Group Head of Compliance

Job Title

Group Head of Compliance (Including T&C & Onboarding) – UK Mortgage Network

Business

Mortgage Intelligence (UK Mortgage Network), part of OneDome Group

Reporting line

Reports to Andrew Montlake (SMF3 – Executive Director)
Regular access to Board / Risk & Compliance Committee (or equivalent governance forum)

Direct reports

Compliance Advisory & Monitoring, File Review/Quality Assurance, Training & Competence, Onboarding (and associated teams/roles depending on structure)

Role purpose

To lead the Compliance function across the Mortgage Intelligence network and relevant OneDome Group regulated activities, with accountability for Compliance, Training & Competence (T&C), and Onboarding frameworks. The role ensures robust FCA compliance, effective AR/network oversight, and strong Consumer Duty outcomes, enabling compliant growth, improving adviser quality, and embedding a positive compliance culture.

A key element of the role is to build a strong, scalable compliance and supervision approach for specialist lending, commercial mortgage business, and second charge activity, ensuring appropriate controls, competent advice standards, and effective oversight of higher-risk and more complex cases and customer journeys.

Key responsibilities

1) Compliance leadership, strategy & governance

• Develop and deliver the annual compliance plan and multi-year compliance strategy aligned to business goals and risk appetite.
• Provide clear, insightful reporting to SMF3 (Andrew Montlake), committees and Board on: key risks, monitoring outcomes, breaches, complaints insights, root-cause trends and remediation effectiveness.
• Maintain a strong compliance culture across the network, balancing commercial pragmatism with regulatory expectations.
• Lead, coach and develop the compliance, T&C and onboarding teams, ensuring consistent standards and measurable outcomes.
• Ensure the compliance framework reflects the needs of regulated, specialist, commercial and second charge distribution, including proportionate oversight and appropriate escalation controls.

2) FCA regulatory compliance & advisory

• Provide senior advisory support on FCA rules and guidance relevant to a mortgage network environment, including (as applicable): MCOB, ICOBS, SYSC, PRIN, DISP, COCON/SM&CR, CONC (where applicable) and Financial Promotions.
• Own and maintain the compliance framework: policies, procedures, controls, attestations, governance documentation and approvals.
• Oversee regulatory change management—horizon scanning, impact assessment, implementation and evidencing—ensuring change is translated into practical controls, training and monitoring.
• Ensure advisory coverage and governance for specialist/commercial/second charge activity, including higher-risk case types, complex customer needs, and enhanced oversight expectations.

3) AR / network oversight & supervision model

• Own the network’s AR oversight framework: onboarding due diligence, contractual compliance, supervision, ongoing monitoring, and exit/termination.
• Ensure robust oversight of adviser conduct and advice standards across AR firms/advisers, including clear escalation, intervention and restriction pathways where needed.
• Drive a proportionate supervision model aligned to risk, performance, vulnerability indicators, and customer outcomes.
• Implement enhanced supervision for specialist, commercial and second charge activity where required, including thresholds for additional checks, pre-sale review, or targeted sampling.

4) Consumer Duty & conduct risk ownership

• Lead Consumer Duty implementation and BAU evidence: outcomes testing, data/MI, fair value (as applicable to distribution chains), customer understanding/support, and distribution chain monitoring.
• Embed vulnerability, good customer outcomes, and conduct risk thinking into onboarding, training, advice processes and ongoing monitoring.
• Ensure customer communications and journeys (including marketing and introducers) meet Duty standards.
• Ensure Consumer Duty outcomes are appropriately evidenced for specialist and second charge customers who may have higher vulnerability indicators (e.g., credit impairment, debt consolidation drivers) and for commercial customers where communications, fees and eligibility must remain clear and fair.

5) Monitoring, assurance, breaches & issue management

• Own the risk-based monitoring and assurance programme across: AR firms, advisers, central functions, onboarding and T&C.
• Maintain effective processes for breach logging, investigation, root-cause analysis, corrective actions and validation of fixes.
• Lead thematic reviews and deep dives (e.g., advice quality, vulnerable customers, financial promotions, lead sources, fee disclosure, suitability standards).
• Implement targeted monitoring and MI for specialist, commercial and second charge activity including:
• Suitability
• Product eligibility and disclosure quality
• Fees/commission transparency and customer understanding
• Vulnerability identification and support evidence
• Referral/packager/introducer controls (where applicable)
• Triggered reviews based on complaint trends, lender feedback or unusual performance metrics

6) Training & Competence (T&C)

• Own the T&C framework in line with FCA expectations: competence standards, supervision, coaching, CPD, adviser development pathways and outcomes-based QA.
• Ensure effective file checking and suitability assessment models, including calibration, consistency, and MI that drives improvement.
• Oversee adviser authorisation/competency sign-off processes, including new starter supervision, ongoing competence reviews, and triggered reviews.
• Partner with Sales/Operations to ensure training is practical, current and reflected in adviser behaviour and customer outcomes.
• Develop and maintain defined competence pathways (and sign-off standards) for:
• Specialist lending (e.g., credit impaired, complex income, non-standard property)
• Second charge advice standards and customer outcome risks
• Commercial mortgage business including appropriate fact finding, disclosure and customer communications (with enhanced supervision/sign-off where applicable)

