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: