Credit Risk Manager

My client is a payment company

Key responsibilities

Board membership and statutory duties

• Serve as a statutory director of the Dutch entity and as its day-to-day policymaker for risk.
• Obtain and maintain AFM approval as a day-to-day policymaker before appointment.
• Lead or support the entity's application to the AFM for a licence to offer consumer credit.
• Develop and maintain the entity's consumer-credit risk appetite, policies and governance framework, and present them to the board for approval.
• Define customer eligibility, credit limits, loan amounts, repayment terms and decline criteria.
• Design controls for repeat borrowing, concurrent borrowing, the stacking of multiple small obligations, and credit-limit increases.
• Develop credit-scoring, underwriting and decisioning strategies.
• Review and approve material changes to credit policies and decisioning models.
• Develop management information and reporting for the consumer-credit portfolio.
• Monitor approval rates, utilisation, arrears, defaults, losses, recoveries and customer outcomes.

Governance and oversight

• Act as the principal subject-matter expert for consumer-credit risk and as the board-level owner of the risk-management function.
• Design and maintain risk-management, compliance and internal-audit arrangements proportionate to the entity, with sufficient independence from the commercial lines.
• Establish clear ownership, delegated authorities and escalation routes for credit-risk decisions.
• Maintain the entity's credit-risk policies, procedures and mandates, the incident-handling procedure and the notification obligations owed to the AFM.
• Work with Compliance Monitoring and Internal Audit to test the effectiveness of credit controls.
• Support complaints handling and the entity's Kifid arrangements as they relate to credit decisions, affordability and arrears.
• Support Risk Committee, management board and supervisory board discussions relating to consumer lending.
• Provide training on credit-risk requirements and responsible lending, and support the oath obligations applying to customer-facing and risk-relevant staff.
• Own the credit-risk relationship with the AFM and support the entity's wider supervisory dialogue.

Essential experience

• Previous experience of leading or materially supporting a consumer-credit licence application to the AFM, or a closely comparable authorisation application to another EEA financial regulator.
• Strong knowledge of Dutch consumer-credit regulation: the credit provisions of the Wft and BGfo, Book 7 Title 2A of the Dutch Civil Code, and the AFM's supervisory approach and guidance.
• Working knowledge of CCD2 and its Dutch implementation, and of what it changes for short-term credit, BNPL and deferred payment.
• Experience working for a regulated lender, bank, fintech, payment institution, electronic money institution or BNPL provider.
• Practical experience of consumer-credit underwriting and affordability assessment in the Dutch or a comparable European market, including the credit register and Nibud-based lending norms.
• Experience developing credit-risk policies, strategies and governance arrangements.
• Experience monitoring a consumer-credit portfolio and producing credit-risk management information.
• Experience working with senior management, regulators, external advisers and cross-functional teams.
• Strong understanding of the Dutch duty of care and the AFM's expectations on embedding the customer's interest, with the judgement to apply them absent a single codified outcomes duty.

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, including where the final text of the requirement is not yet settled.
• Strong written communication and regulatory drafting skills.
• Sound judgement and the ability to challenge commercial proposals constructively, including at board level and against the group.
• Ability to explain complex credit-risk matters clearly to senior stakeholders, supervisors and non-specialists.
• Strong project-management and organisational skills.
• Ability to work independently and to manage several regulatory and operational priorities simultaneously.
• High standards of integrity, accountability and attention to detail, commensurate with a regulator-approved board appointment.