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Finance Directors and Chief Financial Officers are our speciality we are a London based recruitment service that specialises in Part-Time and Full Time senior financial professionals. Our podcast episodes discuss topics that are of interest to employers and prospective FD's and CFO's alike.

  1. 5d ago

    SMF16 and SMF17 Temporary Cover: Understanding the 12-Week Rule

    Today we are looking at an issue that can create an immediate problem for regulated financial services businesses: what happens when an SMF16 Compliance Oversight or SMF17 Money Laundering Reporting Officer becomes unavailable? A senior compliance professional may resign, take extended leave, become temporarily unable to perform their role, or leave the business unexpectedly. The firm still has to operate, customers still need to be protected, financial crime risks still need to be managed and regulatory obligations do not stop simply because a key individual has left. This is where temporary SMF cover can become extremely important. To find out more about FD Capital's specialist service, visit: https://www.fdcapital.co.uk/smf16-smf17-temporary-cover-12-week-rule/ What is the 12-week rule? The FCA's rules provide a mechanism that can allow a firm to arrange temporary cover when an individual performing a senior management function is unexpectedly absent. This is commonly referred to as the 12-week rule. The purpose is to give a firm time to manage an unexpected absence without leaving an important senior management responsibility unattended while a longer-term solution is put in place. However, firms should not treat the 12-week rule as a way of avoiding the normal approval requirements for SMF appointments. The rules have specific conditions and limitations, and firms need to establish whether their particular circumstances qualify. The person providing temporary cover must also be capable of performing the responsibilities being allocated to them. That is why specialist interim recruitment can be valuable when an SMF16 or SMF17 suddenly becomes vacant. Why an SMF vacancy needs a rapid response A compliance vacancy is different from many ordinary recruitment situations. The business continues operating while the vacancy exists. Compliance monitoring continues, regulatory developments continue and financial crime risks remain. The board therefore needs to establish quickly who is responsible for the relevant function. Can an existing senior manager provide appropriate cover? Does the current compliance team have sufficient experience and capacity? Is an interim specialist required? And how quickly can a suitable permanent replacement be found? These decisions become particularly important where the firm is highly regulated, undergoing rapid growth or dealing with regulatory change. Leaving responsibilities unclear while a permanent recruitment process takes place can create unnecessary risk. Temporary SMF16 cover SMF16 is the Compliance Oversight function. Depending on the nature of the firm, the role can involve oversight of compliance monitoring, regulatory change, conduct risk, Consumer Duty, financial promotions and the escalation of significant compliance issues. If the existing SMF16 leaves unexpectedly, an interim professional can provide continuity while the business recruits permanently. The interim SMF16 needs to understand the firm's regulatory framework quickly and identify the areas requiring immediate attention. They may need to review outstanding compliance monitoring actions, audit findings, regulatory developments, risk registers and issues previously escalated to senior management. The objective is not simply to put a name against the position. The temporary individual

  2. 5d ago

    Consumer Credit Compliance Recruitment: SMF16, SMF17 and Compliance Leadership for Lenders and BNPL Providers

    Welcome to the FD Capital podcast. Today, we’re discussing consumer credit compliance recruitment and why the right compliance leaders matter for lenders, Buy Now Pay Later (BNPL) providers, point-of-sale finance firms and growing fintech businesses. Find out more about FD Capital’s service: https://www.fdcapital.co.uk/consumer-credit-compliance-recruitment-smf16-smf17-and-compliance-leadership-for-lenders-bnpl-providers-and-point-of-sale-finance-firms/ Why specialist compliance recruitment matters Consumer lenders need to develop products, reach customers and make lending decisions efficiently while maintaining appropriate governance and controls. As a business grows, its responsibilities become more complex: products change, transaction volumes rise, distribution partners multiply and customer needs evolve. An effective compliance leader turns regulatory requirements into practical processes. That means monitoring whether policies work, identifying weaknesses, reporting risks to senior management and supporting a culture in which customers are treated fairly. Recruiting someone with relevant experience is important. A candidate who understands the rules but has little experience of the firm's type of lending may need considerable support. Someone who has worked in a comparable lender or BNPL business may be better placed to recognise risks and address them. BNPL and the changing regulatory environment Buy Now Pay Later has become an important part of online retail and point-of-sale finance. The model gives customers another way to spread payments, but providers must consider

  3. 5d ago

    Payments and E-Money Compliance Recruitment: Finding the Right Compliance Leaders for a Changing Regulatory Environment

