Head of Compliance

  • Competitive
  • London, England, United Kingdom
  • Permanent, Full time
  • Rutherford Search
  • 21 Sep 16

Head of Compliance for leading consumer finance firm

Summary

  • An opportunity has arisen for a risk and compliance specialist to join a leading consumer finance firm. The successful candidate will have the following key roles:
  • Complete the implementation and ongoing maintenance of sound operational risk management and compliance frameworks.
  • Manage the Group’s relationship with the FCA and any other relevant regulatory bodies in both the UK and the USA ensuring that the Group is always aware of and adheres to existing and new compliance regulations in both countries.
  • Be responsible for and carry out, using appropriate internal resource, the Group Compliance Monitoring Program for both the core luxury asset and property business, whilst ensuring that the Group has a deeply embedded compliance and risk culture.
  • Will assume the MLRO Controlled Function on behalf of the Group and be accepted by the FCA as such.
  • Act as the focal point for the resolution of all legal matters within the Group, providing in-house advice on day to day legal matters and coordinating the use of external legal support when needed and when approved by the CEO or Group Finance Director as appropriate.
  • The role will report to the Group Finance Director and support the Audit Committee in its independent oversight of the firm’s operational risk management and compliance activities.

 

Key Responsibilities

  1. Compliance

Compliance Policy and Standards

Maintain, communicate and support the implementation of policy and process changes to reflect changes on the firm’s regulatory environment. This will include: 

  • Monitor external developments through horizon scanning, including updates to the Audit Committee on a quarterly basis.
  • Provide written guidance on developing standards, including updating policies and procedures to reflect changing compliance requirements.
  • Maintain compliance documentation and manuals aligned with regulatory requirements.

 

Compliance Monitoring

Formulate, document and implement a programme for monitoring compliance activities and report to senior management. This will include:

  • Establish and carry out a risk based compliance monitoring program driven by the firm's key compliance risks.
  • Provide updates to the Audit Committee based on the results of the compliance monitoring program, including the status of any remediation action required to address process and control weaknesses.
  • Ensure the firm’s compliance risk appetite and compliance policy remain fit for purpose.
  • Facilitating on-going compliance risk reporting by policy and risk owners.
  • Report breaches and incidents to management and the Audit Committee and where relevant, to the regulators.  This will include reviewing the nature and complexity of breaches and incidents, performing of root cause analysis and advice on potential solutions to address weaknesses.

 

Compliance Oversight and Support

Establish compliance as a centre of expertise and challenge. This will include leading and supporting senior management in preparing for authorisation by the FCA and the delivery of the authorisation requirements, including the business plan, compliance monitoring programme and business continuity planning requirements.  Other areas of ongoing support will include:

  • Reviewing pre-contract documentation based on regulatory changes and co-ordination of approval from the US.
  • Reviewing new product launches and financial promotions.
  • Supplying technical advice on Data Protection
  • Coordinating and resolving issues identified in reviews commissioned by the Audit Committee.
  • Maintaining and updating Approved Person registrations.
  • Maintaining oversight of the complaints procedures, including reporting to stakeholders.
  • Review and challenge over the completeness, accuracy and consistency of compliance risk assessments.
  • Develop and deliver a compliance training programme for the business, Board and ExCo on relevant regulatory requirements.

 

Develop and Maintain Regulatory Relationships

Establish and maintain a productive working relationship with regulators (primarily the FCA) based on transparent and open communication.  This will include:

  • Provide senior management with regular briefings on regulatory expectations.
  • Provide the required returns and reports to the FCA in a timely manner.
  • Escalate and report issues and breaches as necessary.
  • Respond to regulatory requests, notifications and communications in a timely manner.
  • Manage regulatory visits.

 

  1. In House Legal Support

Manage the Group’s internal legal activities. This will include:

  • Review and approval of all legal documentation to include, but not limited to, consignment agreements, sales advance agreements, standard Group contracts, Non – Disclosure Agreements, supplier contracts and internal service level agreements.
  • Customer dispute resolution providing advice on how to respond to claims, drafting formal responses and resolving any litigation if and when it arises.
  • Day to day support of all aspects of the business, providing advice and dealing with legal queries as they arise.
  • Provide regular in house updates and training on legal issues that affect the Group.
  • Manage the Groups relationships with external legal support including acceptance of terms of business, letters of engagement, quality control and performance acceptance.

 

Key Requirements

  • At least 5 years risk management and compliance experience gained within a relevant regulated environment and preferably with experience of having worked in a regulated property lending business. Sufficiently experienced to accept the MLRO controlled function on behalf of the Group.
  • Strong technical background of FCA regulatory requirements across Consumer Credit products and Property Lending.
  • Good understanding of effective risk management frameworks including, but not limited to, operational, conduct, financial, data protection and information security standards.
  • Good understanding of UK and European legislation (e.g. CIA, DPA, IMD), codes of practice and industry guidelines affecting the Group.
  • It is important to note that this is a Global Role and thus, whilst regulation with the FCA is for UK entities, it is important that the risk and compliance processes are appropriate for the US as well and take into account the laws/regulations that we are subject to there.
  • Strong communications skills, both orally and in writing across all levels of management.
  • Pragmatic approach to problem solving which balances commercial and regulatory objectives.
  • Ability to form close working relationships across the business and influence management and stakeholders.
  • Highly motivated self-starter who can work independently.