FCA SMF Interviews: What to Expect and How to Prepare

An FCA interview is not a routine feature of every SMF approval application, but where the FCA has questions about a candidate’s competence, the circumstances of previous employment, or specific disclosures in the Form A, it may request an interview before determining the application. Understanding what these interviews involve and how to prepare can make a material difference to the outcome.

When Does the FCA Request an Interview?

The FCA does not interview every SMF candidate — for straightforward applications with clean employment histories, adequate qualifications and clear Statements of Responsibilities, the FCA will typically determine the application on the papers. Interviews are most commonly requested where: the FCA has specific questions about the individual’s experience or competence for the proposed function; the Form A contains disclosures — previous regulatory action, gaps in employment, financial difficulties — that the FCA wishes to explore further; the regulatory reference raises matters that require explanation; or the proposed SoR is unclear and the FCA wants to understand the individual’s proposed role more specifically.

Format and Conduct of FCA Interviews

FCA SMF interviews are typically conducted by telephone or video call, though in-person interviews do occur for more complex cases. The FCA will send an agenda in advance identifying the areas it wishes to discuss, which allows the individual to prepare targeted responses. Interviews typically last between 30 and 90 minutes and are conducted by one or two FCA supervisors. The firm’s compliance officer may attend alongside the candidate — this is standard practice and the FCA expects the compliance officer to be present unless the firm specifically asks otherwise.

What the FCA Assesses in the Interview

The interview serves as a supplement to the paper-based assessment, not a replacement for it. The FCA uses it to: verify that the individual genuinely understands the responsibilities described in their SoR; assess whether their experience and competence match the role at the specific firm; explore any matters raised in the Form A or regulatory reference; and form a view of the individual’s understanding of their personal accountability under SMCR and their approach to regulatory compliance. The FCA is assessing character and judgment as much as technical knowledge — it wants to understand how the individual approaches regulatory responsibility, not just whether they can recite the relevant rules.

Typical FCA Interview Questions

While every interview is tailored to the specific application, several themes recur consistently across SMF interviews. The FCA regularly asks: what do you understand your responsibilities to be in this role, and how would you go about discharging them? How would you satisfy yourself that the areas within your remit are compliant with FCA requirements? What would you do if you identified a significant regulatory breach within your area? How does your role interact with the compliance function and the board? What experience do you have of [specific regulatory framework relevant to the firm’s activities]? Candidates who have thought carefully about these questions before the interview — rather than relying on spontaneous responses — consistently perform better.

How to Prepare: The SoR and Role Understanding

The most important preparation step is a thorough review of the proposed Statement of Responsibilities. The individual must be able to explain, in their own words, what they are accountable for at the firm — not in the formal language of the SoR, but in practical terms that demonstrate genuine understanding. Any element of the SoR that the individual cannot explain clearly or connect to a specific aspect of the firm’s activities is a potential interview vulnerability that should be addressed before the interview.

How to Prepare: Regulatory Knowledge

For SMF16 (compliance officer), the FCA expects the interview candidate to demonstrate knowledge of the regulatory framework applicable to the firm’s specific activities. The preparation should focus on: the FCA rules most directly relevant to the firm’s business; the FCA’s current supervisory priorities in the relevant sector; and the specific compliance obligations the SMF16 holder will oversee. For SMF17 (MLRO), the equivalent preparation covers the AML framework — MLR 2017, POCA, the DAML process and the NCA’s reporting expectations.

How to Prepare: Handling Adverse Disclosures

Where the interview has been triggered by a specific Form A disclosure or regulatory reference finding, the candidate should prepare a clear, factual and proportionate explanation of the circumstances. The explanation should: acknowledge the relevant matter accurately; describe the context in which it arose; explain what the individual learned from it and what they did differently as a result; and confirm that the matter is fully resolved. Defensiveness, minimisation or implausible explanations are the most common ways candidates make adverse disclosures worse in an FCA interview. A factual, candid and forward-looking response is almost always more effective.

After the Interview

The FCA typically takes several weeks to determine an application following an interview. Where the interview has addressed the FCA’s queries adequately, determination follows in due course. Where further queries arise, the FCA will typically write to the firm. In the rare cases where the FCA is minded to refuse an application following an interview, it will issue a Warning Notice giving the firm and individual an opportunity to make representations before a final decision is made.

Key References

• FCA — Senior Managers Regime guidance
• FCA Handbook FIT — fit and proper sourcebook