The Consumer Credit SMF Market

Consumer credit has been regulated by the FCA since 2014 and has become one of its most closely watched sectors. Lenders, brokers, debt collectors and debt purchasers have all faced reviews of affordability, forbearance, collections and commission, and the Consumer Duty has raised expectations further. Behind most of those issues sits the question the regulator always asks: did the senior team understand the risks, and act on them?

That makes Senior Manager appointments in consumer credit unusually consequential. The candidate pool with genuine credit and conduct experience is small, and experienced Senior Managers look hard at a firm’s regulatory history before accepting personal accountability for it.

Senior Manager Functions at Consumer Credit Firms

How the regime applies depends on permissions and size:

• Limited permission firms, such as retailers and motor dealers whose main business isn’t credit, are generally Limited Scope firms, with a much smaller set of functions.
• Full permission firms, including most lenders, brokers and debt collectors, are usually Core firms. Their functions typically include the SMF1 Chief Executive, executive directors, the SMF9 Chair and SMF16 and SMF17.
• The largest lenders can meet the Enhanced thresholds, bringing additional risk, finance and board functions.

The Consumer Credit sourcebook and the Consumer Duty shape what the regulator expects the senior team to oversee. Our guide to which SMFs apply at each firm tier explains the mapping.

Where the FCA Focuses

Affordability and Creditworthiness

Lenders must assess whether customers can afford repayments without significant adverse effect. Senior management must understand how the affordability model works in practice, and what happens when customers’ circumstances change. Weaknesses here have led to large-scale redress.

Customers in Financial Difficulty

The FCA expects forbearance and due consideration for customers in arrears. Senior Managers need management information on how those customers are treated, not just on collections performance.

Fair Value and the Consumer Duty

Pricing, fees, charges and the treatment of vulnerable customers all fall under the Consumer Duty. The board must review an annual assessment of outcomes, and Senior Managers must evidence the conclusions.

Complaints and Redress

Complaint trends, including cases escalated to the Financial Ombudsman Service, are often the first sign of a wider problem. The scrutiny of motor finance commission has shown how historic practices can become major issues years later.

How We Run Consumer Credit 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 credit roles, we test how candidates have evidenced good customer outcomes in practice, especially on affordability, arrears and vulnerability.

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

At a credit firm, the chief executive can’t delegate customer outcomes to compliance. We recruit leaders who have run credit businesses through regulatory change, remediation or a Consumer Duty implementation, and who treat customer outcomes as a commercial priority.

Compliance Officers and MLROs

We place compliance leaders with specific CONC expertise: affordability, collections, financial promotions for credit and broker oversight. Where compliance and money laundering reporting are combined, we look for strength in fraud and financial crime risks in lending too.

Risk and Credit Risk Leaders

Larger lenders need risk functions that challenge both credit risk and conduct risk. At Enhanced firms, this can include an SMF4 Chief Risk Officer. At smaller firms, a head of risk with strong conduct awareness often fills the gap.

Finance Leaders

Credit businesses depend on finance teams who understand impairment, funding lines and regulatory reporting. Our sister practice Accountancy Capital recruits qualified finance professionals for lenders below director level, and FD Capital covers finance directors and CFOs.

Chairs and Independent Non-Executives

Many credit firms are founder-led or private equity backed. An independent chair or non-executive with conduct experience gives the board a voice focused on customer outcomes, which is especially valuable during remediation or a skilled person review.

Brokers, Collectors and Specialist Lenders

Credit brokers need Senior Managers who understand commission disclosure, financial promotions and oversight of introducers or appointed representatives. Debt collection and debt purchase firms need particular strength in treating customers in financial difficulty fairly. Specialist lenders serving customers with impaired credit histories face heightened expectations on affordability and vulnerability. We specify each search around the firm’s actual business, not a generic credit profile.

Hiring Challenges in Consumer Credit

• A tight pool of experienced credit compliance and risk leaders, many already approved elsewhere.
• Cautious candidates who want to understand any redress or remediation before accepting accountability. Openness wins.
• Interim needs during remediation, where an experienced interim Senior Manager can stabilise a function while the permanent search runs.
• First-time Senior Managers stepping up from head of function, who need a strong case for approval.

For more, read our article on building the senior team the FCA expects at consumer credit firms.

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, Insurers, Brokers & MGAs, 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 credit brokers and debt collectors?

Yes. We recruit Senior Managers across lenders, brokers, debt collection and debt purchase firms, and specialist lenders.

Can you help a firm going through remediation?

Yes. We regularly recruit interim and permanent Senior Managers for firms under remediation or skilled person review, and we’re open with candidates about what they’re taking on.

Does a limited permission firm need an SMF16?

Limited permission firms are generally Limited Scope firms with a smaller set of functions. We’ll help you confirm exactly what applies to your firm before you recruit.

How long does a consumer credit SMF search take?

Typically three to six weeks to shortlist, then notice periods and the regulator’s assessment period of up to three months once a complete application is submitted.