Consultation Paper
CP17/24**
July 2017
Information about current account services
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Financial Conduct Authority
Information about current account services
We are asking for comments on
this Consultation Paper (CP) by
25 September 2017.
You can send them to us using
the form on our website at:
www.fca.org.uk/your-fca/
documents/consultation-papers/
cp17-24-response-form.
Or in writing to:
Rebecca Langford
Banking and Payments Policy Team
Financial Conduct Authority
25 The North Colonnade
Canary Wharf
London E14 5HS
Telephone:
0207 066 0532
Email:
cp17-24@fca.org.uk
How to respond Contents
1 Summary 3
2 The wider context 7
3 Considering the case for additional
service information 10
4 Changes to the Banking Conduct
of Business sourcebook 15
5 Discussion of metrics we are not pursuing 33
6 Next steps 37
Annex 1
Questions in this paper 38
Annex 2
Cost benet analysis 40
Annex 3
Compatibility statement 47
Annex 4
Stakeholder expert group 52
Annex 5
Metrics considered 53
Annex 6
Abbreviations used in this paper 60
Appendix 1
Draft rules and guidance
returns you to
the contents list
takes you to helpful
abbreviations
How to navigate this
document onscreen
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1 Summary
Why we are consulting
1.1 These proposals seek to promote effective competition by enabling customers to
make effective comparisons between providers of personal current accounts (PCAs)
and business current accounts (BCAs) based on service, and by incentivising providers
to improve service and performance.
Who this applies to
1.2 This consultation paper (CP) affects the majority of current and potential participants
in the PCA and BCA markets as well as those interested in this market.
1.3 The CP applies to firms that accept deposits (banks and building societies) and provide
payment accounts as defined by the Payment Accounts Regulations
1
(typically PCAs)
or BCAs that have the features of a payment account. These firms should read the
whole consultation.
1.4 Organisations which offer comparison services are encouraged to read the whole
consultation and to respond to questions 7 - 10.
1.5 This CP will be of interest to PCA and BCA customers. While we do not expect
customers to read this paper in full, organisations representing consumers may
want to read the summary of the consultation.
The wider context of this consultation
1.6 In its retail banking investigation final report
2
the Competition and Markets Authority
(CMA) recommended that we require firms to publish objective measures of service
performance for both PCAs and BCAs, in addition to the core service quality indicators
it will require the largest current account providers to publish. We committed to
consider doing so, where the evidence supported this and the measures advanced our
objectives.
3
1 http://www.legislation.gov.uk/uksi/2015/2038/pdfs/uksi_20152038_en.pdf
2 https://assets.publishing.service.gov.uk/media/57ac9667e5274a0f6c00007a/retail-banking-market-investigation-full-final-report.pdf
3 November 2016, FCA response to the CMA’s recommendations following its investigation into retail banking.
www.fca.org.uk/publications/corporate-documents/our-response-cma-investigation-competition-retail-banking-market
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What we want to change
1.7 Information available to customers about the service provided by individual firms is
rarely provided in a consistent manner that allows comparison between firms. We want
to make it easier for customers to access and assess information about providers’
service, enabling them to make informed comparisons and choose the provider that
best suits their needs. We also want to incentivise BCA and PCA providers to improve
their service and performance.
1.8 To achieve this we propose to require BCA and PCA providers to publish service
information in the following categories:
• Account opening – clear information about the account opening process and
information about how long it takes to open an account and gain access to specied
services including overdraft funds (see paragraphs 4.40-4.55)
• Time taken to replace a lost, stolen or stopped debit card and to organise third party
access to a PCA under a power of attorney (see paragraphs 4.56-4.75)
• Service availability – identifying how and when various services can be accessed and
whether 24-hour help is available for certain matters (see paragraphs 4.76-4.83)
• Major incidents – information about the number of major operational and
security incidents that rms have reported to the FCA, by channel (see paragraphs
4.84-4.88)
1.9 The service information we propose to require firms to publish includes both:
• standing data – information rms will be required to publish and keep up to date, for
example about the times of day when certain services are available
• service metrics – things that we will require rms to measure or count and publish
every quarter
Other proposals
1.10 We propose to require firms with more than 70,000 relevant PCAs or 15,000 BCAs
(held by “banking customers” as defined for the purposes of BCOBS) to publish
this service information. These thresholds apply per brand. We do not consider it
proportionate to require firms to publish service information for smaller brands.
However, if they choose to publish service metrics they will need to comply with those
rules to ensure meaningful and consistent comparisons (see paragraphs 4.13-4.18).
1.11 So that customers and digital comparison services can access service information
we propose that firms should publish it on their website. We also want firms to make
the information available via Application Programming Interface (API) and propose to
require firms that are part of Open Banking and all firms in scope of the rules which use
an API for the purposes of PSD2 to also to make the information published under our
rules available through an API (see paragraph 4.23-4.28).
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1.12 We propose that the service metrics should be measured quarterly (beginning in
April 2018) and published within six weeks of the end of each quarter. Depending on
the outcome of this consultation, we will aim for the first publication of the metrics
to coincide with firms’ first publication of the core indicators required by the CMA in
August 2018 (see paragraphs 4.29-4.32).
1.13 We propose not to require service information in a number of areas, including
subjective service quality measures, measures related to fraud, and information
specific to BCAs - for example regarding relationship managers. We are not pursuing
these because our research and analysis suggested that they may duplicate the core
CMA service indicators, not be motivating to customers, not be practical to measure,
or result in unintended consequences. While we are not proposing service information
requirements in these areas now, we will reconsider this in the future if evidence
suggests we should. For further information about service information we are not
pursuing see Chapter 5.
Unintended consequences of our intervention
1.14 In designing our proposals we have considered possible unintended consequences and
these are outlined in this CP. We have sought to be proportionate in designing these
remedies and we are neither proposing that they apply to all firms nor all aspects of
service. The rules we are proposing relate to areas of service that our research tells
us matter to customers. We are mindful that introducing service metrics for some
services and not others may impact the attention that firms pay to ensuring the quality
of other services that are not subject to metrics. We consider that the CMA core
service quality indicators (for those firms which are subject to the CMA’s requirements)
will mitigate this since they focus on overall brand perceptions.
1.15 We are aware that not requiring the smallest firms to provide service information and
not applying rules to certain providers, including credit unions could potentially distort
competition. We propose that if these firms wish to compete by publishing the same or
similar service metrics, they must comply with the relevant rules.
1.16 We will monitor whether publication of service information causes unintended
consequences.
Outcome we are seeking
1.17 We want to improve competition in the current account market by:
• making it easier for customers to make informed comparisons and choose the
provider that best suits their needs based on service, and
• incentivising BCA and PCA providers to improve their service and performance.