    Welcome to the FD Capital podcast, where we explore finance leadership, financial services recruitment, regulatory change and the people who help businesses grow while managing risk effectively. Today, we are looking at an increasingly important area of financial services: payments and e-money compliance recruitment. We will discuss why payment institutions and electronic money institutions need experienced compliance leadership, the challenges facing firms under the FCA's regulatory framework, and how to find the right Head of Compliance, Money Laundering Reporting Officer or Head of Safeguarding. We will also explore the differences between permanent, interim and fractional compliance appointments, and why recruitment decisions made during authorisation or a period of rapid growth can have a lasting impact on a business. If you operate a payment institution, an electronic money institution, a card programme, an open banking business or an embedded payments platform, this episode should be particularly relevant. Why payments compliance has become a board-level priority The payments industry has evolved considerably. New technology, faster transactions, embedded finance and the expansion of digital payment services have created opportunities for innovative businesses. However, these developments have also increased the importance of effective compliance, financial crime prevention and safeguarding. Payment firms must demonstrate that they understand their regulatory obligations and have appropriate people, systems and controls in place. It is not sufficient to have a policy document sitting on a shared drive. Compliance arrangements must work in practice, reflect the firm's business model and remain effective as transaction volumes increase. For founders and boards, this creates a significant leadership challenge. They need compliance professionals who understand the regulatory framework but can also work alongside commercial teams, product developers, operations and finance. The right individual must be able to identify risk, challenge decisions where necessary and help the business develop a proportionate control environment. They must understand that a growing payments business needs commercial momentum, but that growth cannot come at the expense of customer protection, financial crime controls or regulatory obligations. This is one reason experienced payments compliance professionals are so valuable. Finding somebody with the right combination of technical knowledge, practical experience and judgement is not always straightforward. The impact of the strengthened safeguarding regime Safeguarding is a particularly important issue for payment institutions and electronic money institutions. The FCA's strengthened safeguarding regime took effect on 7 May 2026, bringing additional requirements for relevant firms. These include daily safeguarding reconciliations on business days, monthly safeguarding returns, annual safeguarding audits subject to applicable exemptions, and a resolution pack documenting where relevant funds are held and how they are managed. For firms, these requirements reinforce the importance of clearly defined ownership, reliable information and effective oversight. Safeguarding is not simply an accounting exercise. It requires coordination between finance, operations, compliance and senior management. Reconciliations need to be performed appropriately, discrepancies investigated, records maintained and weaknesses escalated. This is creating a stronger case for dedicated safeguarding expertise in firms where the scale, complexity or risk profile justifies it. Some businesses may need a Head of Safeguarding with responsibility for the overall framework. Others may need a compliance leader who understands safeguarding in sufficient depth to oversee the arrangements, challenge weaknesses and work effectively with the finance function. When recruiting for these positions, employers should look beyond job titles. They should ask candidates to explain how they have managed safeguarding processes, prepared for audits, resolved reconciliation problems and improved controls following a review. Practical experience matters. A candidate who has worked through a safeguarding remediation exercise may bring valuable insight that is difficult to assess from a CV alone. Finding the right Head of Compliance and MLRO Two of the most important appointments for a payments business are the Head of Compliance and the Money Laundering Reporting Officer, commonly known as the MLRO. At smaller and early-stage firms, these responsibilities are often combined in one position. That can be a sensible arrangement, provided the individual has sufficient seniority, expertise, time and support to discharge both responsibilities effectively. As the business expands, the workload can become more demanding. Transaction volumes increase, new products are introduced, additional partners are appointed and financial crime risks evolve. A structure that worked for a small start-up may no longer be appropriate for a larger, more complex organisation. An effective Head of Compliance should understand the relevant regulatory requirements, oversee compliance monitoring and maintain an appropriate relationship with the regulator. The role also requires the ability to communicate clearly with the board and translate regulatory expectations into practical actions. The MLRO has a distinct focus on the firm's anti-money laundering arrangements, suspicious activity reporting and wider financial crime framework. The individual needs to understand the firm's risk assessment, customer due diligence, transaction monitoring and escalation procedures. For payments firms, financial crime expertise should extend beyond traditional money laundering risks. Fraud, sanctions exposure, money mule activity and the misuse of payment services all require careful consideration. Employers should also assess whether candidates have experience relevant to their particular operating model. A professional who has worked at a traditional bank may have strong technical knowledge, but experience at a payment institution, EMI or card programme manager may be more directly applicable to a fast-moving payments business. The objective is not simply to recruit somebody who knows the rules. It is to find somebody who can apply them effectively within the organisation. Understanding the difference between payments regulation and SM&CR Another important recruitment consideration is the regulatory structure under which the business operates. Payment institutions and electronic money institutions authorised solely under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011 generally sit outside the Senior Managers and Certification Regime. Their compliance and MLRO arrangements therefore do not automatically map onto the SMF16 and SMF17 designations used by firms within SM&CR. However, where a payments business or its group also operates an entity with relevant FSMA permissions, the position can become more complicated. For example, a group might combine an EMI with a lending business or an investment-related entity. In these circumstances, the responsibilities and approval requirements applicable to each legal entity need to be considered carefully. This matters when recruiting because candidates must understand the actual regulatory responsibilities attached to the role, rather than relying on familiar job titles. Someone who has operated successfully as an SMF16 or SMF17 in an investment firm may bring valuable governance experience, but they still need to demonstrate an understanding of the payments environment. Equally, a payments compliance specialist may need additional experience if the role includes responsibilities within an SM&CR-regulated entity. A good recruitment process examines these differences at the outset, helping the employer identify the experience genuinely required for the appointment. Financial crime, fraud and operational expertise Financial crime controls are another major consideration for payment institutions. A strong compliance or MLRO candidate should be able to discuss how customer risk assessments are developed, how transaction monitoring is calibrated, how sanctions screening operates and how suspicious activity is escalated. They should also understand the practical challenges of operating these controls at scale. For example, a monitoring system that generates excessive false positives can overwhelm an investigations team and make it harder to identify genuine concerns. Conversely, poorly designed controls can fail to identify suspicious activity that should have been investigated. The challenge is to build a system that is proportionate to the firm's risks while remaining effective as its customer base, products and transaction volumes change. Experience working with technology teams can therefore be particularly valuable. Compliance professionals increasingly need to understand data, systems and operational workflows, and to explain the controls required in a way that product managers and engineers can implement. Partner oversight is equally important. Embedded payments, banking-as-a-service arrangements and card programmes may involve agents, distributors, sponsor banks and other third parties. The compliance function needs to understand these relationships, establish appropriate oversight and ensure that responsibilities are clear. When interviewing candidates, employers should ask for specific examples of controls they have designed, weaknesses they have identified and improvements they have implemented. This provides a more

