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Affirm

Mid

Vulnerable Customer Manager at Affirm — owning the UK FCA Consumer Duty vulnerability program end-to-end

This is a regulated-operations role, not a general Data Analyst role: Affirm needs someone to own the Vulnerable Customers program for its UK BNPL business, translating FCA Consumer Duty (PS22/9), FG21/1, and CONC into agent-facing policy, scripts, and reporting. The interview probes regulatory fluency, program ownership, and cross-functional execution with Compliance, Legal, and Data.

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What this interview tests

  • FCA Consumer Duty (PS22/9), FG21/1, and CONC — translating regulation into operational policy
  • Vulnerable Customer identification, flagging taxonomy, and severity classification
  • Distinguishing Vulnerable Customer vs Hardship/Breathing Space treatment and exit criteria
  • Agent scripts, decisioning guides, and escalation pathway design for sensitive interactions
  • KPI/KRI definition and board-level reporting; governance, risk, and audit readiness
  • Cross-functional execution with Operations, Compliance, Legal, and Data/Product/Engineering

Common question themes

How would you design a vulnerability flagging and severity-classification framework from scratch

How do you distinguish and route between Vulnerable Customer and Hardship/Breathing Space programmes

Walk me through a policy or script you wrote for a regulated, sensitive customer interaction

How have you translated a specific FCA requirement (Consumer Duty, CONC) into an operational control

Describe a time you built or reported KPI/KRI dashboards to senior stakeholders or a board

How do you partner with Compliance and Legal during a regulatory review or supervisory request

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