1.18 We consider that we will achieve this if the following conditions are met:
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• rms comply with requirements to publish meaningful and comparable service
metrics
• customers access and assess the information about providers’ service when
choosing an account
• digital comparison services and the media use the published metrics to draw
attention to the service oered by providers
• there is competitive pressure from market commentary, and
• rms respond to the pressure of reputational damage caused by indications of
providing worse service than their competitors by taking steps to improve service.
Measuring success
1.19 We will gather baseline information about customers’ attitudes and behaviour related
to service information and switching in 2018. We will also interview digital comparison
services to understand their role in distributing service information to customers, and
track media coverage.
1.20 We will repeat this exercise as part of a post-implementation review, expected to take
place in 2019/20, to assess the impact of the changes we make.
Next steps
1.21 The consultation period for this CP is two months. We consider this shorter
consultation period is appropriate as we have engaged with stakeholders, including
firms, extensively as we developed our proposals, and it will allow firms more time for
implementation. Subject to the outcome of the consultation, we would aim to have
rules in place to require the first publication of additional service metrics in August
2018 to coincide with the first publication of the core CMA service quality indicators.
1.22 Please send your response to this CP by 25 September 2017. To submit a response,
please use the online response form on our website or write to us at the address on
page 2.
1.23 If, having considered the feedback to this CP, we propose to make rules we would plan
to publish a Policy Statement later this year.
1.24 We may consider introducing additional service information requirements in the future
should there be evidence that this would benefit customers and improve competition.
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2 The wider context
The harm we are trying to address
2.1 The CMA’s retail banking market investigation found that there are barriers to
accessing and assessing information about service quality, which contributes to low
customer engagement in the current account market. This may result in harm as
customers may receive poor value by staying with products that are not best suited to
their needs or do not provide good quality service.
The CMA’s package of remedies
2.2 The CMA identified several remedies which are intended to work together to tackle the
underlying problems identified in the PCA and BCA markets by:
• enabling customers to make reliable comparisons between providers
• ensuring customers can compare the service quality of existing and prospective
providers by requiring rms to make available:
–
information about customers’ willingness to recommend their service to others
–
operational performance metrics with respect to PCA and small and medium-
sized enterprise (SME) banking services, and
–
promoting engagement by prompting customers to consider their banking
arrangements and take appropriate action.
2.3 The CMA is implementing a number of these remedies itself, but has also made five
broad recommendations to the Financial Conduct Authority (FCA). These include
a recommendation that we consider requiring operational performance metrics
(the subject of this consultation), work on Open Banking, designing prompts and
alerts to encourage consumers to consider their banking arrangements, reviewing
the Maximum Monthly Charge for unarranged overdrafts and delivering a more
competitive market for SMEs. Our response to the CMA’s final report outlines the
recommendations the CMA made to the FCA and our response.
4
2.4 The CMA has made an Order which requires the largest PCA and BCA providers to
publish core service quality indicators.
5
Firms will publish results in their branches, on
their websites and in leaflets. These core measures of quality are based on customers’
willingness to recommend their bank’s services to friends, family or colleagues or other
SMEs. They will be measured every six months by an independent survey required by
the CMA with the first set of results due to be published by firms in August 2018. As
4 November 2016 www.fca.org.uk/publications/corporate-documents/our-response-cma-investigation-competition-retail-banking-
market
5 https://www.gov.uk/government/publications/retail-banking-market-investigation-order-2017
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discussed at paragraph 1.6, the CMA asked the FCA to consider whether we should
require firms to publish additional objective measures of service performance. This CP
outlines our proposals on this and how we consider them to further our objectives.
How it links to our objectives
2.5 The action we are taking to consider each of the CMA’s recommendations is intended
to advance our statutory objectives, which are broader than the CMA’s remit.
Competition
Requiring the provision of additional service information will improve customer
engagement in the current account market.
2.6 Improving the availability of meaningful and comparable information about service will
make it easier for customers to make informed comparisons and choose the provider
that best suits their needs based on the quality of their service.
2.7 More engaged customers and reputational pressure from publishing service
information should drive providers to improve service and performance to retain
existing and attract new customers.
Consumer Protection
Requiring the provision of additional service information will lead to provision of
services that are better suited to meeting consumers’ needs
2.8 While not directly focussed on our consumer protection objective, as a result of
our intervention we expect to see provision of services that are better suited to
consumers’ needs, for example as providers adjust the service availability and contact
routes they offer.
2.9 Where we require provision of service information to advance our competition
objective, the FCA and other regulators may also be taking action in other ways to
protect consumers, for example in relation to reducing harm arising from major
incidents, fraud and aspects of access to financial services.
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What we are doing
2.10 We are proposing rules that would oblige firms to publish information about service for
PCAs and BCAs. The following chapters provide more information on our reasons for
doing this and the detail of our proposals:
• Chapter 3: Considering the case for additional service information
• Chapter 4: Changes to the Banking Conduct of Business sourcebook
• Chapter 5: Discussion of metrics we are not pursuing
• Chapter 6: Next steps
Equality and diversity considerations
2.11 We have considered the equality and diversity issues that may arise from our
proposals.
2.12 Overall, we do not consider that the proposals adversely impact any of the groups with
protected characteristics under the Equality Act 2010 but we will continue to consider
the equality and diversity implications of the proposals during the consultation period.
We will also revisit them when publishing the final rules.
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3 Considering the case for additional
service information
3.1 As discussed in paragraph 2.4 the CMA will require firms to publish core service quality
indicators. These will be based on a survey that asks customers how willing they are to
recommend their bank’s services to friends, family or colleagues or other SMEs.
3.2 The CMA recommended that we require firms to publish additional objective measures
of service performance. Having undertaken research and analysis we have decided to
pursue the publication of additional objective service information, as we consider that
doing so will advance our operational objective to promote effective competition.
3.3 In this section we outline the consultation, research and analysis we have undertaken
to come to this conclusion. We also explain why we consider requiring publication of
additional objective service indicators will advance our objectives.
Process
3.4 In summary, our process to consider additional service information included five
stages:
• Review of existing evidence – to analyse the likely eect on customers of consistent
service information, and to develop a long-list of options.
• Establishing a stakeholder expert group – to prioritise and reduce the options to a
shortlist and understand how metrics would be used by rms/intermediaries and
communicated to customers.
• Qualitative consumer research – to get customer views on shortlisted options, and
identify any alternatives.
• Discussions with rms – to understand the potential eects on rm behaviour of
such publication, and their capability to deliver the metrics.
• Analysis of evidence and deciding to pursue publication of additional metrics.
