The Insurance SMF Market

Insurance covers two very different parts of the Senior Managers regime. Insurers are usually dual-regulated, answering to the Prudential Regulation Authority as well as the FCA, with a full set of board and executive Senior Manager Functions. Brokers, managing general agents and other intermediaries are mostly solo-regulated Core firms with a compact senior team. Both have seen rising expectations under product governance rules and the Consumer Duty.

The market is also changing fast. Broker consolidation has created large private equity-backed groups, MGAs have grown quickly on delegated authority from insurers and Lloyd’s syndicates, and capacity providers now scrutinise the senior teams they work with almost as closely as the regulator does.

Senior Manager Functions in Insurance

Insurers

Dual-regulated insurers carry PRA-designated functions including the Chief Executive, Chief Finance, Chief Risk and Chief Actuary functions, the Chief Underwriting Officer where relevant, the Head of Internal Audit, the Chair and committee chairs. FCA-designated functions include compliance oversight and, for firms carrying on life business, money laundering reporting. Each regulator approves its functions with the other’s consent.

Brokers and MGAs

Most intermediaries are Core firms, with functions typically including the Chief Executive, executive directors, the Chair where there is one and SMF16 Compliance Oversight. The Money Laundering Regulations apply to life insurance and certain investment-related business, but not to general insurance intermediation, so many general insurance brokers and MGAs don’t need an SMF17. They still need senior oversight of fraud and sanctions risk.

Where the Regulators Focus

Product Governance and Fair Value

Under the product governance rules in PROD and the Consumer Duty, manufacturers and distributors must make sure products meet their target market’s needs and offer fair value. MGAs often act as co-manufacturers, which makes this a direct senior management responsibility.

Distribution Chains and Remuneration

The FCA expects firms to understand the whole distribution chain and whether total remuneration is consistent with fair value. Senior Managers need to know how much of each premium reaches the insurer.

Oversight of Appointed Representatives and Delegated Authority

Principal firms are responsible for their appointed representatives, and MGAs must show control over business written in their name.

Prudential Soundness

For insurers, the PRA’s focus on capital, reserving and risk management puts finance, actuarial and risk leadership at the centre of every appointment, and the PRA assesses the board’s collective suitability as well as each individual’s.

How We Run Insurance SMF Searches

Every search starts from the Statement of Responsibilities the new Senior Manager will sign and any Prescribed Responsibilities they’ll carry. We build the specification around that accountability rather than a job title, then approach candidates directly and in confidence. Most of the strongest candidates aren’t actively looking, and many already hold approvals at competing firms.

Before anyone reaches your shortlist, we test them against the fit and proper test: prior approvals, regulatory history, directorships and financial soundness. We start regulatory references early, because late references are one of the most common causes of delay. For insurance roles, we test candidates’ experience of product governance, fair value and, for insurers, prudential oversight.

Adrian Lawrence FCA interviews every shortlisted candidate personally, and we stay involved until your new Senior Manager is approved and in post. For a realistic view of the stages, see how long an SMF appointment actually takes, and for the full service, our SMF recruitment services page.

The Senior Roles We Recruit

Chief Executives

We recruit chief executives for insurers, brokers and MGAs who combine underwriting or distribution credibility with ownership of conduct and customer outcomes.

Compliance Officers

Insurance compliance is specialised. We place SMF16 holders with direct knowledge of insurance distribution, product governance and fair value, and of the different expectations for commercial and personal lines. For smaller brokers and early-stage MGAs, a fractional compliance officer is often the practical answer.

Chief Risk Officers and Actuarial Leaders

For insurers, we recruit risk leaders who can challenge capital and reserving assumptions, and we support searches for actuarial leadership alongside them.

Finance Leaders

Intermediaries handle client money and risk transfer arrangements, and insurers face demanding prudential reporting. For growing brokers and MGAs, our sister practice FD Capital places fractional and interim finance directors with insurance experience.

Chairs and Independent Non-Executives

Independent board members with insurance and conduct experience strengthen challenge on fair value and product governance, and reassure capacity providers and investors.

Commercial Lines, Wholesale and Personal Lines

The right Senior Manager depends heavily on the firm’s mix of business. Personal lines firms deal mainly with consumers, so the Consumer Duty, vulnerability and claims outcomes dominate. Commercial and wholesale brokers, and MGAs writing specialist commercial risks, deal largely with business customers, where some Consumer Duty requirements apply differently, but product governance, conflicts and remuneration still matter. Many of these firms place business into the London market, which brings its own oversight.

A compliance officer who has only worked in personal lines may need time to adjust to a wholesale broker, and the reverse is equally true. We specify every insurance search around the firm’s actual book of business, so candidates are tested against the risks they’ll really oversee.

Hiring Challenges in Insurance

• Consolidation, raising questions about which functions sit at group level and which at each acquired firm. Our article on change in control and the Senior Manager team covers the issues.
• MGA growth outpacing the senior team, particularly in compliance, finance and risk. Our multi-SMF team build service helps firms recruit ahead of growth.
• A specialist candidate pool, with many experienced insurance compliance and risk leaders preferring established firms.
• Dual-regulated timelines for insurers, where PRA interviews and board suitability add time to the approval process.

For more, read our article on building the senior team at insurance brokers and MGAs.

Other Sectors We Recruit For

SMF Capital recruits Senior Managers across the regulated market. Alongside this sector, we run dedicated searches for Wealth Managers & Advice Firms, Investment Managers & Hedge Funds, Consumer Credit Firms, Banks & Building Societies, Payments, E-Money & Fintech and Crypto-Asset Firms. We also work with overseas firms opening UK branches and firms seeking FCA authorisation, in London, Birmingham, Bristol and across the UK.

Frequently Asked Questions

Do you recruit for Lloyd’s managing agents and MGAs?

Yes. We recruit Senior Managers for managing agents, MGAs, brokers and insurers, including roles where capacity providers will review the appointment.

Does a general insurance broker need an MLRO?

General insurance intermediation is outside the Money Laundering Regulations, so many general insurance brokers don’t need an SMF17. They still need senior oversight of fraud and sanctions. We’ll confirm what applies before you recruit.

Can you handle PRA-designated insurer appointments?

Yes. We plan insurer searches around both regulators’ expectations, including PRA interviews and the board’s collective suitability.

Do you provide interim compliance cover?

Yes. Our fractional and interim SMF cover can bridge a vacancy while the permanent search runs.