Hiring Into a Senior Manager Function: What the Approval Gate Changes
Executive search at an FCA-regulated firm runs to a different clock, and the single most common planning error is treating a senior manager appointment like any other hire. The offer is accepted, a start date goes in the diary, and then somebody discovers that the …
Can One Person Hold More Than One SMF? Combining Senior Manager Roles
At a smaller regulated firm, the question comes up almost immediately: does every Senior Management Function need its own person, or can one individual hold several? The answer is that combining functions is both common and legitimate — but it is not unlimited, and getting …
SMF4: The Chief Risk Officer Function and Why Independence Defines It
The Chief Risk Officer is the Senior Management Function the regulator relies on to be the independent check inside a firm. SMF4 — the chief risk function — is held by the individual with responsibility for the firm’s risk management framework, and the defining feature …
SMF3: What the Executive Director Function Means at a Regulated Firm
At an FCA-regulated firm, sitting on the board is not the same as holding a board title at an unregulated company. An executive director of an authorised firm ordinarily holds SMF3 — the executive director function under the Senior Managers and Certification Regime — a …
SMF20 and SMF23: The Insurance Senior Manager Functions Explained
The Senior Managers and Certification Regime applies to insurers as well as to FCA-regulated firms, but insurers have their own set of Senior Management Functions reflecting how the sector is governed. Two of the most specialist are SMF20, the Chief Actuary, and SMF23, the Chief …
SMF16 vs SMF17: When You Need One, Both, or a Combined Role
Two of the most frequently confused Senior Management Functions are SMF16 and SMF17. Both sit in the compliance and financial-crime space, both are required at most authorised firms, and at smaller firms they are often held by the same person. But they are distinct functions …
SMF1 Explained: What Changes When You Hire a CEO for a Regulated Firm
Hiring a chief executive is the most consequential appointment any business makes. At an FCA or PRA-regulated firm it is also a regulated one. The person you appoint does not simply take the title of CEO. They take on SMF1, the Chief Executive function under …
Hiring an SMF2-Approved CFO: What the Chief Finance Function Really Demands
When a bank, insurer or larger FCA-regulated firm hires a chief financial officer, it is doing more than appointing its most senior finance leader. It is appointing the holder of SMF2, the Chief Finance function under the Senior Managers and Certification Regime (SM&CR). That is …
Board Evaluation: When and How
Board evaluation has a poor reputation, and largely a deserved one. A questionnaire goes round in December, the results are presented in January, a paragraph in the annual report confirms that the board considers itself effective, and nothing changes. Done that way it is a …


