Consumer Credit Risk Manager

PaymentGenes; Amsterdam; Hybrid; EUR 110,000 - 150,000; Full time

Job summary

PaymentGenes is establishing a Dutch entity to expand its consumer credit offering. The Consumer Credit Risk Manager will be a statutory director and board risk policymaker, overseeing risk governance and regulatory compliance, including the AFM licensing process.

In this hybrid role based in Amsterdam, you will design risk frameworks, credit-policy controls and underwriting standards, coordinating with regulators and senior management to ensure responsible lending and regulatory suitability.

Qualifications

• AFM approval or eligibility is required as a day-to-day policymaker.
• Experience leading or supporting consumer-credit licence applications to AFM or equivalent regulators.
• Senior leadership experience in the Pay Later (BNPL) space is required.

Responsibilities

• Serve as a statutory director and day-to-day policymaker for risk.
• Lead or support the entity's application to AFM for a consumer credit licence.
• Develop and maintain consumer-credit risk policies, governance and appetite.
• Define customer eligibility, credit limits and approval criteria.
• Monitor portfolio performance, arrears and credit-risk reporting.

Skills

AFM approval

Regulatory drafting

Credit risk governance

Board comms

BNPL experience

Job description

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.

Engagement details

• 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.

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 required:

• 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 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 required:

• 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.

If you feel you have the relevant skills and experienced required for this unuique role, please apply today!