Consumer Credit Compliance Recruitment — SMF16, SMF17 and compliance leadership for lenders, BNPL providers and point-of-sale finance firms

Consumer Credit Compliance Recruitment

Consumer credit has become one of the busiest corners of the UK compliance hiring market. On 15 July 2026 the FCA began regulating Deferred Payment Credit, the product most people know as Buy Now Pay Later, bringing a group of lenders inside the regulatory perimeter for the first time. Established lenders, meanwhile, are working through a maturing Consumer Duty, closer supervisory attention on creditworthiness and arrears handling, and a regulator that expects the individuals holding compliance and money laundering accountability to evidence what they do rather than simply describe it.

FD Capital recruits the compliance leaders those firms need: SMF16 Compliance Oversight holders, SMF17 Money Laundering Reporting Officers, combined SMF16/17 Heads of Compliance, and the senior compliance managers who sit beneath them. We work on interim, fractional and permanent bases for third-party consumer lenders, BNPL providers, point-of-sale and retail finance businesses, motor and asset finance lenders, and debt collection and debt purchase firms. Every consumer credit compliance search is led personally by Adrian Lawrence FCA.

This page explains why consumer credit firms are hiring compliance leadership now, which senior manager functions your firm actually needs, what separates a strong consumer credit compliance candidate from a generalist, and how to time the hire around an authorisation application. If you need someone in the seat this month, go straight to our contact page or call 020 3287 9501.

Why consumer credit firms are hiring compliance leadership now

Most of the consumer credit compliance mandates we see start with a specific trigger rather than a general wish to strengthen the team. Five triggers account for nearly all of them.

1. BNPL lenders moving from temporary permission to full authorisation

Lenders that were already offering Deferred Payment Credit and registered for the FCA’s temporary permissions regime can continue lending while their full authorisation applications are assessed. The FCA’s final rules for Deferred Payment Credit (PS26/1) set out the conduct standards those firms must meet. During the temporary regime a lender whose only regulated activity is Deferred Payment Credit sits outside the usual SM&CR firm classification. Full authorisation changes that: a third-party lender becomes a Core SM&CR firm, and the people it names as its compliance oversight and money laundering reporting senior managers have to be credible to the FCA at the point of application. For many BNPL firms this is the first time anyone in the business has held an approved role.

2. Consumer Duty moving from implementation to evidence

The Consumer Duty has been in force long enough that supervisors now expect outcome data, not policies. Boards must approve an annual assessment, and the SMF16 holder is usually the person expected to stand behind the evidence on price and value, consumer understanding, consumer support and products and services. Firms that implemented the Duty with consultants and never built the monitoring capability in-house are now hiring to close that gap. Our guide to how the Consumer Duty has reshaped the SMF16 role covers this in more depth.

3. Creditworthiness, forbearance and vulnerable customers

Supervisory work on consumer credit keeps returning to the same areas: the quality of affordability and creditworthiness assessments, the treatment of customers in arrears, and the identification and support of vulnerable customers. A lender whose compliance function cannot test these areas through file reviews and data will struggle when the FCA asks for evidence.

4. Growth across SM&CR thresholds

From 10 July 2026 the SM&CR Enhanced threshold for consumer credit firms rose to £130m of regulated consumer credit lending revenue, under the FCA’s SM&CR review policy statement (PS26/6). A lender growing towards that line needs to plan for additional senior manager functions, overall responsibilities and a fuller certification population, and that usually starts with a stronger Head of Compliance.

5. Departure of the current SMF16 or SMF17

The most urgent mandates are simply vacancies. When a Head of Compliance or MLRO resigns, the firm has to notify the FCA, reallocate prescribed responsibilities and arrange cover. The reformed 12-week rule now gives firms 12 weeks to submit an application for a replacement, with the cover individual able to continue until the FCA decides it. Our page on SMF16 and SMF17 temporary cover under the 12-week rule sets out the timetable.

Which senior manager functions does a consumer credit firm need?

The answer depends on the firm’s permission and size. The table below is a practical starting point; your own regulatory advisers should confirm the position for your firm.

Two points catch firms out. First, lending is one of the activities that brings a firm within the Money Laundering Regulations 2017, so most third-party lenders need a nominated officer and therefore an SMF17. Second, at a smaller Core firm the SMF16 and SMF17 roles are frequently combined in one individual. That is acceptable where the person has the capacity and the expertise for both, but the FCA will look hard at whether one person can genuinely cover compliance monitoring, Consumer Duty evidence, financial promotions and financial crime in a high-volume lending business. For a fuller treatment, see our guide to SM&CR for Limited Scope firms and the FCA’s SM&CR hub.

The consumer credit compliance roles we recruit

• Head of Compliance / Compliance Director (SMF16): the senior manager accountable for the compliance function, the compliance monitoring plan and the firm’s regulatory relationship.
• Money Laundering Reporting Officer (SMF17): the nominated officer for suspicious activity reporting, owner of the firm-wide risk assessment and the financial crime framework.
• Combined Head of Compliance and MLRO (SMF16/17): the most common shape at smaller lenders and newly authorised BNPL firms.
• Deputy MLRO: increasingly expected at volume lenders so that suspicious activity reporting does not stop when the MLRO is unavailable.
• Senior Compliance Manager: the delivery lead beneath the SMF16, often running monitoring, regulatory change and FCA correspondence.
• Consumer Duty Lead: owner of outcome monitoring, fair value assessments and the annual board report.
• Compliance Monitoring and Quality Assurance Manager: file reviews across lending decisions, collections and complaints.
• Financial Promotions Manager: sign-off of advertising, affiliate and social media content under CONC 3.
• Complaints and Financial Ombudsman Lead: root cause analysis and the link between complaints data and Consumer Duty outcomes.
• Collections and Arrears Conduct Manager: forbearance, vulnerable customer treatment and third-party collection agency oversight.

Where the need is broader than consumer credit, our compliance recruitment, MLRO recruitment and Consumer Duty recruitment pages cover the wider market.

What a strong consumer credit compliance candidate looks like

A generalist financial services compliance professional is not the same thing as a consumer credit compliance leader. The best candidates for these roles share a recognisable profile.

Working fluency in CONC. They know the Consumer Credit sourcebook in practice, not just by reference: creditworthiness under CONC 5, arrears, default and forbearance under CONC 7, financial promotions under CONC 3, and the new Deferred Payment Credit provisions where relevant. Ask them how CONC and the Consumer Duty interact and listen for a clear answer; our article on how the two regimes interact gives a sense of what good looks like.

Comfort with data and automated decisioning. Consumer lending is a high-volume, model-driven business. A credible SMF16 can interrogate decisioning rules, understand acceptance and arrears MI, and design monitoring that samples the right files. In BNPL, where transaction values are low and volumes very high, this matters even more.

Collections and vulnerability experience. Many of the most serious consumer credit failings have arisen in collections. Candidates who have overseen debt collection under CONC, forbearance strategies and vulnerable customer treatment bring direct value.

Financial crime in a lending context. For an SMF17, the threats in consumer lending are different from those in a bank or wealth manager. First-party fraud, synthetic identities, application fraud and money mule activity sit alongside traditional money laundering risk. A good lending MLRO knows how fraud and AML controls meet and how to tune them without strangling conversion.

A track record with the regulator. Prior experience of an authorisation, a section 166 review, a voluntary requirement or a supervisory visit is a strong signal. So is having held, or deputised for, an approved role before. First-time SMF candidates can succeed, but the FCA will probe them harder at interview, so the rest of the senior team needs to compensate.

Commercial judgement. Lenders are growth businesses. The strongest compliance leaders are those a CEO trusts in product meetings because they find compliant ways to launch, rather than simply blocking. In merchant-facing BNPL, that includes oversight of merchant partners and their promotions.

Hiring compliance leadership for a BNPL authorisation

For BNPL lenders moving from temporary permission to full authorisation, the order of work matters. A firm that applies first and recruits later tends to face more questions from the FCA, not fewer.

1. Decide the structure. One combined SMF16/17 or two individuals? In-house, fractional or interim to start? This depends on volumes, product complexity and the size of the compliance team underneath.
2. Identify the individuals before submission. The authorisation application names the firm’s senior managers, and their Form A applications are assessed alongside it. Our guide to SMF appointments during FCA authorisation explains how the two processes run together, and the Form A guide covers the application itself.
3. Complete fit and proper work early. Under PS26/6, regulatory references must now be provided within four weeks rather than six, and criminal records checks for a new SMF remain valid for six months. Build both into the timetable. Our fit and proper guide sets out what the FCA assesses.
4. Prepare for interview. The FCA may interview SMF16 and SMF17 candidates, particularly first-time holders at a newly regulated firm. See FCA SMF interviews: what to expect.
5. Bridge with interim support if needed. An experienced interim Head of Compliance can build the compliance monitoring plan, financial crime framework and Consumer Duty MI while the permanent hire works notice.

The FCA authorisation timeline guide shows where these steps sit in the overall process.

Interim, fractional or permanent?

Indicative pay and day rates

Pay varies with firm size, location, lending volumes and whether the SMF16 and SMF17 roles are combined. The ranges below are indicative of the London and South East market for consumer credit firms; our compliance salary guide and MLRO salary guide carry fuller benchmarks.

How FD Capital runs a consumer credit compliance search

A precise brief. We start with your permission profile, SM&CR category, products, volumes and the state of your compliance monitoring, financial crime framework and Consumer Duty MI. That tells us whether you need a builder, a fixer or a steady pair of hands.

Speed on interim and fractional roles. For interim and fractional mandates we aim to put a shortlist in front of you within 48 to 72 hours, because in our experience that is the window in which good interim candidates are still available.

Depth on permanent roles. Permanent SMF searches run to a different clock. Notice periods and a smaller pool mean that getting the brief and the fit right matters more than raw speed, and we take the time to test regulatory track record properly.

Approval-ready candidates. We check SMF history on the FCA Financial Services Register, probe for regulatory reference issues early, and prepare candidates for the questions the FCA is likely to ask about their experience of CONC, the Consumer Duty and financial crime.

Live roles. Current consumer credit and wider compliance vacancies are listed on our jobs board. Compliance professionals looking for their next role can register with us.

Frequently asked questions

Does a BNPL lender need an SMF16 and an SMF17?

Once fully authorised as a third-party lender, a BNPL provider is ordinarily a Core SM&CR firm and needs both functions, which may be held by one person. During the temporary permissions regime the position is different, but the individuals should be identified well before the full application is submitted.

Can our SMF16 and SMF17 be the same person?

Yes, and at smaller lenders it is common. The FCA will expect the individual to have the time and expertise for both, and you should have a deputy MLRO or equivalent arrangement so that suspicious activity reporting continues when they are absent.

Can a fractional Head of Compliance hold the SMF16 role?

Yes, provided the time commitment is genuinely sufficient for your business and the arrangement is documented. A fractional SMF16 working one or two days a week can suit a smaller lender; a high-volume BNPL book will usually need more.

How long does FCA approval of a new SMF16 take?

The statutory deadline is three months from a complete application, and the FCA reports that the large majority of applications are decided within that period. See our guide on how long SMF approval takes.

Should we hire from a bank or from a specialist lender?

For most consumer credit firms, a candidate from a specialist lender, BNPL provider or credit card issuer will be stronger than one from a retail bank, because they will know CONC and collections in depth. Bank candidates can work well at larger lenders, particularly where governance structures are more complex.

Do you recruit compliance for firms outside consumer credit?

Yes. We also recruit compliance leadership for payments and e-money firms, wealth managers and IFAs, insurers and intermediaries and cryptoasset firms.