Five Regulated Firms, Five Completely Different Finance Jobs

An insurance broker, a MiFID investment firm, an asset manager, an authorised payments institution and a cryptoasset business all sit inside the FCA’s perimeter. From the outside they look like variants of the same thing: regulated businesses whose finance teams have extra compliance to worry about. Anyone hiring across them quickly discovers otherwise. The reconciliations are different, the calculations are different, the audits are different, and — the part that catches employers out — a Financial Controller who is excellent in one of them may be genuinely unqualified for another. This article walks through what the finance function actually owns in each, and why “regulated experience” is one of the least useful phrases in a job specification.

Why the differences are larger than they look

The FCA’s perimeter covers businesses that do fundamentally different things with fundamentally different risks, and the rules follow the risk rather than the sector label. A broker holding premium on its way to an insurer faces a different hazard from an investment firm holding client cash, which faces a different hazard again from a payments institution holding funds mid-settlement.

That means the regulatory obligation is not a layer on top of a common finance job. It reshapes the job itself — the monthly cycle, the reconciliations, the year-end, the reporting audience and, in some roles, the personal accountability. The common ground is real but it is the part employers already know how to assess.

1. The insurance broker or MGA: everything turns on one concept

The defining feature of finance in an insurance intermediary is risk transfer, and it has no equivalent anywhere else in finance.

When a broker collects a premium, the money either belongs to the client, belongs to the insurer, or belongs to the firm — and which of the three it is depends on the terms of business agreement with that particular insurer. Where a written agreement confers agency, the premium is treated as received by the insurer on payment to the broker, and it may not be client money at all. Where no such agreement exists, it is client money and must be segregated under CASS 5.

The same firm routinely has both, across different insurers and different products. So the client money calculation — which determines whether the segregated balance is adequate and whether a shortfall must be made good — depends on a mapping between every balance and its risk transfer status, kept current as agreements change.

That mapping decays silently, and it is a recurring audit finding. Firms discover, some way into a CASS audit, that money they had treated as insurer money for years was client money all along, because the agreement did not say what everybody assumed. That is a historic shortfall rather than a process improvement.

Add Insurance Premium Tax, binder and bordereaux reconciliation where the firm underwrites on delegated authority, and commission recognition across instalments and mid-term adjustments, and you have a finance role that shares its job title with commercial financial control and very little else. Our full guide to finance in insurance intermediaries covers what the FC owns, where firms typically struggle, and what the roles pay.

2. The investment firm: a second job on top of the first

An investment firm’s Financial Controller does everything a Financial Controller does anywhere — and then a prudential job on top of it.

That second job means calculating own funds after deductions, determining which requirement bites (the permanent minimum, the fixed overheads requirement or the K-factor requirement), submitting returns on the regulator’s calendar, and contributing to the ICARA — the internal assessment of whether the firm holds enough capital and liquidity against the harms it could cause, plus a documented wind-down plan.

Two things about that work surprise people arriving from commercial finance. The judgement sits in unexpected places — the fixed overheads calculation, for instance, turns on what genuinely counts as a fixed overhead and what may be excluded, which is a decision the FC makes and has to defend a year later. And the hardest part is data rather than regulation: K-factors derive from assets under management, client money held and client orders handled, all of which live in portfolio management and order management systems that finance does not own. Extracting them reliably each period, and reconciling them, is frequently the heaviest recurring task in the role.

Where the firm also holds client money under CASS 7 or custody assets under CASS 6, the remit extends again. Our guide to finance in an investment firm sets out the full remit and where the difficulty concentrates.

3. Asset management: two sets of books, two different jobs

Asset management is the only one of the five where the finance function routinely accounts for two entirely separate things — and where job specifications most often blur them.

The fund side accounts for the funds, which belong to investors. Net asset value production or oversight, valuation, fee calculation including performance fees and — in private markets — carried interest and the waterfall, plus investor reporting and a fund audit with its own timetable.

The firm side accounts for the management company, which belongs to the shareholders. Management and statutory accounts, revenue recognition on management and performance fees, regulatory capital as a MIFIDPRU firm, and the firm’s own audit.

These have different reporting entities, different cycles, different audiences and different auditors. A strong financial accountant is not a substitute for a fund accountant, and the reverse is equally true. Yet a great many roles are advertised as “Financial Controller” and turn out to be eighty per cent fund accounting, or the reverse — and the mismatch is invisible on a CV.

There is a further split inside the fund side that employers rarely think to state: whether the role produces NAVs in-house or oversees an administrator’s. Those are different skills — production versus reconciliation, challenge and adviser management — and someone whose whole career has been production frequently finds oversight unsatisfying. Our guide to finance in asset management works through the fund and firm split and what to specify.

4. Payments and e-money: money you do not control

The distinguishing feature here is not the regulation. It is the flow of money.