3.5 We provide more detail on each stage of this process below.
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Review of existing evidence
3.6 We began by reviewing a considerable amount of existing research and evidence.
This included the CMA’s final report into competition in the retail banking market
6
and
additional information gathered by the CMA on the service information that firms
already collect for internal monitoring purposes. Whilst not directly related, we also
looked at experience of service-disclosure interventions by other regulators, and
experience from FCA interventions requiring data publication, such as on complaints,
the cash savings sunlight remedy, and general insurance claims. We also considered
published research on consumer attitudes to service in relation to bank accounts.
3.7 This review of existing evidence helped us to understand the pros and cons of different
approaches and to develop a list of potential metrics to discuss with stakeholders as
we developed our proposals. It also helped to shape our qualitative research.
Stakeholder expert group
3.8 Acknowledging the complexity of developing industry-wide metrics for services,
we established an external stakeholder expert group (SEG) of consumer and SME
representatives, digital comparison services, service experts, other regulators and a
trade body to inform our consideration of what service quality information could be
made available and how it might be used.
3.9 The SEG considered a long-list of over 90 service information items suggested from
our research and by stakeholders, including items already collected by firms for
internal monitoring purposes, and additional items suggested by SEG members. The
full list of metrics considered is available in Annex 5. Detailed feedback from members
on likely customer and intermediary use, credibility, and interaction with the core
CMA indicators was consistent with findings from our review of existing evidence.
It highlighted what information would most likely be used by customers, digital
comparison services and commentators. It showed that some metrics duplicated
the CMA core indicators, while others could complement them and contribute to
competition in the interests of customers.
3.10 A list of SEG member organisations is available in Annex 4 of this CP. The SEG’s views
are included in our discussion of our proposals in this CP.
Qualitative consumer research
3.11 After considering the views and evidence provided by the SEG, we commissioned
qualitative research into a short-list of over 30 service metrics. The results of the
research are published alongside this report.
7
The research aimed to:
• test customers’ understanding of a short-list of service indicators and their power
to motivate them to consider switching or trying a new current account with another
provider, and
6 https://assets.publishing.service.gov.uk/media/57ac9667e5274a0f6c00007a/retail-banking-market-investigation-full-final-report.pdf
7 www.fca.org.uk/publications/search-results?live_c=1
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• test, by dierent areas of service, customers’ preferences for dierent types of
information (eg number of events or duration of events; national average gures or
data about local service).
3.12 The research included ten focus groups with PCA holders, and three workshops and 37
in-depth telephone interviews with SME BCA holders. The research also included eight
face-to-face in-depth interviews with individuals deemed to have additional needs with
regards to their current account. A total of 155 respondents were engaged.
3.13 Participants were asked what was important to them about their current account. They
were also asked to reflect on the CMA core service quality indicators. The research
then tested 34 possible metrics
8
categorised into six groups:
• Communicating with the bank
• Technical service reliability
• Ease of opening an account
• Resolution of issues
• Complaints
• Local branch oering
3.14 The short-list of areas of service and indicators tested in the research was created by
us based on views of the SEG and findings from our review of existing evidence.
3.15 Our qualitative research backs up the views of experts in our SEG that customers value
good service and would be willing to switch account to get it. While some assume ‘all
banks are the same,’ this perception is challenged when they learn about the service
available from other providers. However, often this information is not provided and
when it is available it is rarely provided in a consistent manner that allows comparison
between firms.
3.16 BCA and PCA customers had similar views on what service information they wanted
to see. They considered the CMA core metrics a “useful starting point to understand
which banks were performing.” However, they also wanted to see objective measures
of the service they could expect to receive. They were more interested in measures of
service that were important to them than in aspects of service that they did not expect
to experience. Areas of particular interest were:
• Eciency of response
• Service stability
• Accessibility (particularly out-of-hours)
• Speed and exibility of opening an account.
8 Eight of which were specific to SME audiences and only tested during telephone interviews with this group.
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3.17 Customers expect to access service information through digital comparison services
and the media. They expect to use information about service to choose an account.
They also think this information could prompt them to consider switching or trying
another account. Once engaged, they might seek out further information on a firm’s
website.
Discussions with banks and building societies
3.18 We have engaged with banks and building societies individually and by participating
in a series of roundtable meetings with them to discuss potential effects on firms’
behaviour of data publication, and their capability to deliver the additional measures of
service we are proposing. We have also discussed our proposals with trade bodies of
impacted firms.
3.19 These conversations showed that challengers are competing on service in the areas
of interest to customers and there is sufficient differentiation in service to warrant
publication of metrics. Service metrics in these areas would enable customers to
choose their account provider based on its performance, and this along with broader
reputational considerations would encourage account providers to improve their
service.
Decision to propose publication of additional metrics
3.20 The CMA’s retail banking investigation found that there are barriers to accessing
information about service quality which contribute to low consumer engagement in
the current account market. This adversely affects competition in the retail banking
market. Throughout our evidence gathering and consultation process we have seen
a broad and on-going consensus that requiring firms to publish additional service
information alongside the CMA core indicators of service quality will help address this.
3.21 Publication of additional service information will advance our operational objective to
promote effective competition by making it easier for customers to access and assess
information about providers’ service, enabling them to make informed comparisons
and choose the provider that best suits their needs. More engaged customers and
reputational pressure from publishing service information should incentivise BCA
and PCA providers to improve their service and performance to retain and attract
customers. Commonly defined service metrics may be particularly relevant and useful
for smaller banks or building societies that cannot take part in the CMA core service
quality indicator survey and could help them to compete.
3.22 Throughout the process outlined above we considered over 90 service indicators
proposed by stakeholders against a range of criteria including:
• Relevance to customers: to consider whether customers will be suciently
interested in the service information
• Relevance for challengers and smaller banks and building societies: to ensure that
metrics would be adequately relevant and useful for challengers, particularly given
their exclusion from the CMA core indicators
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• Relevance to intermediaries: to assess whether intermediaries are likely to use the
proposed service metric in their comparison tools or publications in a way that is
useful for customers
• Dierentiability: to assess whether variation between providers would be of
signicance to customers
• Duplication: to ensure that the proposed metrics do not duplicate information that
is already available or will be available elsewhere
• Unintended consequences: to consider if there are risks that the proposed metric
could lead to unintended consequences leading to detriment to competition, rms
or the market
• Proportionality: to ensure that the metrics are feasible for rms to measure and the
costs are reasonable relative to the benet to customers.
