Matthew Sutula
About Matthew Sutula
Matthew Sutula (born 1985) is the Fund’s Chief Compliance Officer (CCO), serving since December 2019 after an interim CCO assignment from September–December 2019. He joined ALPS in 2012 and progressed through compliance roles (Compliance Analyst, Senior Compliance Analyst, Compliance Manager) before becoming CCO of ALPS Advisors, Inc. (AAI); prior to ALPS he spent seven years at Morningstar, Inc. in analyst roles supporting registered investment company databases . He concurrently serves as CCO for ALPS ETF Trust, ALPS Variable Investment Trust, Liberty All-Star Equity Fund, and Liberty All-Star Growth Fund, Inc.; he previously served as CCO for RiverNorth Opportunities Fund, Inc. from September 2019 to September 2022 . Officers are elected annually and hold office until successors are elected; as an ALPS employee, he is deemed an affiliate under the 1940 Act . Fund performance (NAV total return) during his tenure is summarized below and provides context for governance/compliance-led execution within PGZ’s strategy .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| ALPS Advisors, Inc. (AAI) | Compliance Manager; Senior Compliance Analyst; Compliance Analyst; later CCO of AAI | Joined 2012; served in these roles prior to current CCO role | Built and led compliance oversight for registered investment companies; advanced to CCO responsibility |
| Morningstar, Inc. | Analyst supporting registered investment company databases | Seven years prior to joining ALPS | Data, coverage, and operational support for RIC databases; foundation for fund compliance expertise |
External Roles
| Organization | Role | Years | Notes |
|---|---|---|---|
| ALPS ETF Trust | Chief Compliance Officer | Current | Concurrent CCO role across ALPS-affiliated fund complexes |
| ALPS Variable Investment Trust | Chief Compliance Officer | Current | Concurrent CCO role |
| Liberty All-Star Equity Fund | Chief Compliance Officer | Current | Concurrent CCO role |
| Liberty All-Star Growth Fund, Inc. | Chief Compliance Officer | Current | Concurrent CCO role |
| RiverNorth Opportunities Fund, Inc. | Chief Compliance Officer | Sep 2019–Sep 2022 | Prior concurrent CCO appointment |
Fixed Compensation
Officers of the Fund who are employed by ALPS or ALPS Advisors receive no compensation or expense reimbursement from the Fund or any other fund in the Fund Complex. The proxy does not disclose base salary, bonus targets, or equity compensation at AAI; these are not within PGZ’s filings .
| Item | PGZ Disclosure |
|---|---|
| Compensation paid by PGZ to fund officers (including CCO) | $0 |
| Perquisites and benefits | Not disclosed in PGZ filings |
| Base salary and bonus targets (AAI employment) | Not disclosed in PGZ filings |
Performance Compensation
No performance-based compensation (bonuses, RSUs/PSUs, options) is disclosed at the Fund level for officers employed by AAI. PGZ’s proxy does not provide AAI-specific award structures, performance metrics, or vesting schedules for the CCO role .
Equity Ownership & Alignment
- Officers and Trustees, as a group, owned less than 1% of outstanding shares as of December 31, 2024; the proxy shows named holdings for Trustees and the Fund’s Principal Executive Officer (PEO) and Principal Financial Officer (PFO). Sutula’s individual holdings are not specifically disclosed in the proxy table .
- Section 16(a) compliance: Based on the Fund’s review, all applicable Section 16(a) filing requirements for fiscal year ended October 31, 2024 were complied with .
- Pledging/hedging policy: The proxy does not state an officer hedging or pledging policy; it does require trustee nominees to disclose hedging arrangements in nomination submissions, indicating sensitivity to hedging for governance purposes .
| Holder | Shares | Ownership % |
|---|---|---|
| Officers & Trustees as a Group | 2,000 | <1% |
| Jeremy Held (Trustee) | 2,000 (Beneficial) | <1% |
| Robert McClure (PEO) | None | <1% |
| Erich Rettinger (PFO) | None | <1% |
| Matthew Sutula (CCO) | Not disclosed in proxy table | N/A |
Major shareholders (context for governance pressure):
| Shareholder | Shares | Ownership % |
|---|---|---|
| Saba Capital Management L.P. (and related filers) | 411,915 | 6.15% |
| Phillip Goldstein & Andrew Dakos | 420,848 | 6.29% |
| Bulldog Investors, LLP | 211,845 | 3.31% |
Employment Terms
| Term | Disclosure |
|---|---|
| Start date at PGZ (CCO) | Served since December 2019; interim CCO Sep–Dec 2019 |
| Officer election cadence | Officers elected annually; hold office until successors are elected |
| Employer and affiliate status | Employed by ALPS/AAI; deemed affiliate under 1940 Act |
| Contract term, severance, change-of-control | Not disclosed in PGZ filings |
| Non-compete/non-solicit, garden leave | Not disclosed in PGZ filings |
| Clawback provisions | Not disclosed in PGZ filings |
Fund Performance Context (during CCO tenure)
| Period (Fiscal YTD windows) | Annualized Distribution Rate as % of NAV | Cumulative Distribution on NAV | Cumulative Total Return on NAV |
|---|---|---|---|
| 11/1/24–11/30/24 | 10.54% | 1.76% | 1.92% |
| 11/1/24–12/31/24 | 11.00% | 2.75% | -1.40% |
| 11/1/24–1/31/25 | 10.94% | 3.65% | 0.22% |
| 11/1/24–6/30/25 | 10.89% | 8.17% | 5.76% |
| 11/1/24–8/31/25 | 10.85% | 9.95% | 8.27% |
| 11/1/24–9/30/25 | 10.93% | 10.93% | 8.59% |
Additional reference:
- Full prior fiscal year (11/1/23–10/31/24) cumulative total return on NAV: 36.35%; 5-year average annual total return on NAV: -3.05% (through 10/31/2024) .
Investment Implications
- Compensation alignment: Fund-level pay for officers is $0; without visibility into AAI employment pay mix, investors cannot evaluate pay-for-performance incentives for the CCO. This suggests alignment at the Fund rests more on fiduciary and regulatory compliance than on Fund-level pay levers .
- Ownership and pledging: Individual CCO holdings are not disclosed; officers/trustees collectively hold <1% and no pledging disclosures for officers are provided. Low disclosed insider ownership at the Fund level limits direct “skin-in-the-game” signals, though nominee hedging disclosure requirements indicate governance awareness of alignment risks .
- Retention/execution risk: Sutula’s multi-fund CCO footprint and tenure since 2019 point to institutional continuity in compliance oversight, reducing regulatory execution risk; however, absence of disclosed employment terms (severance, non-compete, change-of-control) at the Fund level precludes assessment of retention economics .
- Governance pressure: Presence of activist holders (Saba ~6.15%; Goldstein/Dakos ~6.29%) can drive tighter governance and distribution scrutiny, indirectly elevating compliance demands on the CCO and signaling potential for Board-level actions that require strong execution under the compliance program .
- Performance context: Positive NAV total returns across most FY24–FY25 intervals reflect market and strategy dynamics rather than management compensation structures; the Audit Committee charter review and compliance focus (including Section 16 adherence) support a risk-managed operating environment under the CCO’s remit .