The Lending Standards Board (LSB) have published updates to the Contingent Reimbursement Model Code for Authorised Push Payment (APP) scams (the CRM Code), following their full review of the Code earlier this year.
The first full review of the Code, published in January 2021, set out a series of recommendations to be taken forward by the LSB and stakeholders, to ensure that the Code and the consumer protections which sit at the heart of it, work effectively. In order to drive consistency of application of the Code across the industry, we identified that the Code should set out expectations around governance arrangements and related controls to ensure that it is embedded within the culture of Code signatories, from senior management through to customer facing staff.
The updates, published today, include the introduction of governance and oversight requirements into the Code. The new provisions will support embedding and ongoing oversight of the Code’s requirements as well as ensuring that Code related policies and processes are formalised and customer facing staff have greater awareness of the Code. These provisions will be effective from 14 June 2021.
Emma Lovell, Chief Executive says: ‘The introduction of the governance and oversight provision will set out a clear framework to ensure that the Code is embedded within the culture of a firm – an area both the Code review and our oversight work has identified as being critical to improving the outcomes for customers.’
Amendments have also been made to the wording of the Code in respect of the no-blame funding pot. References to the no-blame fund now makes it clear that firms are able to self-fund no-blame scam cases. These amendments are effective immediately.
The updates to the Code form part of a range of activity that the LSB is undertaking following their review, including a further Call for Input and a follow up review of provision R2 1(c) – approach to reimbursement of customers, the outcomes of which will be published later this year. Further information about this activity is set out in the LSB’s roadmap.