An authorised payment institution or e-money institution holds funds belonging to customers and must safeguard them — segregated with an authorised credit institution, or covered by insurance or guarantee. The obligation is broadly analogous to client money, and it is daily.

What makes it genuinely hard is settlement. Money moves through acquirers, schemes, correspondent banks and partner institutions on timetables the firm does not control. At any given moment a meaningful balance is in flight — authorised but not settled, settled but not allocated, or sitting with a scheme over a weekend. The safeguarding calculation has to account for all of it correctly, and the timing differences are where errors accumulate. Add chargebacks reversing flows after the fact, foreign exchange, and interchange and scheme fees affecting both revenue and the customer obligation, and the daily reconciliation becomes a real operational discipline.

This sector also produces the single most common mis-hire in regulated finance, and it is worth naming precisely. A large share of businesses describing themselves as fintechs operate as agents or distributors of an authorised principal firm. They do not safeguard anything, because the principal does. Their finance people have therefore never performed the obligation the hiring firm needs. The CV looks right, the sector matches, and the experience is absent.

The question that prevents it takes ten seconds: was your firm authorised, and did it hold relevant funds? Our guide to finance in a payments or e-money firm covers the full remit and how to specify the role.

5. Cryptoasset firms: the newest and least settled

Cryptoasset finance combines conventional financial control with obligations that resemble client money without being governed by it, and valuation questions where practice has not settled.

The perimeter question comes first and is regularly assumed rather than established. A firm may be registered for anti-money-laundering supervision as a cryptoasset business, may hold e-money or payments permissions for the fiat side of its operation, may be authorised for regulated activities where its products fall inside the perimeter, or may sit largely outside it. The same group frequently holds several, and each produces a different set of finance obligations.

The operational discipline is reserve and client asset reconciliation: demonstrating daily that what is held matches what is owed to customers. That means reconciling on-chain balances across wallets and custodians, exchange and venue balances, and fiat held at banks — against the customer liability in the firm’s own systems. Those live in a blockchain explorer, a custodian’s portal, an exchange API and a ledger, none of which agree on timing or granularity.

Then the accounting judgements, which are genuinely unsettled: how holdings are classified and measured, the distinction between own and customer assets, revenue recognition on spreads and staking arrangements, and the volatility between reporting date and sign-off. Auditors are still developing their approach, and firms should expect to be asked for evidence of control over keys as well as over balances. Our guide to finance in a cryptoasset firm covers the remit and where firms most often struggle.

What actually transfers between them

Having drawn the distinctions, it is worth being clear about the common ground, because employers over-correct in both directions.

What transfers well: the mindset that customer assets are not the firm’s, and the discipline of daily proof. Someone who has genuinely owned a CASS 7 reconciliation understands what safeguarding is trying to achieve, even though the rules differ. Payments and e-money experience transfers into cryptoassets for the same reason. And general financial control — the close, the balance sheet, the audit, the team — transfers everywhere, because it is roughly seventy per cent of every one of these jobs.

What does not transfer: the specific calculations, the reportable-breach judgement, and the sector accounting. A CASS 7 specialist does not know risk transfer. An investment firm FC does not know bordereaux. A payments FC does not know the waterfall. Those are learnable, but not learnable safely by someone who is the firm’s only finance resource.

The practical consequence for hiring

Three things follow, and they are cheap to implement.

Name the regime and the model in the advert. “CASS 5 client money, non-statutory trust, mixed risk transfer” reaches a small and correct pool. “Experience in a regulated environment” reaches everybody and filters nobody — and produces a shortlist you then have to disqualify at interview.

Ask the authorisation question at screening, before anything else. It costs ten seconds and prevents the sector’s most expensive mistake.

And decide who could check the work. This is the question that actually matters, and it is more useful than asking whether the candidate knows the regime. Where there is genuine expertise elsewhere in the firm — a compliance lead, an engaged adviser, an existing specialist — a capable candidate from an adjacent regime with strong control discipline is frequently the better and faster appointment. Where there is not, and the role is the sole finance resource, that is the configuration in which problems go unnoticed longest, and the specific experience is worth waiting for.

The thread running through all five

One pattern appears in every sector on this list, and it is the reason a large share of regulated firms come to the market at all.

In each of these businesses, the specialist knowledge concentrates in one person. They built the reconciliation, they know why each judgement was made, and none of it is written down. The firm functions perfectly well — right up until that person is unavailable in the wrong week, or leaves.

That is a business continuity problem before it is a hiring problem, and the first response is not always recruitment. Getting the methodology documented to the point where a competent outsider could follow it costs nothing, makes any eventual hire considerably easier, and is precisely what the audit will ask about. It is also, in my experience, the single most consistently neglected thing in regulated finance functions of every size.