  4. Oct 11

    FD Capital Announces the Launch of SMF Capital

    Today we're announcing the launch of something new from the FD Capital group: SMF Capital, a specialist recruitment practice dedicated to Senior Manager Function appointments within UK financial services. The new business is now live at www.smfcapital.co.uk. So why have we launched SMF Capital, and what does it offer regulated firms? Why SMF Capital? Since FD Capital was founded in 2018, we've specialised in recruiting Finance Directors, CFOs and senior finance professionals, including fractional and interim appointments. As that business has grown, we've increasingly worked with FCA-regulated firms where the senior appointment carries an additional dimension: regulatory accountability. A CFO may be an SMF2. A senior compliance professional may hold SMF16 or SMF17. A Chief Risk Officer may be an SMF4. A Chair or other board-level appointment may also carry an SMF designation. These aren't ordinary executive appointments. The individual may need regulatory approval before taking up the function, and the firm needs to be satisfied that the candidate is fit and proper for the responsibilities involved. We therefore decided that SMF recruitment deserved its own specialist practice. What Does SMF Capital Do? SMF Capital recruits Senior Manager Function holders for FCA and PRA-regulated firms. The practice covers executive and non-executive appointments, permanent, interim and fractional recruitment. It works with a wide range of regulated businesses, including wealth and investment managers, consumer credit firms, insurers and intermediaries, banks and building societies, payments and fintech businesses, and overseas firms establishing UK operations. The focus is not simply on finding somebody with an impressive CV. The recruitment process is built around the question: Is this person genuinely suitable for the specific regulatory responsibility they are being asked to take on? That means considering their previous experience, sector knowledge, leadership capability and readiness for personal regulatory accountability. The Regulator's Test Starts at the Beginning One of the ideas behind SMF Capital is that the regulator's fit and proper assessment shouldn't be treated as something that happens at the very end of recruitment. It should influence the search from the beginning. For example, a candidate might have extensive compliance experience but very limited experience in the particular type of regulated business they are being asked to oversee. Another candidate might have excellent technical credentials but insufficient seniority or experience of exercising the judgement required by the role. A conventional recruitment process can miss these distinctions. SMF Capital aims to identify them early. Every search is led personally by Adrian Lawrence FCA, rather than being handed to a junior consultant part way through the process. Permanent, Interim and Fractional SMFs Not every regulated business needs a full-time senior manager. A smaller firm might require an experienced compliance professional or MLRO for only part of the working week. Another business may need an interim senior manager following an unexpected departure. A newly authorised firm may need senior leadership in place while it develops its permanent structure. SMF Capital therefore covers permanent, interim and fractional appointments. The important point is that a fractional or interim arrangement still needs to provide the individual with sufficient time, authority and resources to perform their responsibilities effectively. SMF Authorisation Support SMF Capital also helps firms preparing for FCA authorisation. For a new regulated business, recruiting the right senior managers can be one of the most important parts of building the organisation. The people named in an application need to be capable of performing the responsibilities assigned to them. SMF Capital can help firms identify appropriate candidates and build the recruitment process around the regulatory timetable. This can be particularly valuable for fintechs, investment businesses and other firms building their management team from scratch. Governance and SMF Structure The business also provides support with governance and SMF structures. As a regulated firm grows, its responsibilities can change. A business may become more complex, move into a different regulatory category, introduce new activities