Claudia DiGiacomo
About Claudia DiGiacomo
Claudia DiGiacomo (born 1974) serves as Chief Legal Officer of PGIM Short Duration High Yield Opportunities Fund (SDHY) and has served as an officer of the Fund since inception . She concurrently serves as Chief Legal Officer, Executive Vice President and Secretary of PGIM Investments LLC (since August 2020), and holds CLO roles across the PGIM fund complex, including PGIM DC Solutions LLC (since January 2024), PGIM Private Credit Fund (since September 2022), and PGIM Private Real Estate Fund, Inc. (since July 2022) . Her prior roles include Vice President and Assistant Secretary at PGIM Investments LLC (2005–2020) and Associate at Sidley Austin Brown & Wood LLP (1999–2004) . The Fund’s proxy also names her among the designated proxies for shareholder meetings, underscoring her central governance role at SDHY .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Sidley Austin Brown & Wood LLP | Associate | 1999–2004 | Legal associate supporting securities/investment management matters |
| PGIM Investments LLC | Vice President and Assistant Secretary | 2005–2020 | Corporate secretary and legal functions for PGIM-managed funds |
| Prudential (The Prudential Insurance Company of America) | Vice President and Corporate Counsel | Since Jan 2005 | Corporate counsel across Prudential affiliates and fund complex |
External Roles
| Organization | Role | Years | Scope/Notes |
|---|---|---|---|
| PGIM Investments LLC | Chief Legal Officer, Executive Vice President & Secretary | Since Aug 2020 | Legal leadership across PGIM Retail Funds and Prudential Annuities Funds |
| PGIM DC Solutions LLC | Chief Legal Officer | Since Jan 2024 | PGIM Alternatives platform governance |
| PGIM Private Credit Fund | Chief Legal Officer | Since Sep 2022 | Alternatives fund legal oversight |
| PGIM Private Real Estate Fund, Inc. | Chief Legal Officer | Since Jul 2022 | Real estate fund legal oversight |
| PGIM Credit Income Fund | Chief Legal Officer | Since Sep 2023 | Alternatives fund legal oversight |
| PGIM Rock ETF Trust | Chief Legal Officer | Since Sep 2023 | ETF trust legal oversight |
| Prudential Mutual Fund Services LLC | Chief Legal Officer | Since Aug 2020 | Service affiliate governance |
| PIFM Holdco, LLC | Chief Legal Officer | Since Aug 2020 | Prudential affiliate legal oversight |
| AST Investment Services, Inc. | Corporate Counsel | Since Aug 2020 | Corporate counsel for affiliate |
Fixed Compensation
- Pursuant to the Fund’s Management Agreement, the Manager (PGIM Investments LLC) pays all compensation and expenses of the Fund’s officers and employees; officers do not receive compensation from PGIM Investments-managed funds directly, and the Fund does not disclose officer salary/bonus/equity details in its proxy .
Performance Compensation
- No disclosure of performance-linked compensation metrics (e.g., revenue growth, EBITDA, TSR), vesting schedules, stock/option awards, or incentive structures for Fund officers; such compensation, if any, resides within PGIM Investments LLC and is not included in the SDHY proxy .
Equity Ownership & Alignment
- Share ownership disclosures in SDHY proxies pertain to Board Members; the Fund does not present officer beneficial ownership, pledging, hedging, or compliance with stock ownership guidelines for officers .
- Section 16(a) compliance: For the fiscal year ended July 31, 2022, the Fund reported all filing requirements were met except one late Form 3 by another individual; no delinquency is noted for Ms. DiGiacomo .
Employment Terms
- Fund officer since Fund inception; detailed employment contracts, severance, change-of-control terms, non-compete/non-solicit, clawbacks, or garden leave provisions for Fund officers are not disclosed in the SDHY proxy and are covered by PGIM Investments LLC’s arrangements .
Investment Implications
- Compensation alignment: Because officer pay is borne by PGIM Investments LLC and not disclosed at the Fund level, there is no visibility into Claudia DiGiacomo’s pay-for-performance metrics or vesting schedules tied to SDHY’s outcomes, reducing direct compensation-based trading signals from SDHY filings .
- Retention risk: Long tenure at Prudential/PGIM (Corporate Counsel since 2005; senior legal leadership since 2020) and multiple concurrent CLO roles across the PGIM complex indicate institutional continuity and low observable retention risk from SDHY disclosures .
- Ownership/pledging: Absence of officer-level beneficial ownership and pledging disclosures in SDHY proxies limits “skin-in-the-game” analysis from Fund documents; monitor Section 16 filings for updates, noting no delinquency indicated for DiGiacomo in the Fund’s report .
- Governance role: Her recurring designation as a named proxy for shareholder meetings underscores a central legal/governance function, but does not provide compensation or equity alignment signals for trading decisions .