FCA

FCA-Regulated Firm Executive Recruitment

Exec Capital is a specialist executive search firm placing senior leaders into UK FCA-regulated businesses. Our practice covers the senior management functions designated under the Senior Managers and Certification Regime — SMF1 CEO, SMF3 Executive Director, SMF4 Chief Risk Officer, SMF5 Head of Internal Audit, SMF24 Chief Operations Function — alongside the SMF9 Chair and SMF14 Senior Independent Director appointments that anchor regulated firm Boards. We work with asset managers, wealth managers, insurance and brokerage firms, fintechs, payment institutions, consumer credit lenders and specialised investment firms across the FCA-solo-regulated firm population. Every mandate carries the regulatory dimension built into the brief from day one — Statement of Responsibility, FCA approval pathway, fit-and-proper readiness, regulatory references — alongside the substantive commercial and governance criteria that any senior search requires.

Hiring senior leaders for FCA-regulated firms is materially different from hiring at non-regulated businesses, and the gap shows up most clearly in three places: the candidate pool is structurally narrower than for corporate equivalent roles, the regulatory dimension affects who is genuinely available and what compensation looks like, and the FCA approval timeline needs to be planned into the search rather than discovered at the back end. Boards approaching their first regulated-firm search often expect a corporate executive search with a compliance addendum — and find the reality is closer to a regulatory-led search with the commercial dimension layered on top. Our practice is built on getting that orientation right from the brief.

The senior management functions we recruit for

Our FCA-regulated firm practice covers six core senior management function appointments. Each is run as an integrated commercial-and-regulatory search — and each has its own dedicated service page setting out our approach to that specific role.

CEO of FCA-Regulated Firm — SMF1

The Chief Executive of an FCA-regulated firm holds SMF1 and is the most senior individual personally accountable to the regulator. The role is a different exercise from a corporate CEO appointment because the candidate must be FCA-approved before they take up the role, the Statement of Responsibility is a regulatory document with weight, and the personal accountability under the regime affects who is genuinely available. We run permanent, interim and (less commonly) fractional SMF1 mandates across the FCA-solo-regulated firm population.

CEO of FCA-Regulated Firm Recruitment →

COO of FCA-Regulated Firm — SMF24

The Chief Operations Function holder at an FCA-regulated firm — typically the COO — sits at the centre of operational delivery, operational resilience, third-party risk, and the firm’s ability to deliver important business services within agreed impact tolerances. The candidate pool is the tightest of any executive SMF we work on, and the gap between what boards expect from a COO search and what the role actually requires under SMCR is particularly wide. Operational resilience is central to the role since the FCA’s policy took effect in March 2022.

COO of FCA-Regulated Firm Recruitment →

Executive Director — SMF3

SMF3 attaches personal regulatory accountability to executive directors who sit on the Board of an FCA-regulated firm but are not the CEO. In mid-sized regulated firms the role typically stacks with another executive SMF — a COO holding SMF3 plus SMF24, a CFO holding SMF3 plus SMF2 (where applicable), a CRO holding SMF3 plus SMF4. The Statement of Responsibility covers all the SMFs the individual holds, and FCA approval is unified across the functions in a single submission.

Executive Director Recruitment →

Chief Risk Officer — SMF4

The CRO of an FCA-regulated firm holds SMF4 and is the senior individual accountable for the firm’s risk management framework, the second line of defence, and the relationship with the Board’s Risk Committee where applicable. The role gained materially in importance after the post-2008 risk function build-out across UK financial services, and the candidate pool has been tight for several years. Strong CRO candidates evaluate the firm’s risk environment carefully — the responsibilities map, the strength of the second-line team, the working relationship with the Risk Committee Chair — before accepting a role.

CRO Recruitment →

Chair of FCA-Regulated Firm — SMF9

The Chair of the Board of an FCA-regulated firm holds SMF9 and is the most senior independent voice in the firm, responsible for the effectiveness of the Board itself and acting 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. The candidate pool is small and tenure runs typically to two three-year terms — meaning succession planning works best on an 18-24 month horizon.

Chair of FCA-Regulated Firm Recruitment →

Senior Independent Director — SMF14

The Senior Independent Director on the Board of an FCA-regulated firm holds SMF14. The SID is the second most influential governance voice on the Board after the Chair: leading the Chair evaluation, providing an alternative channel for shareholders, regulators and other directors to raise concerns outside the Chair-CEO relationship, and stepping in when the Chair is conflicted or unavailable. The role is structurally distinct from a general senior NED appointment, and we treat SMF14 as a deliberate appointment for the SID role specifically — not as a senior NED search with a SID label attached.