or restructure its senior management team. At that point, it is worth asking whether the firm's SMF structure still reflects how the business actually operates. Who is responsible for each area? Are responsibilities clearly allocated? Does the firm's documentation accurately reflect reality? And do the people holding those responsibilities have sufficient experience and capacity? These questions are at the heart of effective senior management governance. Who Is Behind SMF Capital? SMF Capital was founded by Adrian Lawrence FCA, who also founded FD Capital. Adrian is a Fellow of the ICAEW, holds an ICAEW practising certificate and is a former listed-company Finance Director with more than 25 years' experience as a Chartered Accountant and finance leader. FD Capital remains focused on Finance Directors and CFOs, while the wider specialist network includes Exec Capital, NED Capital and Accountancy Capital. SMF Capital is the latest addition, concentrating specifically on Senior Manager Function appointments. This specialist structure means that if a client needs an SMF2 CFO, a senior compliance appointment, a board appointment or another regulated senior role, the requirement can be directed to the most appropriate specialist practice. Why Is This Important for FD Capital? For FD Capital, the launch of SMF Capital is a natural extension of the business. Finance leadership and regulatory leadership increasingly overlap. A regulated firm may need a CFO who understands both finance and the responsibilities associated with SMF2. A growing business may need a fractional compliance officer alongside its finance leadership. A board restructuring may involve several senior appointments at the same time. Rather than treating these as generic executive recruitment assignments, the new network provides specialist expertise across the different areas. A New Resource for the SM&CR SMF Capital isn't just a recruitment business. The website also includes a Knowledge Centre, covering subjects such as the fit and proper test, regulatory references, firm tiers, the Conduct Rules, the 12-week rule and the practical mechanics of SMF appointments. There's also SMF Unlocked, a dedicated podcast exploring the Senior Managers Regime and the practical issues faced by firms and senior managers. The aim is to make SMF Capital a useful resource for boards, compliance teams, HR professionals, candidates and businesses preparing for authorisation. Who Should Visit SMF Capital? If you're a regulated firm recruiting a Senior Manager, the website is designed for you. If you're preparing an FCA authorisation application and need to build a senior management team, it's relevant to you. If you're looking for interim or fractional compliance, risk or other SMF support, it's also relevant. And if you're already an experienced Senior Manager considering your next appointment, SMF Capital provides a confidential way to register with a specialist recruiter. Many of the senior appointments handled by specialist recruiters are never publicly advertised. Visit SMF Capital So, if you work in UK financial services and have a Senior Manager Function recruitment requirement, visit: www.smfcapital.co.uk You'll find information about the different SMFs, recruitment services, interim and fractional appointments, authorisation support, governance reviews and current opportunities. And if you're not sure whether your requirement is actually an SMF appointment, you can contact the team and discuss it. Final Thoughts The launch of SMF Capital reflects something we've seen repeatedly through FD Capital's work with regulated businesses. A Senior Manager appointment isn't simply another senior recruitment assignment. The individual may carry personal regulatory accountability for a defined area of the business, and the firm needs confidence that the person appointed is genuinely capable of carrying that responsibility. That means the regulatory dimension needs to be considered from the beginning of the recruitment process. That's why we've created SMF Capital. It's a specialist practice focused on Senior Manager Function recruitment for regulated firms, covering permanent, interim and fractional appointments as well as authorisation and governance support. So, from everyone at FD Capital, we're delighted to announce the launch of SMF Capital. Visit www.smfcapital.co.uk to find out more. Thank you for listening to the FD Capital Podcast.

