the MFIC level .
- Governance and compliance signal: Expanded attorney‑in‑fact/proxy authorities and broad fund coverage indicate trust in Del Giudice’s compliance leadership; continued adherence to MFIC’s Code of Ethics and timely Section 16 compliance (no delinquencies noted for Del Giudice) support governance quality .
Monitoring priorities: future proxies for any introduction of MFIC‑level executive equity awards or ownership guidelines; any change in reported beneficial ownership; and any 8‑K Item 5.02 disclosures that might add detail on employment terms and compensatory arrangements.