Pre-Offer Checks for SMF Candidates: A Recruiter’s Checklist
By the time a firm makes an offer to a Senior Manager candidate, the checks that decide whether the regulator will approve them should already be done. In practice, many firms run them afterwards, as part of onboarding. That’s when surprises cost the most.
This is the checklist we use before any SMF candidate reaches a client’s shortlist, with the red flags we look for and how we handle them.
Why We Check Before the Shortlist, Not After the Offer
A Senior Manager can’t start until the regulator has approved them, and approval turns on the fit and proper test. If something in a candidate’s history causes a problem, the firm wants to know before it commits, and the candidate wants to know before they resign. Checking early protects both, and it means the approval application goes in with no surprises.
These checks are done with the candidate’s knowledge and consent. Most candidates welcome them, because they’d rather deal with any issue openly and early.
The SMF pre-offer checklist
- FCA Register: current and past approved functions, firms and dates match the CV
- FCA Directory: certification history for candidates coming from certified roles
- Regulatory references: requested early from every relevant employer for the past six years
- Direct question on disclosures: anything the candidate expects a reference or check to show
- Criminal records check: arranged at conditional offer stage, with consent
- Insolvency and credit: Individual Insolvency Register and credit history checked
- Companies House: current and past directorships, dissolved or insolvent companies, disqualifications
- Other roles and time commitment: current SMF, NED and fractional roles confirmed
- Qualifications: professional qualifications verified, including Level 4 and SPS for advising roles
- Competence against the Statement of Responsibilities: evidence for each major responsibility
How Each Check Works
The FCA Register and Directory
The FCA Financial Services Register shows the Senior Manager Functions and controlled functions an individual holds or has held, the firms and the dates. We compare it line by line with the CV. Differences are usually innocent, a role title that doesn’t match the designation, for example, but they need explaining before the regulator asks.
Regulatory References
Every SMF application needs regulatory references from relevant employers covering the previous six years, using the mandatory template. We ask candidates directly whether anything is likely to be disclosed, and we encourage clients to request references as early as the candidate is comfortable with. Slow references are among the commonest causes of delay.
Criminal Records
Firms must carry out a criminal records check through the Disclosure and Barring Service or equivalent as part of an SMF application. We arrange this at conditional offer, with consent. As with every check, non-disclosure is usually more serious than the underlying matter.
Financial Soundness
A search of the Individual Insolvency Register and a credit check cover bankruptcy, individual voluntary arrangements and county court judgments. Rarely an issue, but essential to know.
Directorships
Companies House shows current and past directorships, companies that failed while the candidate was a director, and any disqualification. Undisclosed directorships can point to conflicts of interest or time commitments.
Other Roles
Many experienced Senior Managers hold several roles, especially fractional compliance officers and MLROs. We confirm every current commitment and discuss whether the new role is realistic alongside them. The regulator will ask the same question.
Competence
The only forward-looking check, and often the most important. We map the candidate’s experience against the draft Statement of Responsibilities and test it at interview. Our guide to interviewing an SMF candidate sets out the questions we use.
Red Flags and How We Handle Them
| What we find | What it might mean | How we handle it |
|---|---|---|
| Functions on the Register don’t match the CV | A title mismatch, or a role overstated | Ask the candidate; confirm with the Register and references |
| A very short SMF tenure | Restructuring, interim assignment, or a difficult exit | Discuss openly; check what the reference says |
| An undisclosed directorship | Oversight, conflict or time commitment | Discuss; assess relevance and time |
| A failed company where they were a director | Not disqualifying in itself | Understand the circumstances and their role |
| Something the candidate expects a reference to disclose | A past conduct or disciplinary matter | Assess relevance, seriousness and time elapsed; plan disclosure |
| Many current roles | Capacity concerns | Confirm days committed and flexibility |
| A lapsed qualification or SPS | Can’t perform an advising function | Confirm renewal timetable before offer |
A strong compliance oversight candidate mentions, when asked directly, that a former employer recorded a Conduct Rules breach several years ago relating to a late regulatory return in her area. Raised early, the firm reviews the circumstances, is satisfied, and discloses it in the application with an explanation. Had it first appeared in the reference after she’d resigned, the process would have been far harder for everyone.
What Happens When We Find Something
Finding something rarely ends a candidacy. The regulator considers how relevant and serious a matter is, how long ago it happened and what the individual has done since. Firms should take the same approach, record their reasoning and disclose relevant matters fully in the application. Applications that address issues openly are far more likely to succeed than those that leave the regulator to find them. Our guide to what goes wrong in Form A submissions covers the application side.
Checks for Fractional and Interim Candidates
Fractional and interim Senior Managers go through the same checks, with extra attention to their other commitments. An interim MLRO who already holds SMF17 at two other firms may be excellent, but the firm and the regulator will both want to know how many days they can realistically give, how conflicts between clients are managed, and how quickly they can respond when something urgent happens. We confirm these points in writing before introduction, so the engagement terms and the approval application say the same thing.
Checks for Board Appointments
For chairs and committee chairs, the same checks apply, plus a closer look at other board roles and potential conflicts between them. Independence matters: we check for any relationship with the firm, its owners or its advisers that could compromise it. For dual-regulated firms, we also consider how the candidate would fit the board’s collective suitability, because the PRA will.
For Candidates
If you’re applying for a Senior Manager role, run these checks on yourself first. Look up your own record on the FCA Register, check your directorships at Companies House, and think about what each of your references might say. Raising anything early, with context, is always better than having it discovered.
Why This Matters for Timelines
Running these checks before the shortlist doesn’t slow a search down. It speeds up the part that matters most, the approval. An application that goes in complete, with issues already explained, is far less likely to attract questions that extend the regulator’s assessment. Our SMF appointment timeline shows how the stages fit together.
SMF Candidate Assessment
Guides and services behind every SMF Capital shortlist. Every SMF search is led personally by Adrian Lawrence FCA
Getting Approved
The standards we check against.
→ The fit and proper test
→ Regulatory references
Assessment
How we assess candidates.
→ Interviewing an SMF candidate
→ Statements of Responsibilities
Board Roles
Checks for board appointments.
→ Chair and committee chairs
→ Regulated CEO (SMF1)
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
Is it legal to run these checks before an offer?
Yes, with the candidate’s knowledge and consent, and in line with data protection requirements. Criminal records checks are usually arranged at conditional offer stage.
Do you share what you find with the client?
We discuss anything relevant with the candidate first and agree how it will be raised with the client.
What if a candidate won’t consent?
That’s their choice, but a Senior Manager application can’t proceed without these checks, so it usually means the candidacy can’t go forward.
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 reviews every SMF Capital candidate’s regulatory history personally before introduction. View Adrian’s ICAEW profile.
Want Candidates Checked Before You Meet Them?
Every SMF Capital shortlist has been through these checks. Tell us about your hire and we’ll come back to you the same working day.
Adrian Lawrence FCA is the founder of SMF Capital and a Fellow of the Institute of Chartered Accountants in England and Wales and holds an ICAEW practising certificate in his own name. He holds a BSc from Queen Mary College, University of London, and has over 25 years of experience working with boards, investors and business owners across the UK. He founded SMF Capital to help FCA and PRA-regulated firms appoint the Senior Managers the regulators expect, with the fit and proper assessment built into every search, and personally leads every Senior Manager Function search.