  5. Oct 11

    Fractional Compliance Officers: The Smarter Way to Build FCA Compliance Leadership

    Welcome to the FD Capital Podcast, where we explore finance leadership, fractional executives and the changing needs of businesses across the UK. Today we're looking at an increasingly important option for FCA-regulated firms: fractional compliance officers. Every regulated business needs effective compliance leadership. But does every firm really need a full-time Head of Compliance or Chief Compliance Officer? That's the thinking behind fractional compliance. What Is a Fractional Compliance Officer? A fractional compliance officer is an experienced compliance professional who works for a firm on a part-time, ongoing basis. Why Is the Model Becoming More Attractive? There are several reasons. The first is cost. A small regulated firm may need the expertise of a senior compliance professional but may not have enough work to justify a six-figure full-time appointment. The second is access to experience. A fractional professional may have previously held senior compliance or MLRO positions across several regulated businesses. A smaller firm can therefore gain access to experience that would otherwise be difficult to recruit on a full-time basis. The third is flexibility. A business might initially require one day a week. As it grows, adds permissions, launches products or becomes more complex, the commitment can increase. Fractional, Outsourced and Interim Are Not the Same These terms are sometimes used interchangeably, but they can describe quite different arrangements. Fractional generally means a named senior individual working for the firm on an ongoing part-time basis. Outsourced compliance usually means the firm engages an external consultancy to provide compliance services, potentially using several members of its team. Interim normally means an experienced individual comes into the business for a defined period, often to cover a vacancy, remediation programme or transition. The distinction matters particularly where an SMF is involved. An SMF is a function performed by an individual. The firm needs to understand exactly who is responsible, what authority they have and whether they have sufficient time and resources to perform the role properly. SMF16 and SMF17 Two particularly relevant functions are SMF16 Compliance Oversight and SMF17 Money Laundering Reporting. For smaller firms, it may be possible for one appropriately qualified individual to perform both functions, depending on the firm's circumstances. This can make a fractional model particularly attractive. The individual needs sufficient time and support to carry out the responsibilities effectively. How Many Days a Week Do You Need? There is no universal answer. A small directly authorised IFA with relatively straightforward activities might require considerably less senior compliance time than a rapidly growing payments or investment business. A boutique investment manager might need one or two days each week. A newly authorised lender or payments business may need substantially more support while its systems and controls mature. A firm that has suddenly lost its Head of Compliance might also use a fractional professional as a bridge while recruiting a permanent replacement. The important question is not: "How cheaply can we cover compliance?" It is: "How much senior compliance resource does our business genuinely require?" That is a much better starting point. The exact responsibilities should be clearly defined in the firm's governance arrangements and, where applicable, the individual's Statement of Responsibilities. The Importance of Sector Experience One of the biggest mistakes a regulated business can make is assuming that any experienced compliance professional will automatically be suitable. Compliance is highly sector-specific. An SMF16 working for an IFA needs to understand the regulatory environment around financial advice, suitability and the firm's particular business model. A compliance leader for a payments firm needs different experience. An investment manager will have different requirements again. The best fractional appointment is therefore usually someone who has already worked in a business with a similar regulatory profile. That allows them to contribute quickly rather than spending months learning the firm's sector from scratch. What Makes a Good Fractional Compliance Leader? There are several characteristics to look for. Relevant SMF experience is highly valuable, particularly where the individual will be expected to hold an SMF16 or SMF17 function. Sector experience is equally important. A candidate should understand the regulatory environment in which the firm actually operates. Board presence matters too. A fractional compliance officer may only be in the business one day a week, but they still need the confidence to challenge directors when necessary. Efficiency is essential. Someone working fractionally has limited time and needs to prioritise the highest-risk issues. And finally, capacity and conflicts need to be considered. Many fractional compliance professionals work with several firms. That can be a strength because they bring broad experience, but the firm needs confidence that the individual has enough capacity to perform its particular role effectively. The Financial Case The economics can be compelling. A firm might pay a senior fractional compliance professional a day rate for one or two days a week rather than employing a full-time executive with salary, pension, employer National Insurance, bonus and other employment costs. FD Capital's current fractional compliance recruitment market includes senior professionals working at approximately £600–£1,100 per day depending on seniority, sector and complexity. Actual rates vary significantly by individual and requirement. That means a smaller regulated business can potentially obtain senior compliance expertise for a fraction of the cost of a full-time appointment. But the financial calculation should always come second to determining what level of compliance resource the firm actually needs. When Should a Firm Consider Going Full-Time? Fractional compliance isn't necessarily the end state. As a business grows, there may come a point where a full-time Head of Compliance or Chief Compliance Officer makes more sense. Potential triggers include: rapidly increasing customer numbers;additional regulatory permissions;new products or business lines;increased financial crime exposure;growing compliance monitoring requirements;increased FCA engagement;a move towards greater organisational complexity;or simply the point where the fractional professional is consistently working beyond the agreed commitment.The fractional model can therefore act as a bridge between having too little senior compliance resource and building a full-time compliance function. How FD Capital Helps FD Capital brings the fractional model that has traditionally been associated with Finance Directors and CFOs into the wider regulated business environment. We recruit fractional Heads of Compliance, Compliance Officers, MLROs and senior compliance professionals for FCA-regulated businesses. Our approach starts with understanding the firm's regulatory perimeter, permissions, activities, size, risk profile and the support already available internally. We then identify candidates with the relevant sector and regulatory experience rather than simply searching for anyone with "compliance" on their CV. For fractional appointments, FD Capital says it aims to provide a shortlist within 48 to 72 hours of receiving a full brief, with the subsequent appointment and regulatory approval process depending on the individual and circumstances. Fractional compliance can provide a more flexible alternative. Find Out More If your business needs senior compliance expertise but isn't ready for a full-time appointment, FD Capital can help you explore the fractional model. We've created a dedicated guide covering fractional compliance officer recruitment, including SMF16, SMF17, the difference between fractional and outsourced compliance, typical time commitments and the recruitment process. You can read it here: Fractional Compliance Officer Recruitment If you're considering recruiting a fractional Head of Compliance, SMF16, MLRO or combined compliance and financial crime leader, the team at FD Capital can discuss your requirements and the level of support your firm actually needs. For many smaller FCA-regulated firms, that could be a highly practical and commercially sensible model. If your firm needs senior compliance expertise without immediately committing to a full-time appointment, take a look at FD Capital's Fractional Compliance Officer Recruitment service. Thank you for listening to the FD Capital Podcast. Join us next time as we explore another issue affecting finance, compliance and senior leadership in UK businesses.

  6. Jun 5

    Podcast Episode: Consumer Duty in 2026 – From Compliance Project to Business Reality