3.23 As a result we propose that firms should publish service information related to the
following aspects of service in this consultation. Unless otherwise stated we propose
to require this information to be published for both PCAs and BCAs:
• Account opening – clear information about the account opening process and
information about how long it takes to open an account and gain access to specied
services including overdraft funds (see paragraphs 4.40-4.55)
• Time taken to replace a lost, stolen or stopped debit card and to organise third party
access to a PCA, under a power of attorney (see paragraphs 4.56-4.75)
• Service availability – identifying how and when various services can be accessed and
whether 24-hour help is available for certain matters (see paragraphs 4.76-4.83)
• Major incidents – information about the number of major operational and security
incidents that rms have reported to the FCA, by channel (see paragraphs 4.84-
4.88).
Q1: Do you agree with our analysis that we should require
publication of service information?
Q2: Doyouagreethatrmsshouldpublishservice
information related to the areas of service outlined? Are
there any other areas we should consider (bearing in mind
our discussion of metrics we are not pursuing in Chapter
5)?
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4 Changes to the Banking Conduct
of Business sourcebook
Introduction
4.1 In this section we consult on new rules in BCOBS to require the publication of additional
service information about:
• Account opening
• Time taken to replace a debit card, and to give a third party access to a PCA under a
power of attorney
• Service availability
• Major incidents
4.2 We discuss the application of the proposed rule changes, including the products and
firms within scope of our rules.
4.3 We also discuss distribution (how we will require firms to make information about
service available to customers) and the timing and frequency (when we expect new
rules to commence and the frequency with which we expect firms to publish service
information).
4.4 We seek feedback from interested stakeholders, particularly customer
representatives, impacted firms and digital comparison services.
Application of proposed rule changes
Products within scope of our rules
4.5 Our main banking rules are in BCOBS. They apply to a range of accounts such as
current accounts and savings accounts. They apply to a range of defined banking
customers, including individual consumers, micro enterprises
9
and charities which have
an annual income of less than £1 million.
4.6 We are confident that BCOBS covers broadly the right banking customers for the
purposes of these rules but, at this time, want to restrict their application to PCAs and
BCAs.
9 An enterprise which: (a) employs fewer than 10 persons; and has a turnover or annual balance sheet that does not exceed
2 million Euros.
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4.7 Despite PCA and BCA being common terms used by both firms and customers,
they are currently not defined in BCOBS or in legislation. We are therefore adopting
a definition of a PCA based on the definition of a ‘payment account’ in the Payment
Accounts Regulations 2015 (PARs). This includes PCAs and basic bank accounts as
well as instant access savings accounts and current account mortgages, where they
are used in a way that is similar to a current account (that is, for day to day payment
transactions).
10
However, we propose to exclude current account mortgages as we
consider that including these might distort the service information that firms report,
making it less relevant to current account customers.
4.8 Our work will allow customers to compare similar current accounts held by the majority
of each provider’s customers. We are aware that a small minority of PCA customers
get preferential service on their account, for example because they have a high
balance or monthly income. We do not want to include these customers in our service
information and metrics because they could skew them to show better performance
than most PCA customers can get.
4.9 In order to ensure fair comparison we therefore propose to define and exclude
‘premium service accounts’. We propose to define such accounts as PCAs which have
eligibility criteria relating to minimum balances or minimum monthly deposits (or both)
whose holders receive better service than non-premium service accounts, based
on any of the service information we propose to require firms to publish. An account
cannot be a premium service account if it is held by 10% or more PCA customers. For
example, an account which has staff available to respond to relevant queries through
telephone banking for more hours of the day than other accounts, or whose account
holders can replace a lost debit card more quickly than other accounts, would be a
premium service account if it is not held by 10% or more of the firm’s PCA customers.
4.10 An account may only be a “payment account” for the purpose of the PARs if it is held
by a “consumer”. As a business user is not a consumer, we propose to define a BCA as
an account which would be a PCA if the account holder were a consumer. Further, we
propose to align our rules with BCOBs, so that only BCAs held by “banking customers”
will be subject to our rules.
Q3: DoyouagreewithPCAsandBCAsbeingdenedby
referencetothedenitionof“paymentaccount”inthe
Payment Accounts Regulations 2015?
Q4: Do you agree that ‘premium service current accounts’
should be excluded from PCA service information?
4.11 There are other accounts that sit outside BCOBS, for example accounts provided by
e-money and payment institutions which are similar to current accounts. There may
be benefits to competition of making information about service quality available to
customers with those accounts. However, our rule making powers do not currently
extend to the providers of such accounts.
4.12 We will monitor the impact of introducing service information for current accounts. If
we consider there could be consumer and competition benefits to requiring service
information to be published for other products such as mortgages, savings accounts
10 We have issued guidance to help firms decide if an account they offer is a Payment Account. www.fca.org.uk/publications/finalised-
guidance/fg16-6-payment-accounts-regulations-2015-definition-payment-account
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that are not payment accounts (as defined by PARs) or insurance, we may consider
doing so.
Providers within scope of our rules
4.13 We propose that firms measure and publish information about each of their brands
separately, as this is the basis on which customers will identify providers. By ‘brand’ we
mean the trading name notified to the FCA.
4.14 We have analysed data related to firms’ market share to consider which firms should
be in scope of our rules. We are unable to publish details of this analysis as this is
commercially sensitive information. The data available to us suggest that it is not
appropriate to require firms with fewer than 70,000 PCAs in a brand to publish
information about their PCA service under that brand, or fewer than 15,000 BCAs in
a brand to publish information about BCA service under that brand. These thresholds
differ from those set by the CMA. For PCAs our proposed PCA definition (as discussed
in paragraph 4.7-4.9) is wider. For BCAs, we propose a narrower application of our
rules, in line with the existing application of BCOBS – limited to micro enterprises and
to charities whose annual turnover is less than £1 million. The CMA’s thresholds are
measured separately for Northern Ireland and Great Britain and cover only active
accounts, while ours relate to all accounts in scope and cover the whole of the UK.
4.15 We consider that the thresholds proposed above will encompass a wide range of
account providers, including challengers, and that this will increase the availability
of information for customers and lead to increased competition in the interest of
customers. We understand that these thresholds will capture firms that are actively
competing for PCA and BCA customers, including all of the firms in scope of the
CMA core indicators plus others which have fewer active accounts than the CMA’s
threshold. We consider that it would not be proportionate to require firms with fewer
accounts than our proposed thresholds to publish service information and metrics.
4.16 Firms with fewer accounts than our proposed threshold may wish to compete on
service in the current account market by publishing information which is the same or
similar to one or more of the service metrics we are requiring larger firms to publish.
However, if they choose to publish information which is within scope of any of the
service metrics (not standing data), we propose that they are required to comply
with the rules as if they did have the requisite number of accounts and are required
to publish all aspects of the metric concerned. For example, if choosing to publish
information about time taken to replace a debit card (see paragraph 4.67-4.69) they
would be required to publish same day, average and 99% response times for the same
quarterly reporting period. This is to ensure a fair and consistent comparison between
firms. We will monitor the impact of these proposals on competition.
