About the role
Affirm is reinventing credit to make it more honest and friendly, giving consumers the flexibility to buy now and pay later without any hidden fees or compounding interest. Affirm is committed to building lasting partnerships with merchants for long term growth and ongoing revenue generation. 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. What you’ll do 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 What we look for: Essential: 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 Preferred: 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