    Welcome back to The Regulatory Leadership Podcast. Today we're tackling one of the most significant regulatory developments to impact UK financial services in recent years: Consumer Duty. If you're a Chief Compliance Officer, Risk Director, Board Member, Head of Compliance, or anyone involved in FCA-regulated businesses, you'll know that Consumer Duty is no longer an implementation project. It's now a permanent part of how firms are expected to operate. The challenge facing many organisations today isn't understanding what Consumer Duty is. The challenge is proving that it's working. In this episode we'll explore: Why Consumer Duty changed the regulatory landscapeThe four customer outcomes firms must deliverCommon implementation mistakesWhat the FCA is focusing on nowWhy specialist compliance talent has become criticalAnd we'll highlight an excellent resource from FD Capital called Consumer Duty: The Complete UK Guide, which provides a detailed practical explanation for firms navigating these requirements. Let's get started. Segment 1: The Biggest Regulatory Shift in a Decade Consumer Duty represents a fundamental shift in regulatory philosophy. Historically, financial services firms focused heavily on process compliance. The question regulators often asked was: "Did the firm follow the rules?" Under Consumer Duty, the question has become: "Did the customer achieve a good outcome?" That's a major difference. A firm can follow procedures, provide disclosures, complete assessments, and still face regulatory scrutiny if customer outcomes are poor. The FCA introduced Principle 12, requiring firms to act to deliver good outcomes for retail customers. This is supported by three cross-cutting rules: Act in good faithAvoid foreseeable harmSupport customers in pursuing their financial objectivesFor many organisations, this has required a complete rethink of governance, customer monitoring, reporting, and accountability. Segment 2: Understanding the Four Consumer Duty Outcomes Let's briefly walk through the four outcomes that sit at the heart of Consumer Duty. Outcome 1: Products and Services Products must be designed for a clearly identified target market and distributed appropriately. Firms need ongoing evidence that products continue to meet customer needs and objectives. This isn't a one-off exercise. It requires continuous review and oversight. Outcome 2: Price and Value The FCA expects firms to demonstrate that customers receive fair value. Importantly, fair value doesn't mean lowest price. It means the benefits received are proportionate to the cost being paid by customers. Firms need robust methodologies to assess this and challenge pricing where necessary. Outcome 3: Consumer Understanding Communications must be clear, understandable, and effective. The FCA increasingly expects firms to test customer communications and demonstrate that customers genuinely understand key information rather than simply receiving it. Outcome 4: Consumer Support Customers should be able to access support when needed and use products effectively. This includes complaint handling, service accessibility, vulnerable customer support, and ensuring barriers don't prevent customers from achieving their financial goals. Segment 3: Why Many Firms Are Still Struggling One of the most interesting insights from FD Capital's Consumer Duty Guide is that many firms treated Consumer Duty as a compliance project rather than a business transformation. And that's where problems often begin. Documentation was created. Committees were established. Policies were updated. But customer outcomes weren't always measured effectively. The ongoing challenge is evidence. Can you demonstrate: Customers are receiving fair value?Communications are understood?Vulnerable customers are being supported?Outcomes monitoring drives action?Because increasingly, that's what regulators want to see. Segment 4: The FCA's Focus in 2026 Recent FCA commentary suggests firms are improving the quality of their Consumer Duty reporting. Boards are receiving more structured information, accountability is becoming clearer, and action plans are increasingly linked to measurable outcomes. However, the FCA continues to focus on: Outcomes monitoringGovernance effectivenessFair value assessmentsVulnerable customer treatmentBoard engagementEvidence of remediation when issues are identifiedThe key message is simple. Data alone is not enough. Management information must lead to action. If a problem is identified, firms are expected to demonstrate how they responded and improved outcomes. Segment 5: The Talent Challenge One of the less discussed consequences of Consumer Duty has been the growing demand for specialist compliance professionals. Many firms now require: Heads of Consumer DutyConsumer Duty AnalystsChief Compliance OfficersRisk DirectorsConduct Risk SpecialistsRegulatory Reporting LeadersThese are increasingly strategic positions that sit at the intersection of regulation, customer outcomes, governance, and business performance. The organisations succeeding under Consumer Duty are often those with strong leadership, robust governance structures, and experienced professionals who understand both regulatory expectations and commercial realities. Segment 6: Recommended Resource If today's discussion has raised questions about your own Consumer Duty framework, I strongly recommend reading FD Capital's comprehensive guide: Consumer Duty: The Complete UK Guide The guide covers: Principle 12The three cross-cutting rulesThe four outcomesBoard governance requirementsOutcomes monitoringCommon implementation failuresFCA supervisory expectationsSpecialist compliance rolesIt's one of the more practical and detailed explanations available for senior leaders working within FCA-regulated firms. You can read it here: FD Capital Consumer Duty Guide Closing Thoughts Consumer Duty has fundamentally changed the conversation around compliance. The focus has shifted from demonstrating that rules were followed to proving that customers achieved good outcomes. That's a higher standard. It's also a more meaningful one. The firms that thrive under Consumer Duty won't simply be those with the best documentation. They'll be the firms with the strongest customer focus, the best governance, the most effective monitoring, and the right people leading the effort. Thank you for listening to The Regulatory Leadership Podcast. If you found this episode useful, please subscribe, leave a review, and share it with colleagues working in compliance, risk, governance, and financial services leadership. Until next time, stay compliant and stay customer-focused.

