Multi-SMF Board and Executive Team Build
Some Senior Manager recruitment isn’t a single vacancy. It’s a firm crossing into Enhanced status and suddenly needing several new designations at once, a board refreshing its chair, committee chairs and risk function together, or a new owner rebuilding a governance structure after an acquisition. Running these as separate, sequential searches can stretch a full refresh well beyond a year. SMF Capital runs multi-SMF programmes as a single, sequenced project, with every search overseen by a Chartered Accountant.
When a Coordinated Build Makes Sense
Core-to-Enhanced transitions
Moving from Core to Enhanced status brings several new requirements close together: a Chief Risk Officer (SMF4), a Head of Internal Audit (SMF5), and often risk, audit, remuneration and nomination committee chairs (SMF10 to SMF13) and a Senior Independent Director (SMF14), depending on the board’s structure. The firm also needs a Responsibilities Map and handover arrangements. Firms that see the threshold coming have room to sequence this sensibly rather than filling several roles in a rush once it is crossed. Our guides to which SMFs apply at which firm tier and becoming an Enhanced firm set out what changes.
Coordinated board refreshes
Where a board is reviewing its chair, one or two committee chairs and its Senior Independent Director together, often because several tenures end around the same time, coordinating the searches avoids a drawn-out sequential timeline and the risk of assessing each appointment in isolation from how the people will need to work together.
New firms building a first senior team
Firms applying for authorisation need their core Senior Managers identified before the application is submitted: usually a chief executive, a finance lead, a compliance officer and an MLRO, plus a chair and non-executives for larger applicants. See our FCA authorisation support page and the authorisation journey.
Post-acquisition and restructuring rebuilds
Where ownership or structure changes significantly, the existing Senior Manager population sometimes needs a fresh look rather than incremental patching. New investors, a new strategy or a merged entity’s governance can all call for a coordinated rebuild. Our guide to keeping the SMF team through integration covers the people side of an acquisition.
What a Typical Core-to-Enhanced Build Includes
| Role | Function | Typical timing |
|---|---|---|
| Chief Risk Officer | SMF4 | First, as risk management usually needs building before the transition |
| Head of Internal Audit | SMF5 | Early, though often co-sourced or fractional at first |
| Audit and risk committee chairs | SMF11, SMF10 | Alongside or just after the CRO, so the committees are ready |
| Remuneration and nomination committee chairs | SMF12, SMF13 | Where the board structure requires them |
| Senior Independent Director | SMF14 | Often filled from existing non-executives |
| Compliance officer and MLRO | SMF16, SMF17 | Often split into two roles at this point |
Every firm is different, and not every Enhanced firm needs every role. We confirm the requirement before any search starts.
How a Coordinated Programme Works
- Map the requirement. We confirm which functions the firm needs, which can be filled internally and which need external searches.
- Sequence the searches. We decide which roles must be filled first. Usually that is the chair, because the chair and chief executive relationship shapes everything that follows, then the control functions.
- Apply one standard. The fit and proper bar, sector competence and cultural assessment are applied consistently across every appointment, rather than drifting between separate searches.
- Assess the team, not just the individuals. We look at how the resulting board or executive team will work together, extending the chemistry assessment we use for chair and chief executive appointments across the full set of roles.
- Plan the approvals. Several Form A applications for one firm need coordinating. We plan the timing so the applications are consistent and the regulator can process them smoothly.
- Personal interviews. Our specialist team interviews every shortlisted candidate across the programme.
Our guides to the chair and CEO chemistry problem and how long an SMF appointment takes explain why sequencing matters.
Scenario: A wealth manager expects to cross the Enhanced threshold within 18 months. Its board has a long-serving chair, no separate risk or audit committees and a combined compliance officer and MLRO. We map the requirement with the board, recruit a Chief Risk Officer first, then an audit committee chair and a risk committee chair in parallel, and finally split the compliance and MLRO roles. The Form A applications are staggered so each candidate’s Statement of Responsibilities fits the new Responsibilities Map, and the firm is ready before the threshold is reached.
Common Mistakes in Multi-SMF Builds
- Launching every search at once. It feels faster, but the chair and the chief executive shape what the rest of the team needs, so appointments made before them often have to be revisited.
- Hiring for the documents rather than the business. Filling a list of functions to satisfy the rules, without asking what the board and committees actually need to do, produces a team that looks compliant but doesn’t work well together.
- Underestimating approval time. Each Form A can take up to three months to determine, and longer if the application is incomplete. Planning six to twelve months ahead of a tier transition avoids a gap.
- Forgetting the Statements of Responsibilities. New appointments change who owns what. If the statements and the Responsibilities Map aren’t redrawn together, gaps and overlaps appear on day one.
- Leaving the compliance officer and MLRO combined for too long. At Enhanced scale, a single person holding both functions is often no longer proportionate. See when to split a combined SMF16 and SMF17 role.
What This Saves You
Beyond the efficiency of one project instead of several, a sequenced build reduces the risk of an unplanned governance gap: one search finishing months before another, leaving the firm operating with a partly refreshed, partly outdated senior structure for longer than necessary. It also reduces the risk of appointing people who are individually strong but don’t work together, which is expensive to put right once they are approved.
A coordinated build is often a good moment for a wider look at the structure. Our governance and SMF structure review can run first, so the build is based on an accurate picture of what the firm needs.
Who We Work With
Most of our multi-SMF builds are for investment managers, wealth managers, consumer credit firms and payments businesses approaching Enhanced status, newly acquired firms whose new owners want to reset the governance structure, and applicants building a first senior team for authorisation. On a typical build we work directly with the chair or chief executive, the company secretary and, where there is one, the nomination committee, and we keep the board updated at each stage of the programme rather than only when a shortlist is ready.
Board and Executive Team Builds
Several Senior Managers, one coordinated programme. Every multi-SMF build is overseen by Adrian Lawrence FCA
Board Roles
Chairs and non-executives.
→ Chair and committee chairs → Retained executive searchSMF9 explained →
Control Functions
Risk, audit and compliance.
→ Chief Risk Officer (SMF4) → Head of internal audit (SMF5)Compliance officer and MLRO →
Executive Roles
The leadership team.
→ Regulated CEO (SMF1) → CFO (SMF2)Executive directors (SMF3) →
Planning the Build
Tier, structure and documents.
→ Governance review → Responsibilities Map templateBecoming an Enhanced firm →
Every multi-SMF build is overseen by Adrian Lawrence FCA
Frequently Asked Questions
How long does a multi-SMF build take?
Typically six to nine months from mapping to the last approval for a Core-to-Enhanced build, compared with well over a year if the searches run one after another.
Can some roles be filled internally?
Yes. Existing non-executives often take on committee chair or Senior Independent Director roles. We advise on where internal candidates fit and focus the external searches on the gaps.
Do all the Form A applications go in together?
Not usually. We stagger them so each application reflects the final structure and the regulator can process them in a sensible order.
Do you work with the firm’s lawyers and compliance consultants?
Yes. On larger builds we coordinate with the firm’s legal and regulatory advisers so the Responsibilities Map, Statements of Responsibilities and applications all line up.
Is it cheaper than separate searches?
Usually, because the research, assessment framework and board time are shared across the programme.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He oversees every SMF Capital search. View Adrian’s ICAEW profile.
Planning Several Senior Manager Appointments?
Tell us what’s changing at your firm. We’ll map the requirement, sequence the searches and come back to you the same working day.