Consumer Credit Risk Manager

Our client provides card acquiring services to corporate merchants, with a focus on e-commerce and digital businesses. They are establishing a new Dutch entity to expand their credit offering to consumers in the Netherlands.

The Consumer Credit Risk Manager will be appointed as a statutory director of the new Dutch entity and will hold the risk-management portfolio on its board. Alongside leading the firm's consumer-credit risk framework, the successful candidate will carry the responsibilities that Dutch law and the Autoriteit Financiële Markten (AFM) place on a day-to-day policymaker of a licensed credit provider.

The role will play a central part in preparing and supporting the entity's application to the AFM for a licence to offer consumer credit. The successful candidate must have previous experience of leading or materially supporting a consumer-credit licence application to the AFM, or a closely comparable authorisation with another EEA financial regulator, and must be able to satisfy the AFM's suitability and propriety assessments.

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

• 2-3 days per week, for a duration of up to 2 years.
• Hybrid, flexible working, with 1 day per week required in the Amsterdam office.

• 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.

• 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.

• Candidates will be required to be AFM approved (or eligible for AFM approval as a day-to-day policymaker).
• 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.
• Previous senior leadership experience within the Pay Later (BNPL) space is required.
• 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…