Chair of FCA-Regulated Firm Recruitment

Chair of FCA-Regulated Firm Recruitment

Exec Capital recruits Chairs for the Boards of FCA-regulated firms across the UK — the SMF9 appointment that anchors the firm’s governance, leads the Board’s oversight of the executive team, and acts as the principal counter-balance to the CEO. The role is materially different from a corporate Chairman appointment because the SMF9 holder is personally accountable to the regulator for the way the Board discharges its responsibilities. We work with asset managers, wealth managers, insurance and brokerage firms, fintechs, payment institutions and consumer credit lenders on permanent and interim Chair appointments.

If you are running an SMF9 search now, planning Chair succession in the next 12-24 months, or considering whether to renew an existing Chair past their typical tenure, we are happy to discuss the specifics directly. Every SMF mandate is led personally by Adrian Lawrence FCA.

What an SMF9 Chair appointment involves

SMF9 is the FCA designation that attaches personal regulatory accountability to the Chair of the Board of an FCA-regulated firm. The role is one of the most consequential governance appointments a regulated firm makes — the SMF9 holder is responsible for the effectiveness of the Board itself, leads the Board’s oversight of strategy, risk appetite, culture and conduct, and is the principal independent voice on the Board.

The substantive scope covers what a corporate Chair would recognise — leadership of the Board, agenda setting, evaluation of the executive team, succession planning at Board level — with the regulatory dimension layered through it. The Chair’s Statement of Responsibility includes prescribed responsibilities allocated specifically to the Chair role, and the Chair is expected to manage the Board’s relationship with the FCA at the Board level on matters of supervisory significance.

For the comprehensive treatment of how to approach an SMF9 appointment, see our SMF9 Chair hiring guide. For the corporate (non-regulated) Chair appointment, see Chairman recruitment.

How Exec Capital approaches SMF9 mandates

We structure every SMF9 mandate around three workstreams running together: candidate identification (with prior SMF9 holders first, then SMF14 SID step-up candidates, then experienced regulated-firm NEDs and corporate Chairs with the right preparation), regulatory pathway preparation (Form A submission, fit-and-proper readiness, regulatory references), and the governance dimension (Statement of Responsibility drafting, alignment with the responsibilities map, Chair-CEO scope clarification, board composition and committee chair fit).

The work is substantively different from a corporate Chair search. The candidate pool is genuinely smaller, candidate scrutiny of the firm is more intensive, and the Statement of Responsibility drafting needs to handle the boundary between Chair accountability and CEO accountability with care. Strong SMF9 candidates with prior experience will probe the existing CEO, the responsibilities map, and the firm’s recent regulatory history before accepting a role.

The candidate pool

The SMF9 candidate pool is structurally narrow. Prior SMF9 holders are the strongest signal — typically not actively seeking moves, mid-tenure in their current Chair role, and most genuinely available 18 months before their existing term ends. SMF14 (Senior Independent Director) holders are the natural step-up pool, with existing FCA approval and direct observation of the Chair role at close range. Experienced regulated-firm NEDs without SID experience can be credible particularly where the candidate has chaired Risk, Audit or Nomination Committees. Corporate Chairs without prior SMF approval can clear the SMF9 fit-and-proper assessment with the right preparation — typically structured FCA induction, sponsorship from a current SMF holder, and a deliberately staged Statement of Responsibility.

Searches that connect with the natural rhythm of Chair tenure — engaging candidates 18 months before their existing term ends — see substantively better availability than searches that begin only after the previous Chair has departed.

Permanent and interim Chair appointments

SMF9 Chair appointments are most commonly permanent, with two three-year terms the typical tenure norm. Interim Chair appointments occur during periods of transition — Chair illness, conflict, departure, or while a permanent successor goes through FCA approval. Fractional Chair arrangements are not a feature of the regulated firm market in the same way as fractional executive roles; the time commitment of the Chair role typically runs to 30-50 days per year for Core firms and 80-100 days for Enhanced firms, paid as a fixed annual fee.

For all engagement models, FCA approval is required. The Chair appointment must be approved as the SMF9 holder before the candidate takes up the role, and the Statement of Responsibility must be in place from day one.

Indicative timelines

The realistic timeline for a clean SMF9 appointment runs to fourteen to twenty-four weeks from search opening to first day. Typical breakdown: four to six weeks of search and shortlisting (extended where the candidate pool requires deeper market mapping or where the Chair search involves a parallel CEO search), three to five weeks of selection and offer (often longer than other SMF roles because the candidate, the Chair-elect, and the executive team all need time to evaluate fit), four to twelve weeks of FCA Form A approval. SMF9 candidates may face an FCA interview as part of approval, which can extend the timeline.

Sectors and firm types we work across

Our SMF9 mandates span the FCA-solo-regulated firm population — including asset managers and wealth managers across the AUM range, insurance intermediaries, fintechs and payment institutions, consumer credit lenders, and specialised investment firms. The Chair role varies meaningfully by firm classification: SMF9 in a Core firm typically operates within a smaller Board of four to six directors, while SMF9 in an Enhanced firm operates within a more populated governance environment that includes formal Risk, Audit, Remuneration and Nomination Committees with their own SMF-designated chairs.

For the broader FCA-regulated firm cluster, see our FCA Regulated Firm Executive Recruitment hub. For the SMF Roles overview, see our SMF Roles guide.

Working with Exec Capital on an SMF9 mandate

Every SMF9 mandate is led personally by Adrian Lawrence FCA. The Chair role is too consequential — and the candidate-firm fit too important — to be handed to a junior consultant or generalist. We work on a retained basis for Chair searches, and the engagement runs through to the candidate’s first Board meeting rather than ending at offer acceptance.

For boards beginning Chair succession, refreshing how they have approached previous searches, or considering whether to renew an existing Chair past their typical tenure, we offer a structured initial conversation that walks through the responsibilities map, the role specification and the realistic candidate pool before any formal mandate begins. Chair succession typically runs on an 18-24 month horizon — there is value in the early conversation even if the formal search is some way off.

Further reading

For the complete treatment of SMF9 appointments — including the FCA approval process, the fit-and-proper assessment, the Statement of Responsibility, the Chair-CEO relationship, and common search pitfalls — see our SMF9 Chair hiring guide. For the broader SMCR framework, see our SMF Roles guide.

For the related Board roles, see our SMF14 SID hiring guide and SMF1 CEO hiring guide. For the FCA’s published guidance, see the FCA’s SMCR overview. For corporate governance frameworks complementing SMCR, see the UK Corporate Governance Code.