Gerald Cummins
About Gerald Cummins
Gerald Cummins (age 70) is Chief Compliance Officer (CCO) of Oxford Lane Capital Corp. (OXLC) under a services agreement with ACA Group, LLC; he has served in this role since June 2015. He is a Director of ACA Group and concurrently serves as CCO across several Oxford-affiliated entities; he holds a B.A. in Mathematics from Fordham University. OXLC’s executive officers do not receive direct compensation from OXLC, and the company did not grant stock options in FY2025—meaning his compensation is not tied to TSR, revenue, EBITDA, or similar performance metrics at the fund level .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| ACA Group, LLC | Director | Since Jun 2014 | Leads compliance services; serves as CCO for multiple investment entities |
| Barclays Capital Inc. | Consultant | 2012–2013 | Compliance projects in pricing/valuation, policy and procedures |
| BroadArch Capital | COO & CCO | 2010–2011 | Built compliance function at investment adviser |
| New Castle Funds (predecessor to BroadArch) | CFO & CCO | 2009–2011 | Oversaw finance and compliance at long-short equity manager |
| Bear Stearns Asset Management (BSAM) | Managing Director; senior compliance/controllers/operations risk positions | 25 years | Long-tenured leader in compliance and operational risk |
External Roles
| Organization | Role | Years | Notes |
|---|---|---|---|
| Oxford Lane Management | Chief Compliance Officer | Current | OXLC’s adviser affiliate |
| Oxford Square Capital Corp. | Chief Compliance Officer | Current | Public BDC affiliate |
| Oxford Square Management | Chief Compliance Officer | Current | Adviser to affiliate |
| Oxford Gate Management | Chief Compliance Officer | Since 2018 | Adviser to Oxford Gate Funds/Broadened remit |
| Oxford Park Income Fund, Inc. | Chief Compliance Officer | Since 2023 | Non-traded registered closed-end fund |
| Oxford Park Management | Chief Compliance Officer | Since 2023 | Adviser to Oxford Park Income Fund |
| Oxford Funds | Chief Compliance Officer | Current | Administrator to OXLC and affiliates |
Fixed Compensation
OXLC does not pay executive officers directly; CCO services are provided via ACA Group and expensed by OXLC.
| Component | FY 2024 | FY 2025 |
|---|---|---|
| Fees paid to ACA Group for CCO services | $120,000 | $120,000 |
- OXLC accrued administrative compensation reimbursements (CFO/Controller/support) to Oxford Funds of $1,058,000 (FY 2024) and $1,327,567 (FY 2025), illustrating broader executive support cost structure; Cummins’ CCO fees are separate via ACA Group .
Performance Compensation
| Metric | Weighting | Target | Actual | Payout | Vesting |
|---|---|---|---|---|---|
| None—executive officers do not receive direct compensation from OXLC; no stock option grants in FY2025 | — | — | — | — | — |
- OXLC did not grant stock options, SARs or similar instruments in FY2025 .
Equity Ownership & Alignment
| Holder | Common Shares Beneficially Owned | % of Class | Preferred Shares Beneficially Owned | % of Class |
|---|---|---|---|---|
| Gerald Cummins (FY 2024) | — (none reported) | — | — | — |
| Gerald Cummins (FY 2025) | — (none reported) | — | — | — |
- No pledging, hedging, ownership guidelines, or compliance status are disclosed for Cummins in OXLC’s proxy materials .
- Board risk oversight includes regular independent-director executive sessions with the CCO and annual written compliance reports—reinforcing the centrality of the CCO function to governance .
Employment Terms
- Role and Start: Chief Compliance Officer since June 2015, under an agreement between OXLC and ACA Group; Cummins is a Director of ACA Group .
- Compensation Mechanism: Fees paid to ACA Group for CCO services—$120,000 in FY2024 and $120,000 in FY2025 .
- Contract Structure: Services provided via ACA Group consulting agreement; severance, change-of-control, non-compete, non-solicit, and clawback terms for Cummins are not disclosed in OXLC filings .
- Governance Interface: CCO provides annual written compliance reports to the Board and meets separately with independent directors at least quarterly .
Investment Implications
- Alignment: Lack of direct equity ownership and pay-for-performance linkage (no direct OXLC compensation, no options) reduces traditional alignment and diminishes insider-driven trading signals; CCO fee arrangement via ACA Group is stable and not performance-conditioned .
- Retention Risk: The role is outsourced through ACA Group; retention risk is more about maintaining the ACA Group relationship than individual equity incentive retention, which appears limited given no direct OXLC comp or ownership .
- Governance/Risk Oversight: The CCO’s structured engagement with the Board and independent directors suggests robust compliance oversight, which is positive for risk management in a highly regulated closed-end fund environment .
- Red Flags: No evidence of pledging, option repricing, tax gross-ups, or related-party conflicts tied specifically to Cummins; his multi-entity CCO responsibilities across Oxford affiliates represent potential time-allocation complexity but are mitigated by formal allocation and oversight policies .