7) Onboarding (AR firms & advisers)

• Own onboarding standards and controls for AR firms and adviser appointments: due diligence, fit & proper checks, references, qualifications, competence, financial/credit checks (where applicable) and documentation completeness.
• Ensure onboarding is efficient, customer-outcome focused and risk-based, with clear SLAs and governance.
• Ensure introducers/lead sources and marketing routes are appropriately assessed, approved and monitored where in scope.
• Build onboarding routes/controls for specialist, commercial and second charge permissions and activity, including:
• Competence and experience verification specific to each segment
• Clear scope of permission and operating model (what can/can’t be advised, referral routes, escalation triggers)
• Packager/introducer/third-party due diligence where relevant
• Enhanced onboarding checks for higher-risk distribution models or advisers new to these segments

8) Complaints oversight & external engagement

• Oversee/coordinate compliance input to complaints oversight: DISP adherence, root-cause MI, lessons learned, and systemic remediation.
• Support regulatory engagement as required (information requests, reviews, communications), ensuring responses are accurate, timely and well evidenced.
• Ensure complaint root-cause MI specifically tracks and address’s themes in specialist/second charge/commercial cases (e.g., disclosure, affordability evidence, consolidation rationale, customer understanding).

9) Financial promotions & distribution governance

• Maintain effective controls for financial promotions approvals/oversight across network and group channels (web, social, email, lead-gen, AR materials).
• Ensure strong oversight of distribution chain risks (introducers, packagers, lead generators, outsourced providers).
• Ensure marketing and financial promotions are appropriate for specialist and second charge propositions (particularly where customers may be more vulnerable) and that any claims are fair, clear and not misleading.

10) Third-party / outsourcing oversight & group alignment

• Provide compliance oversight for outsourced/third-party activity impacting regulated business, ensuring appropriate due diligence, contractual controls, monitoring and MI.
• Align Mortgage Intelligence compliance, onboarding and T&C standards with OneDome Group governance requirements while meeting entity-specific regulatory obligations.

11) Specialist, commercial & second charge framework ownership

Develop, embed and continuously improve a compliant and scalable framework for specialist lending, commercial mortgage business, and second charge activity across the network.

• Define the adviser competence requirements, supervision levels, QA/file review standards, escalation triggers and management information.
• Ensure consistent standards for:
• Fact find and evidence expectations proportionate to complexity
• Suitability rationale
• Disclosure and customer understanding (fees, risks, implications, alternatives)
• Vulnerable customer identification/support and outcome evidence
• Partner with the commercial and specialist sales leadership to enable growth safely supporting proposition development, lender relationships and distribution strategy with robust controls and clear adviser guidance.
• Drive targeted improvement plans where risks emerge (e.g., complaint spikes, increased lender declines, poor QA outcomes), ensuring root-cause fixes and re-testing.

Authority & decision making

• Authority to require remedial action, impose enhanced supervision, restrict activity, or recommend suspension/termination of advisers/AR relationships based on risk and evidence
• Recommendation authority for onboarding approvals, competence sign-off, and financial promotions
• Authority to set risk-based controls for specialist/commercial/second charge activity including enhanced QA sampling, pre-sale checks or additional sign-off requirements where appropriate.

Required experience & capability (essential)

• Compliance leadership experience within an FCA-regulated UK mortgage intermediary/network (AR oversight experience strongly preferred).
• Proven ownership of T&C frameworks and advice quality controls (file review/QA) in an advised sales environment.
• Experience owning or partnering closely with onboarding/due diligence for AR firms/advisers.
• Strong practical knowledge of Consumer Duty and conduct risk management.
• Track record of designing and running risk-based monitoring and delivering improvements through effective remediation.
• Confident communicator with ability to challenge senior stakeholders and influence outcomes.
• Strong MI discipline with ability to define, interpret and present data that evidences customer outcomes and control effectiveness.
• Strong working understanding of the risk profile and controls required for specialist lending, commercial mortgage business and second charge, including higher-risk customer journeys, evidencing standards and appropriate supervision models.

Desirable

• Deep hands-on experience specifically in specialist/second charge/commercial oversight within a network environment.
• Experience in wider protection/GI distribution and multi-product advice environments.
• Experience in regulated group structures and managing cross-entity governance.

Personal attributes

• High integrity; balanced, evidence-led judgement.
• Commercially pragmatic but comfortable holding the line on customer outcomes and regulatory standards.
• Strong people leader; develops capability and consistency across teams.
• Comfortable operating at both strategic and hands-on levels.
• Growth-orientated with a “can do” attitude, energised by helping the business scale safely and sustainably.
• A self-starter who looks to make a difference, proactively identifying opportunities to improve controls, processes and customer outcomes.
• Action-focused and solution-led, with ability to unblock progress, find workable routes through challenges, and help teams deliver where others may see barriers.
• Confident, positive challenger who constructively pushes for better outcomes while maintaining strong relationships.