The SMF16 Job Description Problem

Most of the compliance oversight briefs that reach our desk describe a job that does not exist at the firm advertising it. The document is usually recognisable: eight bullet points about leading a compliance function, two about managing a team, one about setting the compliance strategy, a line about “partnering with the business”, and a requirement for fifteen years of experience in a regulated environment. It reads well. It has been through HR. It is also, at a twelve-person brokerage with a single compliance administrator and an outsourced monitoring provider, a description of somebody else’s job.

This matters more than it sounds. A job description is the only document a candidate sees before deciding whether to engage, and it is the document the firm interviews against. When it describes a function three times the size of the real one, three things follow: the wrong people apply, the right people do not, and the firm spends six weeks interviewing before anyone says out loud that the role on the page is not the role in the building.

We have written this because it is the single most common reason an SMF16 search stalls, and because the fix costs nothing but an hour of honesty.

Why the copied job description is so tempting

Nobody sets out to mis-describe a role. The usual sequence is this. A firm decides it needs its own Compliance Oversight holder, often at the point described in our piece on when to hire your first in-house head of compliance. There is no internal template, because the firm has never hired one. So somebody finds a job description from a larger firm, or from a previous employer, or from a recruitment site, and edits the company name.

The source document is almost always from a bigger firm, because bigger firms publish more. And a Head of Compliance job description at a 400-person firm is genuinely a management role: it is mostly about running a team, owning a budget, and sitting on committees. At a twelve-person firm, the SMF16 does the work. They write the compliance monitoring plan and then execute it. They review the financial promotions themselves. They deal with the regulator directly rather than through a regulatory affairs function. The two jobs share a title and almost nothing else.

What the regulatory position actually requires

It is worth separating the regulatory minimum from the commercial wish list, because firms routinely conflate them.

The Compliance Oversight function exists because SYSC requires most firms to maintain a compliance function, and the SMF16 is the approved individual with responsibility for that function and for reporting to the governing body on it. That is the core. Everything else in the job description — the team leadership, the strategy, the transformation programme — is the firm’s own addition, and may be perfectly reasonable, but it is not what the FCA will hold the individual to. Our SMF16 compliance oversight function guide sets out the function in full.

The practical consequence is that the regulatory core of the role is small and precisely defined, while the commercial content varies enormously by firm. A job description that spends ninety per cent of its length on the commercial content and one line on the regulatory core has it backwards, because the regulatory core is what makes the hire non-negotiable and what makes the candidate pool narrow.

The five things a good SMF16 brief tells a candidate

A compliance oversight candidate at this level is assessing personal regulatory risk before they assess the salary. They are deciding whether, in two years, they will be the named individual explaining to a supervisor why something was missed. So they want to know five things, and a brief that answers them gets replies.

What the firm actually does, in detail. Not “financial services” — the permissions, the client types, the products, the distribution model, whether there is client money, whether there are appointed representatives. The regulatory burden of an advisory firm with 200 retail clients is nothing like that of a wholesale broker with twelve institutional counterparties, and candidates sort themselves by this faster than by anything else.

What the compliance function consists of today. Headcount, including fractions. What is outsourced and to whom. What systems exist. Whether there is a monitoring plan and whether it has been executed. Candidates are not frightened of a thin function; they are frightened of discovering it is thinner than they were told.

Who the role reports to, and who it can escalate to. A Compliance Oversight holder who reports to the Chief Executive and has a standing item at board meetings is in a different job from one who reports to the COO and attends on request. This is the single strongest signal of whether the role has real authority, and good candidates read it immediately.

What is already known to be wrong. An open supervisory matter, a past-due monitoring programme, a remediation exercise, a compliance monitoring report that has been sitting unactioned. Firms hide these, which is self-defeating: the candidate will find out at due diligence and the discovery converts a positive process into a negative one. Said upfront, the same facts read as a mandate.

Whether the role is the whole job. At smaller firms the SMF16 is frequently also expected to hold SMF17, or to cover operational risk, or to run the complaints function. If so, say it in the brief. The candidate pool for a combined role is different from the pool for a single function, and we cover why in the piece on combined SMF16 and SMF17 appointments.

Experience requirements that quietly exclude the right people

Two requirements appear in almost every brief we receive and do more damage than any other.

The first is a minimum number of years. Fifteen years in regulated financial services sounds prudent, and it excludes a large part of the population that is actually good at small-firm compliance oversight: people who have spent eight or ten years doing the work directly, often across several firms, and who are entirely capable of being approved. It also admits people whose fifteen years were spent inside a single large function doing one slice of the work, who have never written a monitoring plan from scratch and have never spoken to a supervisor without a team around them.

The second is prior SMF16 approval. It feels like risk reduction and it halves the pool. Approval is granted by the FCA on the basis of fitness and propriety and competence for the specific role at the specific firm; a candidate who has deputised for an SMF16, run a compliance function without holding the function, or held an equivalent role at a firm where the function sat elsewhere, may well be approvable. Firms that insist on prior approval end up competing for the same small group of people against everybody else with the same requirement. Our guide to the Form A application covers what the process actually assesses.

A better framing in both cases is to describe the work rather than the credential: “you will own and execute the monitoring programme” tells a candidate what is needed far more precisely than a number of years.

Salary bands that have not been checked

The third common defect is a band that was set from an internal grading structure rather than from the market. Compliance oversight at a small regulated firm is a scarce skill priced by scarcity, and it does not sit neatly against other roles of similar seniority elsewhere in the business. Where the band is wrong, the search does not fail loudly — it simply produces a long, slow stream of candidates who are not quite right, which is the most expensive failure mode because it consumes months before anyone concludes the problem is structural. Our compliance salary guide is a reasonable sanity check before the brief goes out.

What to do when the real role is smaller than the brief

Often the honest version of the role is genuinely part of a job rather than a whole one. A firm with modest volumes and a clean regulatory history may need two or three days a month of compliance oversight, plus availability. That is not a failure of ambition; it is the actual requirement, and there is a well-established market serving it. A fractional compliance officer holds the function on a retained basis, attends the board, owns the monitoring programme and is approved for the firm in the ordinary way.

Firms resist this because a part-time appointment feels less substantial. In practice the reverse is often true: a fractional holder with six comparable firms behind them has seen more supervisory correspondence, more authorisation variations and more remediation than a full-time hire who has only ever worked at one firm. What the firm gives up is availability on demand, which matters at some firms and not at others.

Rewriting the brief: a short exercise

Before a compliance oversight search goes to market, it is worth writing down the answers to six questions in plain prose, with no job-description language at all.

What will this person spend Monday morning doing? Who will they talk to in their first week? What is the first thing they will be asked to fix? What decision can they make without asking anyone? What decision can they stop? If they resigned in eighteen months, what would be the reason?

The answers are the job description. They are also, in our experience, materially different from the document that was about to be sent out, and the difference is usually that the real role is narrower, more hands-on and more dependent on the relationship with the board than the draft suggested. That is a more attractive role to the right candidate, not a less attractive one — but only if it is described.

Where this leaves a firm that is hiring now

If a compliance oversight search has been open for more than two months with no offer, the brief is the first place to look, ahead of the salary and well ahead of the candidate market. Firms with a clear, specific, slightly uncomfortable brief fill these roles. Firms with a polished generic one tend not to, and generally conclude that there is a shortage of candidates when what there is, is a shortage of candidates for a job that is not on offer.

We are happy to look at a draft before it goes out. It takes twenty minutes and it is the cheapest intervention available in an SMF16 recruitment process.

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