4.17 Where firms have fewer than 70,000 PCAs or 15,000 BCAs but later meet this
threshold, we propose that they will not be required to measure service information
for two quarterly reporting periods. This will allow time (at least six months) for them
to introduce the required measuring and reporting capability. For example, if in quarter
one a firm reaches the threshold, it will be required to start measuring metrics and
publishing service information in quarter four. Where a firm, having previously met the
threshold, no longer meets the threshold, they will no longer be required to publish
service information and metrics for any quarter after the one during which they fell
below the threshold.
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4.18 We propose that customers of overseas branches and customers whose
correspondence address is overseas will be excluded from these rules. The service
these customers receive may not be comparable with customers in the UK - for
example it may take longer for firms to send a debit card to them - and we do not
want to reduce the comparability of the service information that firms with a large
overseas presence provide. We also propose to exclude credit unions from the rules,
as providing service information is unlikely to be proportionate since membership
requirements restrict customers’ ability to choose their credit union.
11
Q5: Do you agree with the proposed application of the rules?
In particular do you agree with the providers, customers
and products in scope of the rules?
Q6: Do you agree with the proposed threshold? Do you agree
that providers below the threshold which choose to
publish the same or similar service metrics must comply
with the relevant rules?
Distribution
4.19 We have considered how service information should be made available to customers.
The options we considered have included: requiring firms to report performance
against service indicators to the FCA for publication on the FCA’s website; requiring
firms to make information available directly to customers and digital comparison
services on their own websites; and requiring firms to make information available for
distribution by APIs.
Our research
4.20 Our consumer research found that customers are interested in service and would
consider service information if it were presented to them by digital comparison
services, financial commentators or the media. Currently, the larger, better known
digital comparison services that provide comparisons for financial services (for
example, insurance, credit and banking products) do not compare providers on the
quality of their bank account service. We understand this is due to the lack of regular,
comparable information and that digital comparison services would use new regulated
service information to rank or recommend current accounts and draw attention to
varying levels of service between brands in one place.
4.21 Research in behavioural economics tells us that consumers can find multiple indicators
difficult to assess and compare.
12
We have been mindful of this and are proposing
to require service information only in a handful of areas that are of most interest to
customers. However this still necessitates multiple indicators. There is an important
role for digital comparison services to bring the service information we propose
to require together in a useful, engaging and meaningful way so that it is easy for
customers to access and compare. Doing so would allow customers to compare
accounts based on their own preferences and account usage, going beyond current
comparisons based on price.
11 www.fca.org.uk/publication/forms/mutuals-cu-common-bond-specimen-wording.doc
12 See, for example, ‘Price Lab: An investigation of consumers’ capabilities with complex products’, which can be accessed here:
www.esri.ie/pubs/BKMNEXT306.pdf
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4.22 We are aware that people who are digitally excluded are unlikely to access service
information online. However, we consider that these customers will still benefit
from our proposals. We expect service indicators to be of interest to financial
commentators and the media and that commentary about service quality will appear
in off-line publications. Firms may also choose to use published service metrics in their
marketing. Further, as discussed in paragraph 2.7, we consider that publishing service
information will result in improvements in firms’ service that will benefit all customers.
We will monitor the distribution of the impacts of requiring publication of service
information, including for digitally excluded customers.
Our proposal
4.23 Publishing service information will make it easier for customers to compare accounts.
We expect intermediaries including digital comparison services and the media to
incorporate service information into their offer and that this will be a key channel
through which customers access the information. This method of distribution
reflects customer preferences for accessing service information and it works for
the detailed nature of the metrics and information proposed. We understand that
digital comparison services see opportunities to make the information available to
consumers. For BCAs this data will be available for digital comparison services that may
emerge in 2018 from work of the National Endowment for Science Technology and the
Arts (NESTA) on behalf of the CMA to develop new comparison websites.
13
4.24 We propose to require firms to publish the service information and metrics we will
require on their websites so that they are easily accessible to customers, digital
comparison services and other intermediaries. It is our policy intention that over
time firms will make the information available via API as this format is preferred by
many digital comparison services. However, we are mindful that the costs to firms
not already using API may be very significant, at least initially. We propose to require
firms that are part of the Open Banking initiative to make the service information
and metrics we require available via the same API as they are required to make the
CMA core indicators available from August 2018. We expect firms to work with Open
Banking to do this.
4.25 We think there are incentives for other firms to make this information available via
API, for example because it will be easier for digital comparison services to use it. We
expect many firms will use an API to meet obligations in PSD2 to enable customers
to use the services of account information service providers and payment initiation
service providers. If they do use an API for this purpose we propose to require them
to also make service information available via API. In other cases, we expect digital
comparison services to be able and willing to access data published on firms’ websites.
4.26 Participants in our customer research wanted reassurance about the methodology
and comparability of information. To provide certainty that an independent body has
set the parameters of the service information, we propose to require firms to state
that they are required by the FCA to publish it. Firms which also publish the CMA core
indicators should make clear that the statement that it is required by the FCA does
not refer to the CMA indicators. In addition, we propose to specify the language firms
must use to describe the service information. This is to ensure consistency between
firms and improve ease of comparability. It is important that service information
we prescribe is clear to firms, customers, and intermediaries including comparison
services, so we welcome views on the language chosen.
13 See http://www.nesta.org.uk/project/open-challenge
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4.27 Beyond this, we are not currently proposing to prescribe a presentational style
provided that the language we propose is used and the information is easily accessible.
We consider that information will be more engaging to customers in the firm’s own
presentational style. It is our understanding that intermediaries, including digital
comparison services, can access and compare information that may be presented in a
different format if the content is common. The tables in the proposed BCOBS 7 Annex
1R contain the language we propose to require firms to use.
4.28 We propose that firms notify us of the webpages where they publish the service
information and we may aggregate the data for our own use.
Q7: Do you agree that our proposals will make service
information easily accessible to customers?
Q8: Do you agree that comparison services are an important
route through which customers will access and assess the
service information we propose to prescribe?
Q9: Do you agree with the proposals to require publication via
anAPI,initiallyforthosermsrequiredtobepartofOpen
Bankingandsubsequentlyforthosermsthatwillusean
API for the purposes of PSD2?
Q10: Doyouagreethatweshouldspecifythelanguagerms
use to describe the service information, but not its
presentational format?
