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name: fintech-hr
description: Use this skill for people work specific to a regulated fintech — writing role scorecards for compliance-sensitive positions, structuring interviews that test regulatory judgment, and mapping the fit-and-proper / background-screening and accountability considerations a financial firm's hires carry. It produces hiring and people artifacts for HR and compliance to review — never employment-law advice or a regulated fit-and-proper determination.
---

# Fintech HR

> **What this is** — a repeatable, AI-assisted working method for the people work a regulated fintech actually needs: scorecards and interview structures for compliance-sensitive roles, and a map of the regulatory considerations (fit-and-proper, screening, accountability regimes) that hiring in a financial firm carries — with HR, compliance, and counsel kept in the loop.
> **What this is NOT** — **not employment-law advice, not a fit-and-proper or licensing determination, and not a substitute for HR, compliance, or employment counsel.** Hiring, screening, background checks, and terminations are governed by employment, anti-discrimination, privacy, and financial-services law that varies by jurisdiction; every artifact is a draft requiring professional review before use.
> **Fairness notice** — Any screening or assessment criterion must be job-related, consistently applied, and compliant with anti-discrimination and data-privacy law. This method flags where a criterion needs legal/HR review; it does not clear any criterion as lawful.

## When to use this
- A regulated fintech is hiring for a compliance-sensitive role (compliance, risk, trading, finance, engineering with production access) and needs a rigorous scorecard.
- An interview loop needs to actually test regulatory judgment and integrity, not just craft.
- Someone needs the fit-and-proper, background-screening, and accountability considerations for a regulated hire mapped before HR/compliance sign-off.
- A people team wants role definitions and competency frameworks that reflect a regulated environment, not a generic tech one.
- Raw people-process requirements need assembling so HR and compliance decide, not gather.

## Operating principle
AI and a repeatable structure draft the scorecards, interviews, and consideration maps; HR, compliance, and employment counsel decide every hiring, screening, and accountability question. The value is a faster, better-structured, regulation-aware starting point — never an employment-law conclusion, a fit-and-proper determination, or a hiring decision.

## Capability 1 — Regulated-role scorecards
**Goal.** Define a role's competencies and evidence so interviewers assess consistently — weighting the regulatory dimension a fintech hire carries.
**Inputs.** The role, its regulatory exposure (customer money, data, trading, advice, production access), the team, the level.
**Method.**
1. Define **outcomes and competencies** for the role, then add the **regulated-environment dimensions**: regulatory judgment, integrity/escalation instinct, control-mindedness, and comfort designing/working within constraints.
2. For each competency, specify **observable evidence** and a **rating scale**, so assessment is behavioural, not vibes.
3. Add **role-specific compliance signals** (e.g., for a compliance/risk hire: familiarity with the relevant regime; for engineering: change-control and least-privilege instincts).
4. Keep criteria **job-related and consistent** across candidates — flag anything that could function as a proxy for a protected characteristic for HR/legal review.
5. Note where the role may be a **controlled/certified function** requiring formal fit-and-proper assessment (counsel/compliance owns that).
**Output.** A role scorecard: competencies, regulated-environment dimensions, observable evidence, rating scale, and flagged review items.
**Quality bar (what the professional receives).** Competencies map to observable evidence and a consistent scale; the regulated dimension is explicit; potential fairness issues and controlled-function flags are surfaced for HR/legal — not resolved.

## Capability 2 — Regulatory-judgment interviews
**Goal.** Structure an interview that tests how a candidate reasons under regulatory and ethical pressure — not just whether they can do the craft.
**Inputs.** The scorecard (Cap 1), the role's real dilemmas, the interview loop and interviewers.
**Method.**
1. Write **scenario-based, behavioural questions** ("tell me about a time…") mapped to each competency, including at least one **regulatory/ethical dilemma** (e.g., pressure to ship past a control, an escalation someone didn't want raised).
2. Provide **calibration notes** — what a strong vs weak answer sounds like — so interviewers rate consistently.
3. Sequence the loop so competencies are **covered without overlap**, and assign each interviewer their focus.
4. Build in a **work-sample or judgment exercise** relevant to the role rather than a trivia quiz.
5. Keep questions **lawful and job-related** — flag anything straying into protected territory (age, health, family, etc.) for removal.
**Output.** A structured interview guide: questions per competency, calibration notes, interviewer assignments, and a scoring rubric.
**Quality bar (what the professional receives).** Questions are behavioural and tied to the scorecard; at least one tests regulatory/ethical judgment; calibration makes scoring consistent; unlawful or off-limits questions are flagged out.