  7. Jun 5

    Speaking the Language of FCA Regulation

    Why Every FCA-Regulated Firm Needs a Regulatory Glossary Introduction Welcome to The FCA Compliance & Leadership Podcast. If you've ever sat in a board meeting, compliance committee, regulatory audit, or FCA supervision discussion and heard terms like SMCR, SMF16, MIFIDPRU, CASS, CONC, PERG, PROD, DORA, PRIIPs, or Consumer Duty being thrown around, you'll know one thing immediately: Financial regulation has its own language. And unless everyone in your organisation speaks that language consistently, misunderstandings can create compliance risks, operational problems, and costly mistakes. Today we're discussing why regulatory literacy has become a strategic advantage for FCA-regulated firms and highlighting an outstanding resource from FD Capital: The FCA Regulatory Glossary: Key Terms and Acronyms Explained. This practical guide brings together the key concepts, frameworks, sourcebooks, and acronyms that every regulated firm needs to understand. In this episode we'll cover: Why regulatory language mattersThe most important FCA acronyms every firm should knowCommon misunderstandings that create riskHow senior managers can improve regulatory awarenessWhy a central glossary has become an essential business toolLet's dive in. Segment 1: The Problem with Regulatory Complexity The UK regulatory environment has become increasingly sophisticated. Over the last decade firms have seen the introduction or expansion of: Consumer DutySMCROperational ResilienceFinancial Promotions reformsMIFIDPRUESG reporting obligationsDORAEnhanced AML requirementsEach framework introduces new terminology, new obligations, and new expectations. The challenge isn't simply understanding the rules. The challenge is ensuring that everyone across the business understands what those terms actually mean. Because when one person interprets a regulatory term differently from another, governance problems begin to emerge. Segment 2: Why Acronyms Matter More Than You Think Let's consider a simple example. Imagine a board report references: "SMF16 concerns regarding Consumer Duty outcomes linked to PROD governance and COBS disclosure requirements." For an experienced compliance officer, that's straightforward. For a finance director, operations executive, or non-executive director without a deep regulatory background, it can sound like an entirely different language. The FCA Regulatory Glossary solves this problem by providing practical explanations of the major regulatory terms and showing how they connect together. Rather than simply defining acronyms, it explains their real-world significance. Segment 3: The Most Important Regulatory Terms Every Firm Should Know Let's highlight a few examples. SMCR The Senior Managers and Certification Regime is the FCA's accountability framework. It places clear responsibility on senior individuals and requires firms to demonstrate who is accountable for specific business areas. SMF Functions Many firms regularly refer to SMF roles without fully understanding the distinctions. Examples include: SMF1 – Chief Executive OfficerSMF2 – Chief Finance FunctionSMF4 – Chief Risk OfficerSMF16 – Compliance OversightSMF17 – Money Laundering Reporting OfficerEach role carries distinct responsibilities and FCA expectations. Consumer Duty One of the most important recent developments. Consumer Duty requires firms to deliver good outcomes for retail customers across four key areas: Products and servicesPrice and valueConsumer understandingConsumer supportConsumer Duty has fundamentally changed how firms approach customer treatment and governance. CASS The Client Assets Sourcebook. A critical framework for firms holding client money or custody assets. Mistakes in CASS compliance can lead to significant regulatory consequences. Segment 4: The Hidden Risk of Misunderstanding One of the biggest risks facing growing regulated firms isn't intentional misconduct. It's misunderstanding. For example: A business may assume a particular activity falls outside FCA regulation. Later they discover the activity sits within the perimeter and authorisation should have been obtained. This is where terms like PERG become incredibly important. PERG, the FCA's Perimeter Guidance Manual, helps firms determine whether activities are regulated and whether FCA authorisation is required. Many costly compliance issues begin with firms misunderstanding regulatory definitions rather than deliberately breaching rules. Segment 5: Building a Culture of Regulatory Literacy The strongest regulated firms don't leave regulatory knowledge solely to the compliance department. Instead they build a culture where: Board members understand key regulatory concepts.Senior managers understand their personal responsibilities.Finance teams understand prudential requirements.Operations teams understand resilience obligations.Marketing teams understand financial promotions rules.This shared understanding creates better decision-making and stronger governance. A practical glossary becomes a common reference point across the organisation. Segment 6: Why the FCA Regulatory Glossary Stands Out What makes the FD Capital glossary particularly useful is its structure. Rather than presenting hundreds of terms alphabetically, it groups concepts into practical regulatory areas such as: SMCRConduct and Consumer RegulationAML and Financial CrimeInvestment ServicesPrudential RegulationPaymentsAuthorisationOperational ResilienceThis reflects how regulation operates in practice. The frameworks are interconnected, and the glossary helps readers understand those connections. For compliance professionals, it's a quick reference guide. For board members, it's a learning tool. For new joiners, it's an onboarding resource. And for senior managers, it's a practical reminder of how the regulatory landscape fits together. Segment 7: The Growing Demand for Regulatory Expertise One trend we're seeing across the market is increasing demand for specialist regulatory talent. Firms are actively recruiting: Chief Compliance OfficersMLROsCROsRegulatory Reporting LeadersConsumer Duty SpecialistsSMF16 HoldersWhy? Because the regulatory environment is becoming more technical and more accountable. Understanding the language of regulation is no longer optional. It's becoming a core leadership skill. Recommended Resource If you're involved in an FCA-regulated business, I strongly recommend bookmarking FD Capital's: FCA Regulatory Glossary: Key Terms and Acronyms Explained The guide covers: SMCR and Senior Manager FunctionsConsumer DutyFCA Handbook terminologyPrudential regulationAML and financial crimeFinancial promotionsInvestment services regulationOperational resilienceAuthorisation conceptsIt's a practical reference designed to help professionals navigate the increasingly complex regulatory environment. You can access it here: https://www.fdcapital.co.uk/fca-regulatory-glossary/ Closing Thoughts Regulation isn't getting simpler. New frameworks continue to emerge. Existing rules continue to evolve. And firms face increasing expectations around governance, accountability, resilience, and customer outcomes. In that environment, understanding regulatory language isn't just useful. It's essential. The organisations that succeed will be those that create a shared understanding of regulation across the entire business—not just within compliance teams. Thank you for joining us on The FCA Compliance & Leadership Podcast. If you enjoyed this episode, subscribe for future discussions on FCA regulation, governance, compliance leadership, and financial services best practice. Until next time, stay informed, stay compliant, and keep learning.

  8. May 30

    Consumer Duty in 2026: From Compliance Project to Business Reality

    Welcome to today's episode, where we're discussing one of the most significant regulatory developments in UK financial services – Consumer Duty. Since its introduction, Consumer Duty has transformed the way the FCA expects firms to operate. What started as a compliance implementation programme has evolved into something much bigger: an ongoing requirement for firms to demonstrate and evidence good customer outcomes. Today, we're exploring what firms have learned since implementation, where many organisations are still struggling, and why the people leading Consumer Duty programmes have become some of the most sought-after professionals in the UK financial services sector. This episode is inspired by the excellent Consumer Duty Outcomes Guide published by FD Capital, specialists in senior compliance, risk and regulatory recruitment for FCA-regulated firms. The Shift from Rules to Outcomes Historically, many firms approached regulation through a process-driven lens. The key question was often: "Did we follow the required procedures?" Consumer Duty changes that question entirely. The FCA now expects firms to demonstrate that customers are actually achieving good outcomes. Following a process alone is no longer enough. Firms must be able to evidence that products, services, communications and support arrangements are delivering positive results for consumers. This represents a fundamental shift in regulatory philosophy. It's no longer about ticking boxes. It's about outcomes. Understanding the Four Consumer Duty Outcomes At the heart of Consumer Duty sit four key outcomes. Products and Services Firms must ensure products are designed for a clearly identified target market and distributed appropriately. This requires ongoing product governance, regular reviews and evidence that products continue to meet customer needs. Price and Value The FCA expects firms to demonstrate that customers receive fair value. This doesn't mean products must be the cheapest available. It means the benefits received should be proportionate to the price being paid. Fair value assessments have become a major supervisory focus and remain one of the most scrutinised areas of Consumer Duty compliance. Consumer Understanding Communications must be clear, understandable and support informed decision-making. The FCA increasingly expects firms to test communications and demonstrate that customers genuinely understand what they're buying and the risks involved. Consumer Support Customers must receive appropriate support throughout the product lifecycle. This includes accessible service channels, complaint handling, vulnerable customer support and removing unreasonable barriers that prevent customers from achieving their financial objectives. Why Many Firms Are Still Struggling One of the most interesting observations highlighted in the FD Capital guide is that many firms viewed Consumer Duty as a one-time implementation project. The reality is very different. The initial implementation phase may be complete, but the ongoing challenge is proving compliance every day. Many firms continue to face difficulties around: Outcomes monitoringFair value assessmentsData collection and reportingVulnerable customer frameworksDistribution chain oversightBoard reporting and governanceThe FCA's recent supervisory communications suggest firms are improving, but there is still significant focus on evidence, accountability and measurable customer outcomes. The Growing Importance of Compliance Leadership Perhaps one of the biggest consequences of Consumer Duty has been the growing demand for senior compliance professionals. We're seeing increasing demand for: Chief Compliance OfficersHeads of Consumer DutyChief Risk OfficersCompliance DirectorsConsumer Duty AnalystsRegulatory Reporting SpecialistsThese roles have evolved significantly. Today's compliance leaders need much more than regulatory knowledge. They need commercial awareness, data literacy, governance expertise and the ability to influence stakeholders across the organisation. Consumer Duty has become a business-wide responsibility rather than a compliance department responsibility. What Good Looks Like So what separates firms that are succeeding from those that continue to face challenges? According to the patterns identified by FD Capital, successful firms tend to have: Strong board engagementClear ownership and accountabilityEffective outcomes monitoringRobust management informationWell-resourced compliance functionsGenuine customer-focused culturesMost importantly, they recognise that Consumer Duty is not a document. It's an operating model. It's embedded into product design, pricing decisions, customer communications and support processes. And that requires the right people. Final Thoughts Consumer Duty continues to reshape the UK financial services landscape. As the FCA's expectations mature, firms will increasingly be judged not on what policies they have written, but on the outcomes they can demonstrate. For many organisations, the question is no longer: "Have we implemented Consumer Duty?" It's: "Can we prove we're delivering good outcomes today?" If you'd like a deeper understanding of the regulatory framework, practical implementation challenges, ongoing governance requirements and the specialist roles firms are hiring to support Consumer Duty programmes, we strongly recommend reading FD Capital's comprehensive Consumer Duty Outcomes Guide. You can find it here: https://www.fdcapital.co.uk/consumer-duty-outcomes-guide/ and https://www.fdcapital.co.uk/consumer-duty-guide/

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Finance Directors and Chief Financial Officers are our speciality we are a London based recruitment service that specialises in Part-Time and Full Time senior financial professionals. Our podcast episodes discuss topics that are of interest to employers and prospective FD's and CFO's alike.

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  • Creator
    Adrian
  • Years Active
    2026
  • Episodes
    262
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    Clean
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    © 2026 FD Capital
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    FD Capital