Timing and frequency
Discussion
4.29 The first set of CMA core service indicators will be published in August 2018 and we
see significant benefits to launching the additional service information we propose
at the same time. The CMA metrics will be relevant to the banking arrangements of
the vast majority of consumers and we expect them to attract attention from the
media. Aligning with the launch of the CMA metrics will also ensure additional service
information is available for digital comparison services to use in any new services they
plan to launch using the CMA core indicators.
4.30 We have considered the frequency with which we will require publication. The CMA
survey data will be collected over 12 months and published on a rolling six monthly
basis. Quarterly reporting of additional "objective" service indicators would provide
firms a regular opportunity and therefore incentive to improve any areas of poor
performance highlighted. It would also provide more up-to-date insights into the
service available to customers.
Our proposal
4.31 We propose to require firms to measure and publish the service metrics on a quarterly
basis, starting with the first reporting period in the second quarter of 2018 (April-June),
with publication due within six weeks of each end quarter. This allows firms six weeks
to review and quality assure the data, and it also means that the publication dates will
align with the twice yearly reporting of the CMA core service quality survey results.
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Table 1 shows the cycle for the first year of reporting. The date of first collection of
data is determined by the objective of aligning first publication of our proposed metrics
and information with that of the first CMA core service indicators. We propose that the
following years follow the same cycle in order to remain aligned with future CMA survey
results. Standing data should be published and kept up-to-date.
Table 1: Proposed reporting timetable for the rst year
Reporting period
Start of reporting
period
End of reporting
period
Publication of
service information
Q1 2018/19 1 April 2018 30 June 2018 By 15 August 2018
Q2 2018/19 1 July 2018 30 September 2018 By 15 November 2018
Q3 2018/19 1 October 2018 31 December 2018 By 15 February 2019
Q4 2018/19 1 January 2019 31 March 2019 By 15 May 2019
4.32 We have discussed timescales for implementation with firms. We recognise that our
timetable gives firms a limited time period to implement systems changes required
to report performance in a consistent manner. We will seek to make rules as quickly
as practical following this consultation to give firms as much time as possible to
implement.
Q11: Do you agree with our plans for the timing and frequency
ofpublication?Inparticular,doyouagreethattherst
publication of service information under the rules that we
are proposing should be in August 2018, to coincide with
therstoftheCMA'sservicequalityindicators?
The service information
4.33 As discussed in Chapter 3 we undertook significant pre-consultation to decide
whether we should require additional information about service to be published. We
found the following areas of service were of most interest to customers, challengers
and intermediaries including digital comparison services:
• Account opening
• Time taken to resolve issues
• Service availability
• Major incidents
4.34 The remainder of this chapter discusses the case for requiring firms to publish service
information for each of the service areas discussed above. It seeks feedback on the
service information we propose to require firms to publish.
4.35 We found that most of the service information we propose to require was equally
relevant for both BCA and PCA customers, except for third party access under power
of attorney which is only relevant to PCA customers. However, firms often deliver
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services differently to PCA and BCA customers, so we consider it is proportionate and
necessary to separate reporting of BCA and PCA metrics in the majority of cases.
4.36 Where we specify service information by channel we refer to the following definitions:
• Mobile banking – accessing an account via a banking app via any device (including
smart phone or computer)
• Online banking – accessing an account via the internet but not through mobile
banking
• Telephone banking – use of a phone to access an account but not via mobile banking.
Service metrics
4.37 Our research suggests that the dimension of service which is most motivating for
customers and easiest for them to compare across firms is, in many cases, the elapsed
time from when they applied for or requested the service until they receive the service.
To introduce such metrics we have defined a set of events which are sufficiently broad
that they will be of relevance to customers but have start and end times that can be
defined and measured comparably by firms.
4.38 We have considered how best to measure and communicate elapsed time to
customers. Participants in our research were interested in the service they should
expect to receive rather than average service. Following discussions at our SEG and
having considered the management information that firms already collect, we consider
that several metrics are required to provide a realistic indication of service:
• The percentage of customers provided the service on the same day - this shows
how often rms are able to provide the service immediately (within the same day)
• The average number of days within which the service was provided - this provides a
reasonable basis upon which customers can compare rms but may not provide an
accurate indication of how long customers can expect to wait
• The number of days within which the service was provided for 99% of customers –
this shows the longest a customer might normally expect to wait before the issue is
resolved. We recognise that a small number of customer requests may be dicult
to resolve for reasons outside of rms’ control. We note that some rms already
measure the time taken to provide the service to 99% of customers so consider it
proportionate for rms to continue using this measure as we have no evidence that
it is unsuitable.
Standing data
4.39 In other areas of service, the motivating aspect of the service provided by a firm is in
what way customers can access services and when they can speak to somebody who
is suitably trained to answer their query or resolve an issue. In addition, customers
need to know what documents or other information they need to supply to their
current account provider in order to obtain various services. Both these types of
information will change infrequently and are not suited to traditional measurement.
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Account opening
Discussion
Speed of opening an account
4.40 Our research found that PCA and BCA customers were very interested in the time
taken for a new account to become fully functional, with particular emphasis on access
to money and avoiding interruptions to direct debits. While the seven working day
Current Account Switching Service has standardised the switching process between
participant banks, this process only starts once an account has been opened. There
is differentiation, particularly from challengers, on the speed and ease of opening an
account prior to the start of the seven day switch process but this information is not
currently provided to customers comparing accounts. Digital comparison services
have indicated that as this information is relevant to customers they would use this
information in their services if it was available on a consistent basis. We consider that
making objective information about account opening available at the point of account
comparison would remove some of the remaining uncertainty around switching and
enable consumers to make more informed decisions.
4.41 Conversations with firms about service metrics have highlighted concerns that
logging every customer enquiry regarding account opening would be challenging
and potentially invasive. Firms have also stressed that the time customers take to
complete their application following initial enquiry is influenced by factors outside
of the bank or building society’s control. Firms have indicated it would be more
comparable between firms to define a reporting standard that commenced from the
point a customer submitted a completed application including required identification.
We recognise the difficulties and delays customers can experience in the early stages
of the account opening process. However, we consider firms have raised legitimate
issues that hinder measurement prior to submission of a complete application. To
incentivise firms to compete on the ease of applying for a current account we propose
to require firms to publish standing data covering aspects of this process.
4.42 We recognise that there is a tension between introducing metrics related to speed
of account opening and the importance of firms conducting robust and thorough
anti-money laundering and fraud checks, including customer due diligence (CDD)
when opening an account. To avoid this conflict we considered requiring metrics that
did not start until after CDD was complete, as is the case for the seven working day
current account switching process. However, we do not consider this information
would be as useful or as readily understood by customers as a measure covering the
whole account opening process following application, and do not consider concerns
regarding possible impacts on CDD to be insurmountable. Existing FCA rules require
firms’ on-boarding processes, including CDD, to be effective and risk-based; our
service metrics will not alter this. We consider that technological advances mean it is
possible to improve the efficiency of on-boarding processing times without sacrificing
thoroughness.