## Capability 3 — Fit-and-proper & accountability mapping
**Goal.** Map the regulatory people-considerations a hire triggers so compliance and counsel can run the actual process — never perform it.
**Inputs.** The role, jurisdiction(s), whether it's a controlled/certified/senior function, the firm's screening and accountability policies.
**Method.**
1. Identify whether the role falls under an **accountability/certification regime** — e.g., the UK **Senior Managers & Certification Regime (SMCR)**, or analogous fit-and-proper expectations under **ASIC** (Australia), **MAS**, or **FINRA** registration/Form U4 in the US.
2. Map the **screening considerations** the role implies (background, credit, regulatory-reference, adverse-media) — as *considerations to run lawfully*, with data-privacy and consent flagged for the DPO/HR.
3. Note **ongoing accountability** artifacts a regulated role may need (statements of responsibility, conduct rules, training/attestation) as items for compliance to own.
4. Flag **cross-border** differences where the hire spans jurisdictions.
5. Route every actual determination — fit-and-proper, reference, screening outcome — to compliance and counsel.
**Output.** A considerations map: regime applicability, screening considerations, accountability artifacts, jurisdiction flags, and owners.
**Quality bar (what the professional receives).** Regime applicability and screening/accountability considerations are mapped and sourced; privacy and fairness are flagged; **no fit-and-proper, screening, or eligibility determination is made** — compliance and counsel decide and run it.

## Worked example (illustrative)
*Illustrative only — hypothetical.* An ASIC-regulated broker is hiring a Head of Compliance. The first-pass draft would: (1) build a scorecard weighting regulatory judgment, integrity/escalation, and control-mindedness alongside leadership, each with observable evidence; (2) structure an interview with a real escalation dilemma ("a senior stakeholder wanted a control relaxed to hit a launch date — walk me through what you did"), with calibration notes and a rubric; (3) map that the role likely carries **fit-and-proper** expectations and note the background/regulatory-reference screening to run lawfully — routing the actual fit-and-proper assessment and reference checks to compliance and employment counsel. Every artifact is a draft. HR, compliance, and counsel decide.

## Guardrails & escalation
- **Escalate to HR, compliance, and employment counsel:** any actual hiring, rejection, screening, background check, fit-and-proper assessment, or termination; any accommodation, dispute, or cross-border employment question.
- **Never** make a hiring or rejection decision, perform or clear a background/fit-and-proper check, or opine that a criterion or process is lawful; those are regulated, jurisdiction-specific judgments.
- **Fairness and privacy first:** flag every criterion that could disadvantage a protected group or that involves personal-data processing for HR/DPO/legal review; keep assessment job-related and consistently applied.
- **Flag uncertainty explicitly:** jurisdiction-specific employment and financial-services rules go in an "open questions for HR/compliance/counsel" section. These rules vary and change — verify against current law before use.

## References & sources
- **Structured-hiring** practice — competency scorecards, behavioural interviewing, and interviewer calibration (job-related, consistent assessment).
- **UK** — the **Senior Managers & Certification Regime (SMCR)** and FCA fit-and-proper expectations; **Australia** — **ASIC** fit-and-proper and organisational-competence expectations; **US** — **FINRA** registration and **Form U4**; **Singapore** — **MAS** fit-and-proper guidelines.
- **Anti-discrimination and privacy** frameworks governing screening and assessment (e.g., US EEOC principles; GDPR / local privacy law for background data) — as constraints requiring HR/legal ownership.
- Employment and financial-services people-rules are jurisdiction-specific and change; verify against current law and confirm with HR, compliance, and counsel before reliance.

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*Part of Ed Chen's AI skill set — how one designer absorbs unfamiliar, regulated, C-level work quickly by pairing AI with rigor and professional review. https://edwson.com*