Credit Risk Officer SMF4

Onerway is a UK-regulated Electronic Money Institution providing card acquiring services to corporate merchants, with a focus on e-commerce and digital businesses.

We are growing our UK presence and are looking for

Consumer Credit Risk Manager to expand our Credit offering to UK consumers.

The Credit Risk Manager will lead the development and implementation of the firm’s consumer-credit risk framework as it expands into Buy Now Pay Later and other consumer-lending products.

The role will play a central part in preparing and supporting the firm’s application to the Financial Conduct Authority for consumer-credit permissions.

The successful candidate must have previous experience of leading or materially supporting an FCA consumer-credit authorisation or Variation of Permission application.

Following authorisation, the Credit Risk Manager will be responsible for establishing and overseeing the firm’s credit-risk strategy, affordability and creditworthiness processes, portfolio monitoring, arrears management and credit-risk governance.

The role will work closely with Compliance, Legal, Product, Finance, Operations, Technology and senior management to ensure that the firm’s lending activities are commercially sustainable and compliant with FCA requirements.

Key responsibilities

• FCA consumer-credit application
• Lead or support the preparation of the firm’s FCA consumer-credit authorisation or Variation of Permission application.
• Define the permissions required for the proposed BNPL, instalment-credit or revolving-credit products.
• Prepare the credit-risk sections of the regulatory business plan.
• Develop the policies, procedures, controls and supporting documentation required for the application.
• Respond to FCA information requests and support meetings with the FCA.
• Demonstrate that the firm is ready, willing and organised to undertake regulated consumer-credit activities.
• Work with external legal and regulatory advisers where required.
• Ensure that the proposed lending model is appropriately separated from the firm’s safeguarded e-money and payment-services funds.
• Develop and maintain the firm’s consumer-credit risk appetite, policies and governance framework.
• Establish creditworthiness and affordability assessment methodologies.
• Define customer eligibility, credit limits, loan amounts, repayment terms and decline criteria.
• Design controls for repeat borrowing, concurrent borrowing and credit-limit increases.
• Develop credit-scoring, underwriting and decisioning strategies.
• Establish appropriate use of credit-reference-agency, open-banking, income and fraud-prevention data.
• Ensure credit decisions are proportionate, explainable and consistent with the Consumer Credit sourcebook and Consumer Duty.
• Review and approve material changes to credit policies and decisioning models.
• Provide credit-risk input into the design of BNPL, instalment-credit and credit-line products.
• Review pricing, fees, repayment structures, customer journeys and contractual terms from a credit-risk perspective.
• Conduct product-risk assessments before launch.
• Assess whether products are appropriate for their intended target markets.
• Ensure that product design does not encourage unaffordable or unsustainable borrowing.
• Support the development of appropriate customer disclosures and explanations.
• Develop management information and reporting for the consumer-credit portfolio.
• Monitor approval rates, utilisation, arrears, defaults, losses, recoveries and customer outcomes.
• Establish early-warning indicators and portfolio-risk thresholds.
• Monitor portfolio performance by customer segment, merchant, product, acquisition channel and credit strategy.
• Identify emerging risks and recommend corrective action.
• Produce regular reports for senior management, the Risk Committee and the Board.
• Support financial forecasting, impairment modelling and expected credit-loss calculations.
• Arrears, forbearance and collections
• Develop the firm’s arrears, forbearance and collections strategy.
• Ensure customers in financial difficulty are treated fairly and receive appropriate support.
• Define appropriate contact, repayment-plan, breathing-space and vulnerability procedures.
• Oversee third-party collections or debt-servicing providers where applicable.
• Monitor collections performance and customer outcomes.
• Ensure that collections practices comply with FCA requirements and the Consumer Duty.
• Governance and oversight
• Act as the principal subject-matter expert for consumer credit risk.
• Establish clear ownership and escalation routes for credit-risk decisions.
• Support Risk Committee and Board discussions relating to consumer lending.
• Maintain appropriate credit-risk policies, procedures and delegated authorities.
• Work with Compliance Monitoring and Internal Audit to test the effectiveness of credit controls.
• Support regulatory reporting and notifications relating to the consumer-credit business.
• Provide training to relevant employees on credit-risk requirements and responsible lending.
• Previous experience of leading or materially supporting an FCA consumer-credit authorisation or Variation of Permission application.
• Strong knowledge of UK consumer-credit regulation and the FCA regulatory framework.
• Experience working for a regulated lender, bank, fintech, payment institution, electronic money institution or BNPL provider.
• Practical experience of consumer-credit underwriting, affordability and creditworthiness assessments.
• Experience developing credit-risk policies, strategies and governance arrangements.
• Experience monitoring a consumer-credit portfolio and producing credit-risk management information.
• Understanding of arrears, forbearance, vulnerability and collections requirements.
• Experience working with senior management, regulators, external advisers and cross-functional teams.
• Strong understanding of Consumer Duty and its application to consumer-lending products.
• Experience of BNPL, instalment-credit, revolving-credit or point-of-sale finance products.
• Experience working within an authorised electronic money institution or payment institution.
• Knowledge of the interaction between the Electronic Money Regulations, Payment Services Regulations and FSMA consumer-credit requirements.
• Experience implementing automated credit-decisioning or credit-scoring systems.
• Experience using credit-reference-agency, open-banking or fraud-prevention data.
• Knowledge of IFRS 9, expected credit losses or consumer-credit impairment modelling.
• Experience overseeing outsourced underwriting, servicing or collections arrangements.
• Experience launching a new regulated lending product.

Skills and competencies

• Strong analytical and quantitative skills.
• Excellent understanding of credit-risk principles and responsible lending.
• Ability to translate regulatory requirements into practical policies and controls.
• Strong written communication and regulatory drafting skills.
• Sound judgement and the ability to challenge commercial proposals constructively.
• Ability to explain complex credit-risk matters clearly to senior stakeholders.
• Strong project-management and organisational skills.
• Ability to work independently and manage several regulatory and operational priorities.
• High standards of integrity, accountability and attention to detail.

Qualifications

A degree or equivalent professional experience in finance, economics, risk management, law, mathematics, statistics or a related discipline is preferred.

Relevant professional qualifications in credit, risk, compliance or financial services would be advantageous.

• Key performance measures
• Successful submission and progression of the FCA consumer-credit application.
• Timely implementation of the consumer-credit risk framework.
• Effective management of credit losses, arrears and portfolio performance.
• Compliance with the firm’s credit-risk appetite and regulatory obligations.
• Quality and accuracy of credit-risk management information.
• Effective identification, escalation and remediation of emerging credit risks.

The title could also be changed to Consumer Credit Risk Manager or Head of Credit Risk depending on the seniority and whether the person will own the FCA application.

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