4.43 Conversations with firms have also highlighted that there are variations in processes
following account opening. From a customer perspective an account is not fully
functional until they can access the services they require. Some providers are able to
provide customers with a debit card and/or access to online and telephone banking
on 'day one' in branches while others have to provide these by post. We consider
that breaking down the account opening process into component parts will provide
customers with sufficient insight into when they can expect the amount to be
functional.
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4.44 The CMA found that PCA customers who are heavy overdraft users could benefit the
most financially from switching their current account.
14
We are separately considering
overdrafts as part of our review of High Cost Credit.
15
We consider that if firms publish
information about the time it takes to make overdraft funds available following account
opening this would help improve certainty for overdraft users who are considering
switching but will require access to overdraft funds very soon after their account is
open. We are mindful of a possible unintended consequence if firms were to offer
fewer overdrafts to personal customers in order to speed up the approval process, but
we consider this a low risk.
Our proposed service information for account opening
Standing data about the account opening process
4.45 We propose to require providers to either publish standing data for each of their PCA
and BCA products (per brand) about the minimum information and documents needed
to open an account, and about how accounts may be opened, or publish a statement
that they do not publish this information. Firms will be free to publish a single set of
standing data, and indicate any variation between accounts. We recognise that a
customer’s circumstances, for example lack of a credit record or a digital footprint,
may impact the account opening process. Information published about the account
opening process should advise customers of circumstances where they may need to
follow a different procedure.
4.46 We also propose to require publication of a statement on the following questions:
• Whether the rm publishes all the information required to open an account in one
place. If it does then the rm must list it or provide a weblink to its location.
• Whether an account can be opened without visiting a branch
• Whether an account can be opened without an appointment in a branch
• Whether an account can be opened with identication provided electronically
• Whether an account can be opened by post
4.47 We also propose to require providers to publish standing data relating to the availability
of a channel through which they can discuss the account opening process, including
how and when customers can apply to open an account, the account opening process,
and overdraft eligibility. See paragraphs 4.76-4.83 on service availability for further
information.
Account opening
4.48 We propose to split measurement of the account opening process into stages to
reflect firms’ differing approaches to the account opening process. When considered
as a set, the metrics will provide an overview of the account opening process from
submission of a complete application to provision of a debit card online banking and
arranged overdraft funds. We propose that for each of these stages firms measure and
publish a same day, average and 99% response time metric (see paragraph 4.38).
14 https://assets.publishing.service.gov.uk/media/57ac9667e5274a0f6c00007a/retail-banking-market-investigation-full-final-report.
pdf
15 www.fca.org.uk/news/press-releases/fca-launches-call-input-high-cost-credit-and-overdrafts
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4.49 The first proposed metrics will require providers to show the time taken from
submission of a complete application to the account being open, ie, the point at
which the customer has been given an account number and can make deposits. This
is intended to reflect the speed of service customers can expect if they submit a
complete application, including required proof of identification.
4.50 Firms that publish a list of the information and documents needed to open an account
will only need to measure the time taken to open the account (as above, have a working
account number) from the point at which they receive all the listed information and
documents. They will not need to include in their metrics those cases where additional
information or documents are required on a case-by-case basis.
4.51 Firms who do not publish a list will have to measure and include in their metrics
all account openings, from the point at which the application is first submitted,
irrespective of whether it is a complete application and irrespective of whether the
firm needs to request further information or documents. The intention here is to
incentivise firms to publish a list, and to ensure that there is no perverse incentive to
avoid requesting further information or documents in appropriate cases (for example,
for client due diligence or anti-fraud purposes).
4.52 We also propose to require providers to publish separate metrics related to the
time taken, following account opening, for a debit card, online banking and arranged
overdraft funds to be available to the customer.
4.53 These metrics are intended to show customers how long they can expect to wait
for services related to their new account to be provided. We recognise that many
customers rely on other services such as access to telephone banking and mobile
banking but consider that limiting metrics to cover the time taken to receive a
debit card, and online banking and arranged overdraft funds to be available to be
proportionate and indicative of the overall speed of service customers can expect at
account opening.
4.54 We propose that each of these metrics should be measured and published separately
rather than as a single metric covering the whole account opening process. Each
metric should be measured and published separately for PCAs and BCAs but not for
each account type. We propose that metrics cover PCAs and BCAs opened via all
channels; we are not proposing that firms publish separate metrics for each channel
as we do not expect that channel will significantly affect the time taken to open the
account.
4.55 The relevant service or action should be included in published service information
for the quarter in which it takes place, irrespective of the quarter in which the other
services or actions take place or the quarter in which the application was made. We
propose that the time taken to, for example, issue a debit card should be measured
up to the point when the customer receives the replacement card (and PIN), but not
activation; we therefore propose that, unless the customer receives the relevant items
on the same day, they be treated as received on the day on which the customer would
be expected to receive them based on the delivery method by which the firm sent
them. Similarly, internet banking should only be treated as enabled once the customer
is expected to have received everything necessary from the firm to access it.
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Q12: Do you agree with the proposed standing data and
metrics for the account opening process?
Q13: Doyouagreethatrmsshouldpublishseparatemetrics
related to the opening of an account, provision of a debit
card, online banking, and an overdraft?
Q14: Doyouagreewithourproposalnottorequirermsto
publish separate metrics for each channel through which
a customer can open an account?
Time taken to replace a debit card, and to give an attorney access to a PCA
Discussion
4.56 Our research found that both PCA and BCA customers would value information about
responsiveness.
4.57 Firms already report information about complaints resolution to us and this is
published on our website. If firms submit a report to the FCA reporting 500 or more
complaints they are required to publish a summary of the complaints data on their
own website.
16
Our experience of complaints reporting has shown that publishing this
information has encouraged firms to improve their performance. Since firms already
publish information about complaints we do not consider it proportionate to require
firms to publish additional information about complaints as part of our current account
service information work.
4.58 Firms do not report or publish information about resolution of requests and issues that
are not complaints. As explained in Chapter 3, participants in our research considered
how quickly they could expect to get a response to a typical question or request to
be a good indicator of overall bank service. They said they would consider switching
provider to receive quicker service. They recognised that they would not expect
firms to publish metrics on everything, but considered some metrics would give an
indication of the levels of service they could expect to receive overall, particularly when
considered alongside the CMA core indicators.
4.59 Digital comparison services in our SEG considered information about the length of
time taken to resolve typical customer queries/issues by channel a good indicator of
service quality that would be easy for them to display and for customers to understand.
