Hiring a Deputy CEO at an FCA-Regulated Firm
Hiring a Deputy CEO at a Regulated Firm: SMF3 vs SMF1 Succession Considerations The Deputy CEO role at an FCA-regulated firm sits at one of the most complex governance intersections in the SMCR framework. It is a role defined more by its succession purpose than …
CEO Succession at an FCA-Regulated Firm
CEO succession at an FCA-regulated firm is one of the most demanding governance challenges a board will manage. It combines the complexity of a senior executive search with the regulatory obligations of the Senior Managers Regime, the supervisory relationship dynamics of a significant change in …
Hiring a CEO Without Previous SMF Approval
The assumption that a CEO appointment at an FCA-regulated firm requires a candidate who has previously held an SMF designation is understandable but wrong. The FCA does not require candidates for senior management functions to have prior SMF experience — it requires them to be …
Senior Managers vs Certification Regime
The Senior Managers Regime and the Certification Regime are the two main parts of the Senior Managers and Certification Regime (SM&CR). They sit side by side, but they cover different people, run on different approval routes and put different obligations on the individual and the …
Consumer Duty: Implications for Board Composition and Senior Hiring Decisions
Consumer Duty is the most significant shift in the FCA’s regulatory philosophy in a generation. The move from rules-based compliance to an outcomes-focused standard — where firms must show that retail customers are consistently receiving good outcomes — has changed what is expected of boards …
Wealth Management Senior Recruitment: Consumer Duty’s Impact on the Board Brief
Wealth Management Senior Recruitment: Consumer Duty’s Impact on the Board Brief Consumer Duty has changed the hiring brief at wealth management firms in ways that many boards are still working through. The requirement to demonstrate good outcomes for retail clients — at every stage of …
Senior Board Appointments at Challenger Banks: SMCR, PRA Expectations and the Talent Pool
Senior appointments at challenger banks sit in one of the most demanding regulatory environments in UK financial services. The combination of FCA and PRA oversight — dual regulation — means that every senior management function appointment is subject to heightened scrutiny, and the personal accountability …
Chief Operating Officer (SMF24) Appointments at FCA-Regulated Firms
Chief Operating Officer (SMF24) Appointments at FCA-Regulated Firms The Chief Operating Officer role at an FCA-regulated firm has been transformed by a decade of regulatory development. Where the COO was once primarily an internal efficiency function, the designation of the role as SMF24 — the …
Head of Internal Audit (SMF5) Recruitment at FCA-Authorised Firms
The Head of Internal Audit is one of the most structurally complex appointments a regulated firm can make. Under SMCR, where the role is a designated senior management function — SMF5 — the individual carries personal regulatory accountability for the internal audit function. But the …
Hiring a Chief Risk Officer (SMF4) at an FCA-Regulated Firm
Hiring a Chief Risk Officer (SMF4) at an FCA-Regulated Firm Appointing a Chief Risk Officer at an FCA-regulated firm is one of the most consequential hiring decisions a board will make. Under the Senior Managers and Certification Regime, the CRO typically holds the SMF4 designation …