Senior Independent Director Recruitment →

Head of Internal Audit — SMF5

The Head of Internal Audit at an FCA-regulated firm holds SMF5 and operates structurally in the third line of defence, reporting primarily to the Audit Committee Chair rather than to the executive line. The candidate pool is dominated by qualified accountants — ICAEW, ACCA, or one of the equivalents — with substantial in-house internal audit experience. As a Fellow of the ICAEW, our work in this area sits within an ICAEW-Registered Practice, and we have invested deliberately in our network of senior audit-qualified professionals.

Head of Internal Audit Recruitment →

How Exec Capital approaches FCA-regulated firm searches

Every senior appointment into a regulated firm — regardless of which SMF designation applies — is structured around three workstreams running in parallel.

The substantive search itself. The commercial brief, the role specification, the candidate market mapping, the engagement and shortlisting, the selection process and offer. This is what every executive search firm should do well — and we treat it as the foundation, not as a substitute for the work that follows.

The regulatory pathway. The Form A submission readiness, the fit-and-proper assessment preparation, the regulatory references workflow, the FCA approval timeline planning. We build this into the search from the brief rather than treating it as a back-end administrative step. Boards that have not factored eight to twelve weeks of FCA approval into their planning often end up with regulatory gaps, interim arrangements that drag, or compromises on the strongest candidate available.

The governance dimension. The Statement of Responsibility drafting, the alignment with the firm’s responsibilities map, the working relationships with the surrounding senior management team, the Board contribution expectations. For SMF1 and SMF9 in particular this is where strong candidates form their view of whether the firm is one where they can perform the role effectively — and where weak briefing makes the candidate withdraw at offer stage.

The three workstreams interact. A candidate identified through the substantive search who carries something material in their regulatory references needs the Form A submission planned around that. A Statement of Responsibility that has not been worked through with the firm before the search begins needs to be revisited when the candidate has questions. A timeline that did not include FCA approval needs to be reset when the offer is accepted. The work runs better when the three workstreams are integrated from day one.

Sectors and firm types we cover

Our FCA-regulated firm mandates span the full FCA-solo-regulated firm population. Different sectors have different shapes — the dominant risk categories, the typical Board composition, the operational profile, the supervisory engagement pattern — and our practice is shaped by direct exposure to each.

Asset management and wealth management firms represent the largest part of our practice — both Core and Enhanced firms across the AUM range. Investment management firms, multi-asset platforms, alternatives managers, hedge funds, private wealth managers, family office investment functions, discretionary fund managers, fund of funds, infrastructure and real estate investors. The senior team at these firms typically has the CIO and the COO on the Board as SMF3 holders alongside the CEO, with the CRO often holding SMF4 either on or below the Board depending on firm classification.

Insurance intermediaries and broker-dealers form a meaningful part of our practice — including general insurance brokers, specialty Lloyd’s market intermediaries, insurance-linked services, broker-dealer arms of larger groups, and specialty broker franchises. The Consumer Duty has reshaped expectations on conduct outcomes in the retail end of this market, and Operational Resilience has reshaped expectations on operational performance — both visible in the senior team specifications we run for these firms.

Fintechs and payment institutions are a growing share of our practice. We work with fintechs at and beyond authorisation, e-money institutions, payment service providers, BNPL specialists, and challenger payments businesses. The candidate profile differs meaningfully from traditional asset management — operational resilience and technology resilience credentials carry more weight, and the SMF24 role is often more technology-led than in established firms.

Consumer credit lenders and specialty consumer finance firms face particularly intense Consumer Duty scrutiny, and the senior team specifications we run for these firms reflect that — strong conduct risk credentials, customer outcomes monitoring experience, complaint handling effectiveness in the candidate’s prior roles. We work with bank lenders, non-bank specialty consumer credit firms, mortgage intermediaries, and motor finance lenders.

Specialised investment firms — including investment banking arms operating as FCA-regulated subsidiaries, infrastructure investment specialists, agency trading firms, market makers, and investment research and corporate broking firms — round out our practice. The senior team specifications here often emphasise specific market and product expertise alongside the regulatory dimension.

For dual-regulated firms — most commonly retail and challenger banks, building societies, and certain insurance firms regulated by both the FCA and the PRA — we incorporate the additional dimension of PRA individual accountability expectations alongside the FCA framework.

Engagement models

We work across three engagement models for FCA-regulated firm searches, with different patterns appropriate to different roles.

