Vulnerable Customer Manager

Who you are

• Experience designing or operating a Vulnerable Customers or Financial Difficulty programme within a UK-regulated financial services environment
• Strong knowledge of FCA Consumer Duty (PS22/9), FG21/1, and CONC, with the ability to translate regulation into operational practices
• Experience developing customer-facing scripts or communications for sensitive or regulated interactions
• Proven ability to define and manage metrics, reporting frameworks, and dashboards
• Strong cross-functional program management skills, with the ability to drive initiatives end-to-end
• Excellent written communication skills, including experience drafting policies, procedures, and board-level materials
• Experience in BNPL, Deferred Payment Credit, or high-volume consumer lending
• Familiarity with Breathing Space, Debt Respite Scheme, and vulnerability frameworks
• Exposure to credit reporting systems and their impact on vulnerable customers
• Experience supporting regulatory submissions or FCA engagement
• Understanding of the incoming DPC regulatory framework

What the job involves

• As a Vulnerable Customer (VC) Manager, you will serve as the subject matter expert at the intersection of consumer protection, regulatory compliance, and operations within a UK-regulated BNPL / Deferred Payment Credit environment
• You will own the end-to-end Vulnerable Customers program, including policy design, operational frameworks, agent experience, and reporting, ensuring alignment with FCA Consumer Duty and related guidance
• This role requires a balance of strategic thinking and hands-on execution, partnering across Operations, Compliance, Legal, and Data to deliver fair customer outcomes at scale
• This person will report to the Collections Sr. Manager
• Own and evolve Affirm's Vulnerable Customers programme, including policy, procedures, and operational frameworks aligned with FCA Consumer Duty (PS22/9), FG21/1, and CONC
• Design and maintain customer identification and flagging frameworks, including taxonomy, severity classification, and case routing workflows
• Define and manage the distinction between Vulnerable Customers and Hardship/Breathing Space programmes, ensuring clear eligibility, treatment strategies, and exit criteria
• Develop and optimize agent scripts, decisioning guides, and escalation pathways to support sensitive customer interactions and needs-based outcomes
• Partner with Operations and Training teams to embed VC practices into agent workflows, onboarding, and QA frameworks
• Own metrics, dashboards, and reporting for the VC programme, including KPI/KRI definition and board-level reporting
• Serve as the internal SME on Consumer Duty and vulnerability, translating regulatory requirements into actionable operational practices
• Monitor regulatory developments (e.g., FCA reviews, Dear CEO letters) and drive gap assessments and program enhancements
• Partner with Compliance and Legal to support regulatory engagement, including supervisory requests and policy interpretation
• Lead governance of the VC programme, including risk management, control frameworks, and audit readiness
• Drive cross-functional execution with Data, Product, and Engineering to ensure accurate system capture, reporting, and scalability

Benefits

• Compensation: We have a simple, flexible, and transparent remote-first compensation structure so you can make the best decisions for yourself and your family
• Spending Wallets: Access tech, food, lifestyle, and family planning wallets for your expenses
• Supportive Communities: Get involved with our employee resource groups and community groups
• Remote-first Workforce: If your role is remote, you can set up shop anywhere in your home country
• Generous Time Off: Take the time you need when life happens
• Health Benefits: Get a plan that fits your needs
• Mental Healthcare: Take care of your mind with great mental health programs
• Parental Leave: Birth and non-birth parents get 18 weeks’ paid leave. Plus, a 4-week return-to-work transition program, at full base pay
• Away Days: We offer 20 company-wide paid days off—which help our teams collectively pause to recharge
• Learning & Development: Engage in exciting learning programs to level up your growth