Colleen Corwell
About Colleen Corwell
Colleen Corwell is Chief Compliance Officer (CCO) of Runway Growth Finance Corp. (RWAY) and has served since 2022; she was 57 per the 2025 proxy, with compliance leadership roles across Kroll, ACA Group, Alaric Compliance Services, Clarion Partners, Capital One, Ameriprise, and Taylor Companies . She performs her CCO functions under an agreement between RWAY and Kroll and is compensated by Kroll (RWAY reimburses its Administrator for an allocable portion of CCO/CFO compensation); no direct Company compensation is paid to executive officers . Corwell is a CAMS-certified member of ACAMS and holds a B.A. from the College of William & Mary and an M.B.A. from Touro University . Beneficial ownership disclosures show no reported RWAY share ownership for Corwell across 2024–2025 and no 10b5‑1 trading plans entered by any director/officer in Q3 2025 .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| ACA Group | Director; served as outsourced CCO for various firms | — | Provided outsourced CCO leadership across BDCs/RIAs and funds . |
| Alaric Compliance Services | Director; outsourced CCO for various firms | — | Led compliance programs for multiple clients as external CCO . |
| Clarion Partners, LLC (formerly ING Group N.A.) | Chief Compliance Officer & Risk Manager (broker-dealer); Deputy CCO (RIA) | — | Oversaw BD and RIA compliance and risk management functions . |
| Capital One Bank | Senior compliance roles | — | Held senior compliance positions at a major financial institution . |
| Ameriprise Financial | Senior compliance roles | — | Led compliance initiatives in wealth/asset management context . |
| Taylor Companies, LLC (private global investment bank) | Chief Compliance Officer | — | Directed compliance for investment banking operations . |
External Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Kroll Associates, Inc. | Managing Director; engaged to serve as CCO for RWAY and, at times, for other BDCs/RIAs/funds | — | Delivers outsourced compliance leadership; RWAY CCO under Company–Kroll agreement . |
Fixed Compensation
- RWAY pays no direct cash compensation to executive officers; Corwell is compensated by Kroll under the Company–Kroll agreement .
- RWAY reimburses its Administrator the allocable portion of CCO/CFO compensation based on estimated time devoted to RWAY business .
Performance Compensation
| Metric | Weighting | Target | Actual | Payout | Vesting |
|---|---|---|---|---|---|
| Not disclosed for Corwell (outsourced CCO compensated by Kroll) | — | — | — | — | — |
| Notes | No Company RSUs/PSUs/options or bonus metrics are disclosed for Corwell; executive officers receive no direct Company compensation . |
Equity Ownership & Alignment
| As-of Date | Shares Beneficially Owned | % of Class | Notes |
|---|---|---|---|
| 2024-07-01 | — | — | Beneficial ownership table lists “—” for Corwell; shares outstanding 38,547,295 . |
| 2024-12-09 | — | — | Beneficial ownership table lists “—” for Corwell; shares outstanding 37,347,428 . |
| 2025-04-24 | — | — | Beneficial ownership table lists “—” for Corwell; shares outstanding 37,347,428 . |
| 2025-11-06 | — | — | Beneficial ownership table lists “—” for Corwell; shares outstanding 36,134,037 . |
- No options/warrants currently exercisable within 60 days per 2025 proxy; no equity awards disclosed for executive officers .
- No pledging or hedging by Corwell is disclosed; Q3 2025 10‑Q reports no Rule 10b5‑1 trading plans by any director/officer during the quarter .
Employment Terms
| Item | Disclosure |
|---|---|
| Appointment | CCO appointed under agreement between RWAY and Kroll; functions performed pursuant to this agreement . |
| Employer/Compensation Source | Kroll compensates Corwell; RWAY reimburses Administrator for allocable portion of CCO/CFO compensation . |
| Start Date (Officer Since) | 2022 . |
| Indemnification | RWAY entered into indemnification agreements with directors and executive officers (including Corwell), with advancement of expenses, to the maximum permitted by Maryland law and the 1940 Act . |
| Severance / Change-of-Control | Not disclosed for Corwell; no Company employment agreement terms presented given outsourced structure . |
| Stock Ownership Guidelines | Not disclosed for executive officers; director dollar-range ownership provided separately in proxy . |
| Non-Compete / Non-Solicit / Garden Leave | Not disclosed . |
| Clawback | Not disclosed; standard indemnification arrangements noted . |
| Compliance Scope | Administers written policies/procedures reasonably designed to prevent securities law violations; annual review required; serves as CCO . |
Investment Implications
- Alignment: Corwell has no reported RWAY equity holdings and receives no direct Company compensation; her compensation is paid by Kroll, indicating limited direct pay-for-performance alignment with RWAY’s stock or financial outcomes, appropriate for an outsourced compliance role .
- Insider supply risk: No equity awards, no reported holdings, and no Rule 10b5‑1 plans in Q3 2025 suggest minimal insider selling pressure attributable to Corwell .
- Retention/continuity: The CCO role is contracted via Kroll rather than an individual employment agreement with RWAY; retention risk hinges on the Company’s agreement with Kroll rather than executive severance/change‑of‑control economics, which are not disclosed for Corwell .
- Governance/compliance stability: Corwell’s mandate centers on administering and annually reviewing compliance policies/procedures; continuity of outsourced CCO services supports regulatory rigor for a BDC, with standard indemnification protections in place .