Permanent appointments are the most common across every SMF designation we recruit for. Senior executive roles (SMF1, SMF3, SMF4, SMF5, SMF24) and Board roles (SMF9, SMF14) typically run as permanent searches with the candidate’s first day in role at the end of the FCA approval window. We work on a retained basis for permanent SMF mandates and the engagement runs through to the candidate’s first day rather than ending at offer acceptance.

Interim appointments are common during transitions, turnarounds, or to bridge a gap between a departing SMF holder and a permanent successor. Interim engagements are full-time during the period but with a clear end date, and the candidate must still be FCA-approved as the SMF holder regardless of the engagement’s duration. We work on interim mandates across all the executive SMFs and on Chair appointments — though interim SID and interim Head of Internal Audit arrangements are less common because the role’s effectiveness depends on continuity.

Fractional appointments apply where the day-to-day demands of the role can be discharged on a defined number of days per week. Fractional SMF24 (COO) appointments are growing — particularly in fintechs and payment institutions where the firm size does not justify a full-time appointment but the SMF24 designation is required. Fractional SMF1 and SMF4 appointments occur in smaller Core firms and Limited Scope firms. Fractional Chair, fractional SID and fractional Head of Internal Audit are not features of the regulated firm market.

For all engagement models, the FCA approval process is unchanged. The candidate must be approved as the SMF holder regardless of how the engagement is structured, and the Statement of Responsibility must be in place from day one.

Knowledge centre — our SMF hiring guides

Alongside the recruitment service pages above, we maintain a set of detailed hiring guides covering each major SMF designation. The guides are written for boards, chairs and CEOs working through SMF appointments — setting out what each role substantively involves, how the FCA approval process operates, what the Statement of Responsibility looks like, how to think about the candidate pool, and what compensation and governance structures look like in practice.

Our SMF Roles guide provides the overview — including the firm classification framework (Core, Enhanced, Limited Scope), the grouping of SMF designations into executive, risk-and-oversight, and board-and-governance functions, and the cross-cluster picture for boards working across multiple SMF appointments simultaneously. The role-specific guides — SMF1 CEO, SMF3 Executive Director, SMF4 CRO, SMF5 Head of Internal Audit, SMF9 Chair, SMF14 SID and SMF24 Chief Operations Function — go into the depth required for boards making the appointment.

The guides are referenced from the corresponding service pages and are linked across the cluster for buyers in research mode. They are not a substitute for the conversation that anchors a real search — but they provide the orientation that lets boards approach a search with their thinking already worked through.

Working with Exec Capital

Exec Capital is an ICAEW-Registered Practice founded by Adrian Lawrence FCA, a Fellow of the Institute of Chartered Accountants in England and Wales. Adrian leads every senior mandate personally — there are no junior account managers or generalist consultants running regulated-firm searches at Exec Capital. The substantive work, the regulatory navigation, the candidate engagement and the post-offer support all run through Adrian directly.

We work on a retained basis for senior FCA-regulated firm mandates. The engagement structure depends on the role — SMF1, SMF9 and SMF14 are typically retained throughout; SMF3, SMF4, SMF5 and SMF24 are retained where the search is for a primary appointment and lighter where the work is closer to refreshing existing senior executives into formal SMF designation. For all engagement structures, the work runs through to the candidate’s first day in role rather than ending at offer acceptance.

For boards beginning their first regulated-firm search, refreshing how they have approached previous searches, or planning succession on a 12-24 month horizon, 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. There is no commitment from this conversation. Boards often use it to check their thinking before deciding whether to commission a search at all.

Further reading and authoritative sources

For the FCA’s authoritative guidance on the Senior Managers and Certification Regime, see the FCA’s SMCR overview and the solo-regulated firms guidance. The FCA’s Form A guidance sets out the application requirements for SMF appointments.

For the broader regulatory framework that affects SMF holders’ accountabilities, see the FCA Operational Resilience policy and the FCA’s Consumer Duty. Both have substantially reshaped what senior management roles in regulated firms entail since 2022. The Bank of England Supervisory Statement on individual accountability covers the dual-regulated firm context for firms that are both FCA and PRA regulated.

For corporate governance frameworks that complement the SMCR, see the UK Corporate Governance Code published by the Financial Reporting Council. The Institute of Directors publishes governance guidance particularly relevant to Board effectiveness, the Chair-CEO relationship, and the SID role. The ICAEW publishes guidance on financial reporting and audit committee work that is particularly relevant to SMF11 (Audit Committee Chair) and SMF5 (Head of Internal Audit) appointments.