Preparing for an FCA or PRA Senior Manager Approval Interview
For many Senior Manager appointments, the Form A is not the end of the process. The FCA or PRA may invite the candidate to an interview before deciding whether to approve them. For candidates, it can feel like the most daunting part of taking on a regulated role. It doesn’t need to be. The interview is a structured conversation about the role, the firm and the candidate’s readiness, and the preparation it requires is the same preparation a good Senior Manager should be doing anyway. This guide explains when interviews happen, what the regulators assess, the kinds of questions candidates face, and how firms can help their candidates prepare.
When Do the Regulators Interview?
Not every Senior Manager candidate is interviewed. The regulators decide case by case, and interviews are more likely where:
- the role is significant, such as chief executive, chair, CFO or chief risk officer at a larger firm;
- the firm is dual-regulated, where the PRA routinely interviews candidates for its most senior functions;
- the candidate is taking on their first Senior Manager role, or a role larger than any they’ve held before;
- the firm is new, under close supervision or dealing with a regulatory issue; or
- the Form A or checks have raised questions the regulator wants to explore.
The firm is usually told that an interview will take place and given dates. Interviews are typically conducted by a small panel of supervisors and, sometimes, specialists. They usually last around an hour or so, in person or by video.
What the Regulators Are Assessing
The interview tests the same things as the rest of the application: whether the candidate meets the standards in the FCA’s FIT sourcebook and is ready for the specific responsibilities in their Statement of Responsibilities. In practice, the panel wants to know:
| Area | What they want to see |
|---|---|
| Understanding of the firm | The business model, customers, products, risks and current regulatory issues |
| Understanding of the role | What the candidate is accountable for, how they will oversee it and how it fits with other Senior Managers |
| Regulatory knowledge | The rules that matter most for the role and firm, and current regulatory priorities |
| Reasonable steps | How the candidate will get assurance that their area is working, and what they will do if it isn’t |
| Judgement | How they would handle realistic scenarios, conflicts and escalation |
| Capacity | Whether they have time for the role alongside other commitments |
The panel is not trying to catch the candidate out. It is trying to find out whether the candidate understands what they are taking on. Candidates who know their firm and their role well, and are honest about what they still need to learn, generally do well.
The Kinds of Questions Candidates Face
Questions vary with the role and firm, but they tend to fall into recognisable themes:
- The firm: What are the firm’s biggest risks? How does it make money? What would cause it serious harm?
- The role: Talk us through your Statement of Responsibilities. What will you do in your first 90 days? Who will you rely on?
- Oversight: How will you know whether your area is working? What management information will you receive? What would make you escalate?
- Regulation: What do the regulator’s current priorities mean for this firm? How does the Consumer Duty apply to your area?
- Scenarios: What would you do if the business wanted to launch a product you had concerns about? If you discovered a significant breach?
- Accountability: What does the Duty of Responsibility mean for you? Which Senior Manager Conduct Rules are most relevant to your role?
- Experience: Tell us about a time you challenged senior colleagues, or dealt with a regulatory problem.
For prudential roles at banks and insurers, expect detailed questions on capital, liquidity or solvency, stress testing and recovery planning. For control function roles such as SMF16 and SMF17, expect questions on monitoring, financial crime risk and how the candidate will maintain independence.
How Candidates Should Prepare
- Know the firm thoroughly. Read the business plan, the latest board papers you can access, the risk register, recent regulatory correspondence and any skilled person or internal audit reports relevant to your area.
- Know your Statement of Responsibilities. Be able to explain each responsibility, how you will discharge it, and how it interacts with other Senior Managers in the responsibilities map.
- Prepare a 90-day plan. Have a clear view of what you will do first and why. Our guides to the first 90 days for a new MLRO or compliance officer may help.
- Refresh your regulatory knowledge. Focus on the rules most relevant to your role and the regulator’s current priorities, using the FCA’s and PRA’s own publications.
- Prepare examples. Have specific examples of challenge, escalation, problem-solving and leadership from your career, with outcomes.
- Practise. A mock interview with someone who understands the regime is the single most effective preparation.
- Be honest about gaps. If there’s something you don’t yet know, say so and explain how you’ll address it. Bluffing is the quickest way to lose the panel’s confidence.
Scenario: A candidate for her first CFO role at a building society is told the PRA will interview her. The society gives her access to recent ALCO and board risk committee papers, arranges sessions with the outgoing CFO and the chief risk officer, and organises a mock interview with a former supervisor. In the real interview, she is asked how she would respond if the society’s liquidity position deteriorated quickly. Because she has studied the contingency funding plan and discussed it with the treasury team, she answers with specific actions. She is approved two weeks later.
How Firms Can Help
The firm has as much at stake in the interview as the candidate. Firms that support their candidates well:
- give the candidate early access to key documents, under appropriate confidentiality
- arrange briefings with other Senior Managers, the chair and key control functions
- make sure the Statement of Responsibilities and responsibilities map are final and accurate before the interview
- brief the candidate on any open regulatory issues the panel may raise
- organise a mock interview with someone experienced in the regime
- make sure the candidate isn’t being asked to prepare while carrying an unrealistic workload elsewhere
For external candidates still serving notice, access to information must be handled carefully. Our guide to managing the gap between offer and approval covers what candidates can do before they join.
After the Interview
The regulator may approve the application, ask further questions, or, in a minority of cases, signal concerns that lead the firm to reconsider. If follow-up questions arrive, respond promptly and fully. If the concerns are serious, read our guide to what happens when an SMF application is refused or withdrawn. Most candidates who have prepared well never need it.
Whatever the outcome, the preparation is not wasted. Everything the candidate has done to prepare, from understanding the firm’s risks to planning the first 90 days, is exactly what they’ll need when they start the role.
Common Mistakes in Approval Interviews
| Mistake | Better approach |
|---|---|
| Generic answers that could apply to any firm | Refer to the firm’s actual products, customers and risks |
| Not knowing the Statement of Responsibilities | Be able to talk through every line of it |
| Over-reliance on the team | Explain how you’ll oversee the team, not just that you have one |
| Defensiveness about past issues | Be open and explain what you learned |
| Bluffing on technical questions | Acknowledge gaps and how you’ll close them |
| Underestimating time commitment questions | Be specific about your other roles and how you’ll manage them |
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Frequently Asked Questions
Does every Senior Manager candidate get interviewed?
No. The regulators decide case by case. Interviews are most common for significant roles, dual-regulated firms and first-time Senior Managers.
Who conducts the interview?
Usually a small panel of supervisors, sometimes with specialists, from the FCA, the PRA or both.
Can the firm attend the interview?
The interview is with the candidate. The firm’s role is to help them prepare beforehand.
What if I can’t answer a question?
Say so honestly and explain how you would find out or address the gap. Bluffing does far more harm.
Can you help prepare our candidate?
Yes. We prepare candidates we place for the approval process, including the interview, as part of every SMF search.
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, including Exec Capital. He leads every SMF Capital search personally and prepares candidates for the approval process. View Adrian’s ICAEW profile.
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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.
