Appointing a senior leader is a consequential decision for any business. For a UK regulated firm, it also raises a specific question: can the individual demonstrate that they are fit and proper to perform the Senior Management Function (SMF) in question? An impressive career history may attract attention, but it cannot replace evidence of sound judgement, relevant capability and suitability for the responsibilities the person will actually hold.
That is why specialist recruitment starts well before a shortlist is drawn up. It connects the firm’s commercial objectives with its governance needs and the evidence required to support an appointment. SMF Capital builds each search around the fit and proper assessment from the first conversation, rather than treating it as a final check after a preferred candidate has emerged.
What fit and proper means in recruitment
Fitness and propriety is not a generic measure of whether someone looks credible on paper. The principal considerations are honesty, integrity and reputation; competence and capability; and financial soundness. The assessment also needs to reflect the nature, scale and complexity of the firm and the specific role the candidate would perform. A person who has succeeded in one regulated setting may not automatically be suited to another.
For recruiters, this changes the questions asked at the outset. What decisions will the appointee own? Which risks will they oversee? How closely will they work with the board, control functions and other senior managers? What experience demonstrates that they can challenge colleagues constructively rather than simply endorse existing plans? Answers to these questions create a more useful candidate profile than a list of former job titles.
The same approach helps distinguish an appointment that meets an immediate need from one that will strengthen the firm over time. A candidate might bring valuable sector knowledge but lack experience of the particular governance demands of the role. Another might have less obvious credentials yet be able to show precisely how they handled comparable decisions, escalated concerns and remained accountable when circumstances changed.
Defining the role before finding the person
A successful search begins with clarity about responsibilities. Two firms can use the same title while expecting markedly different contributions. A senior manager at a growing payments business may need to build processes as well as lead them. At a larger, established organisation, the challenge may be to oversee complex reporting lines and provide effective challenge across multiple teams.
Specialist recruiters can test the brief with the firm before approaching candidates. That means discussing reporting relationships, decision-making authority, the time commitment and the experience needed from day one. It also means identifying responsibilities that may be unclear or overlap with another role. Recruitment cannot resolve every governance question, but it can expose ambiguities early enough for the firm to address them.
This matters particularly when a business is preparing for authorisation, entering a new market or changing its board. The right appointment depends on where the firm is going, not only where it has been. SMF Capital works across first compliance appointments, interim needs and full board refreshes, giving firms a way to frame each search around its particular stage of development.
Assessing evidence, not just experience
Senior candidates often present polished accounts of their achievements. A specialist search process goes further by exploring what they personally did, the decisions they made and the results they can substantiate. It should examine how they responded to difficult information, dealt with competing priorities and worked with colleagues whose responsibilities differed from their own.
Competence also needs to be assessed in context. Experience at a wealth manager, consumer credit lender or insurer may provide a strong foundation, but the firm still needs to understand how that experience applies to its own activities and risks. A thoughtful interview process gives candidates room to explain both the extent and the limits of their expertise.
Integrity is equally important, and it calls for careful, fair questioning. Recruiters should not jump to conclusions from an unexplained career move or an issue that needs further context. They can, however, encourage clear disclosure and help the firm identify matters requiring proper investigation. The aim is not to promise that a candidate will be approved. It is to help the firm make a well-supported decision with fewer avoidable surprises.
Managing the timetable realistically
An SMF vacancy rarely occurs at a convenient moment. A departure can leave a firm seeking continuity while it conducts a permanent search. A new business may need leadership in place as it prepares to operate. A growing firm may require additional capacity before an existing senior manager becomes overstretched.
These situations demand realistic scheduling. The firm must allow time to define the role, identify and assess candidates, complete its checks and prepare an application where approval is required. Regulatory references and criminal record checks form part of the application process, subject to the applicable requirements. Leaving them until the end can create delays or reveal questions when there is little room to reconsider a decision.
A recruiter who understands this sequence can work backwards from the firm’s target date. That does not mean rushing assessments to meet a deadline. It means making the critical steps visible early, keeping candidates informed and recognising when a proposed start date depends on an approval that has not yet been granted. SMF Capital runs searches with the regulatory timetable in view as well as the employer’s commercial timetable.
Choosing the right appointment model
A permanent hire is not the only possible answer to a leadership gap. Interim appointments can provide experience during a transition, while fractional arrangements may suit a firm that needs specialist senior input without a full-time position. Executive and non-executive appointments also serve different purposes. The appropriate model depends on the work to be done, the level of accountability involved and the firm’s governance arrangements.
Specialist recruiters can widen the conversation beyond familiar permanent-hire assumptions. An interim leader may be well placed to stabilise a function while the firm conducts a broader search. A non-executive candidate may add independent challenge where the board needs a different perspective. A fractional appointment may offer a practical way to access expertise, provided the person has sufficient capacity to discharge the responsibilities assigned to them.
None of these models removes the need to assess suitability for the actual role. A limited number of working days, for example, must still be consistent with the decisions the individual is expected to make. The question is not simply whether the candidate is available, but whether the proposed arrangement gives them the authority, information and time to be effective.
Building a team, not filling vacancies
Senior managers do not operate in isolation. Their effectiveness depends partly on how responsibilities are divided and how well the team works together. A search focused too narrowly on one vacant seat can miss a wider issue: the firm may need a different balance of expertise, clearer accountability or stronger challenge between executives and non-executives.
For Enhanced firms, a board refresh provides an opportunity to examine those connections. Senior Managers have Statements of Responsibilities, and Enhanced firms must also maintain a Responsibilities Map. Recruitment should therefore take account of how a proposed appointment fits the existing structure, while the firm remains responsible for its governance documents and regulatory obligations.
This team-wide perspective is useful across sectors. Banks and building societies, investment managers, intermediaries, fintech and crypto-asset firms do not all face identical leadership challenges. Overseas firms establishing UK branches have another set of practical questions about local knowledge and reporting relationships. A specialist recruiter helps turn those differences into a focused search rather than relying on a standard template.
A more defensible hiring decision
The value of specialist recruitment is not simply access to candidates. It lies in asking better questions, testing the role against the firm’s needs and helping decision-makers evaluate evidence consistently. Where concerns arise, the process should bring them into view rather than smooth them over. Where a candidate has strengths but also development needs, the firm should be able to judge whether that combination is appropriate for the position.
Every search at SMF Capital is led personally by Adrian Lawrence FCA. That direct involvement supports a consistent approach from the initial brief through candidate assessment, whether the appointment is executive, non-executive, permanent, interim or fractional. It also helps keep attention on the connection between the individual, the responsibilities and the regulated business they would join.
Ultimately, a fit and proper senior management team is built through deliberate choices, not a collection of impressive CVs. Firms need people whose experience matches their duties, whose judgement withstands scrutiny and whose roles fit together coherently. By placing those requirements at the centre of the search, SMF Capital helps regulated firms approach senior appointments as decisions about lasting leadership and accountability, rather than vacancies to close.
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