Senior management functions

In your application, your firm should demonstrate that it has a robust recruitment process and that it carries out the appropriate level of due diligence on all its candidates.

For SMFs you should also consider providing:

• CV
• statement of responsibilities
• confirmation of a clear criminal records check
• confirmation of clear regulatory reference(s)
• management responsibility map(s)
• handover procedures
• role specification
• organisation chart(s)
• board/executive team biographies
• recruitment, referencing, interview and appointment processes
• skills gap analysis
• learning and development plan
• competency assessment

We may decide to interview any SMF candidate. Typically an interview may be required for these positions:

• chairperson
• senior independent director
• chair of risk or audit committee
• chief executive officer (group or UK)
• risk director/chief risk officer
• finance director/chief finance officer (solo-regulated firms)
• compliance oversight
• individual with CASS oversight

However, if we have concerns about an individual’s fitness and propriety or about their firm, we can choose to interview for a role at any level or at any firm.

We expect people to understand and be able to fully explain their regulatory responsibilities, their role and how their knowledge or experience equips them to carry out these functions.

The interview also looks at awareness and understanding of:

• the market which the firm operates in
• the firm’s business model and strategy
• risk management and control
• financial analysis and controls (for solo-regulated firms)
• governance, oversight and controls
• our regulatory framework, requirements and expectations
• the culture of the firm, including its diversity and inclusion programmes
• the firm’s implementation of our Consumer Duty

The members of the interview panel will be determined by the firm type and role, and will usually include representatives from our Authorisation and Supervision departments, as well as a senior adviser.

If we're satisfied with the person’s fitness and propriety

We will approve the application and confirm this in writing.

If we're not satisfied

We will tell the firm and explain the next steps. These may be to refuse the application or invite the person to attend a second interview.

For dual-regulated firms, the Prudential Regulation Authority (PRA) leads on reviewing applications for PRA-designated SMFs but it needs our consent first. Without this, the PRA has to refuse the application.

If we and the PRA request an interview, we may do this as 1 joint interview or have 2 separate interviews.