Articles and Updates

GLIDDON James 3x3DANKS Felicity 3x3 2018Two recent High Court cases have offered clarity as to when a wide range of material relied on and referred to in proceedings can be accessed by third parties. James Gliddon, Partner and Felicity Danks, Trainee Chartered Legal Executive, provide further insight.

jagOn 28 May 2019, the Contingent Reimbursement Model (CRM) Code for Authorised Push Payment (APP) fraud will come into effect.

When the code goes live, alongside the Practitioners' Guide (due to be published by the Lending Standards Board shortly), it will provide a new landscape for payment services providers (PSPs) in their dealings with customers who are victims of APP fraud.


As we have explored in previous articles, the Contingent Reimbursement Model (CRM) code sets standards expected of participant payment service providers (PSPs) and lays out a framework for reimbursing victims of Authorised Push Payment Fraud (APP) fraud.


So far in this series of articles on the CRM code (see here), we've looked at the code's key principles and the standards it sets for firms to help prevent Authorised Push Payment (APP) fraud.

Of course, the real focus of the CRM code is the reimbursement of defrauded customers.

jagMy last article (here) looked at the development of the CRM code, its purpose in dealing with Authorised Push Payment Fraud (APP) and the principles underpinning the scheme.

In this second piece I want to explore the standards it sets for those payment service providers (PSPs) who have committed to the code and how those standards may affect the landscape for all PSPs when they respond to APP fraud.

la3The FCA has published its Business Plan for 2019/20. It comes as no surprise following a number of recent high-profile IT failures that the FCA has committed during the next 12 months to review how firms use third-party IT suppliers. As noted by the FCA, between October 2017 and September 2018, 17% of the incidents reported to the FCA by firms were caused by IT failure at a third party-supplier.

cnOn 18 March 2019, Canada became the 104th member of the Madrid System bringing the total number of countries covered by the system to 120 countries. The protocol for Canada will come into effect on 17 June 2019. Canada, the world's 10th largest economy, is the last of the G8 countries to enter into the Madrid System.

ah2The Financial Ombudsman Service recently published its latest statistics about the types of complaints received and upheld. PPI still tops the charts and there has also been coverage of increases in complaints in other areas, for example SIPPs. Many of these complaints are brought with the "assistance" of claims management companies who themselves will be regulated by the FCA by 1 April 2019. The growth in the claims management industry has been accelerated by the PPI mis-selling scandal and it is in the nature of the industry that it must constantly be looking for the 'next big thing'.