However, feedback from the majority of firms has indicated that reporting response
times would require significant changes to their systems and in some circumstances,
particularly for queries made in-branch, response time would be difficult to measure.
4.60 We have considered firms’ concerns and propose to introduce only a limited number of
response time metrics, at least initially. Metrics we propose to introduce relate to:
• Replacing a lost or stolen or stopped debit card, and
• Organising third party access to a PCA under power of attorney.
16 DISP 1.10A1
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4.61 Replacing a stopped card is an inconvenience. We consider that a metric that reflects
the speed with which customers can expect to receive a replacement card is a service
event that is easy to measure and one that will resonate with customers.
4.62 Participants in our research highlighted difficulties arranging third party access to
accounts under power of attorney. We have been working with stakeholders as part
of our Ageing Population project
17
to understand how the financial sector can better
support people who require third party access to accounts. There is significant
scope to improve access to third party access arrangements, and this will require
improvements to services. The BBA recently agreed and published principles (a
voluntary code of practice) to improve access.
18
Given the known issues with third
party access and the growing number of people who require this service, we consider
that requiring publication of service information in this area will provide customers with
a good indication of the quality of service they can expect to receive from firms if they
encounter difficulties with their banking.
4.63 There are many types of third party access ranging from third party mandates agreed
between the customer, third party and the firm, to various legal instruments granting
access including, for example, Lasting Power of Attorney, Appointeeship and Court of
Protection Deputyship. Legislation varies between England and Wales, Scotland and
Northern Ireland. Firms’ processes may not be comparable between types of third
party access arrangements. We propose that our metrics in this area cover powers of
attorney, since we understand these are the most common forms of arrangement.
4.64 We recognise that the early stages of the third party access process, including getting
clear information about how to apply and what documentation is required, can cause
delays and be frustrating for customers. However, it is difficult to measure quality of
these services objectively. We consider that requiring firms to state whether they
have published complete information about how to apply for third party access under
a power of attorney and requiring them to state the hours and channels through which
customers can access staff trained to deal with third party access requests will assist
customers. We discuss our proposals for this in paragraphs 4.76 – 4.83.
4.65 As with our proposed account opening metrics, we considered whether metrics
related to third party access should measure time taken to perform customer due
diligence - for example checking identification and the authenticity of the original
or certified power of attorney certificates provided. As discussed in paragraph 4.42,
we recognise the potential concern that firms might reduce the thoroughness or
compromise anti-money laundering or fraud checks, but consider that there are
adequate incentives for firms to ensure their processes are robust, and also that there
is room for firms to improve the efficiency of their processes.
4.66 Third party access agreements via power of attorney vary. Some attorneys will be
able to access all account features, including use of internet banking and a debit card,
while others may be restricted to viewing account information or making payments by
cheque or in person. For this reason, we do not consider it is possible to define a single
point at which third party access has been granted. Instead we propose is to require
multiple metrics that, as for account opening, capture separate stages of the process
to give an attorney access to a PCA.
17 www.fca.org.uk/publications/discussion-papers/ageing-population-financial-services
18 https://www.bba.org.uk/news/bba-voice/a-little-help-from-friends-and-family
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Our proposed metrics for time taken to replace a debit card, and to give an
attorney access to a PCA
Time taken to replace a lost, stolen or stopped debit card
4.67 We propose to require firms to publish the same day, average and 99% response time
metrics (see 4.38) for the time taken to replace lost or stolen cards or cards otherwise
stopped, eg following a security incident. We propose to require these metrics to be
published separately for PCAs and BCAs.
4.68 Measurement of metrics should include cards reported lost or stolen or otherwise
stopped by the firm, and requests made by telephone, in a branch or via online banking
or mobile banking or by any other channel. Time taken to provide the replacement card
should be measured in the same way as for provision of a debit card with a new account
(see paragraphs 4.48-4.55).
4.69 The draft guidance in the instrument which appears at Appendix 1 to this CP refers
to the Payment Services Regulations 2017, which will require a payment service
provider to allow the use of the payment instrument or replace it with a new payment
instrument as soon as practicable after the reasons for stopping its use cease to
exist.
19
Time taken to provide third party access to a PCA under power of attorney
4.70 We propose to require providers to either publish standing data for each of their PCA
products (per brand) about the information and documents necessary to apply for
third party access to a PCA under a power of attorney or a statement that they do not
publish this information. Firms will be free to publish a single set of data, and indicate
any variation between accounts. Information published about access via power of
attorney should advise customers of circumstances where they may need to follow a
different procedure. We propose to require firms that do publish this information to
publish a link to it alongside the statement.
4.71 We propose to split measurement of the process to grant third party access to an
attorney into four stages for the reasons described in paragraph 4.66. For each metric
we will expect firms to publish the same day, average and 99% response time (see
paragraph 4.38).
4.72 The first proposed metric requires providers to show the time taken to provide an
attorney access to the account. By this we mean access that enables the attorney
to ascertain the account balance and obtain information about transactions on the
account. We propose that this metric be measured from the point that the attorney
has requested access and has provided all required ID and documentation to the firm.
Access is granted when the firm acknowledges the attorney’s right to access. Access
may be requested by any channel the firm allows.
4.73 We propose that the following three metrics are measured once access to the account
has been provided:
1. The time taken to allow the attorney to withdraw money and initiate payment
transactions, if this is requested
19 http://www.legislation.gov.uk/uksi/2017/752/introduction/made
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2. The time taken to issue a debit card to the attorney if this is requested, measured
as per provision of a debit card (see paragraphs 4.48-4.55).
3. The time taken to enable internet banking for the attorney if this is requested,
measured as per provision of internet banking (see paragraphs 4.48-4.55).
4.74 As for the proposed account opening metrics, we propose that instances should be
included in the service metric for the quarter in which the service or action is carried
out.
4.75 Firms may exclude from their measurement of these metrics cases where they
required additional information and documents to those specified in their list of
information and documents necessary to apply for third party access. If the firm does
not publish such a list it may not exclude any cases from its measurement.
Q15: Do you agree with our proposed metrics related to time
taken to replace a debit card?
Q16: Do you agree with our proposed metrics related to
providing access under power of attorney? In particular,
doyouagreethatrmsshouldpublishseparatemetrics
related to each stage of the process for giving a third
party access to a PCA under power of attorney?
Ser vice availability
Discussion
4.76 Our qualitative research found that convenient access to banking services is important
to consumers. Both PCA and BCA customers were interested in branch opening times
and the availability of service provision outside of normal working hours. Discussions
with stakeholders also suggest that service availability is extremely relevant to
customers’ choice of bank or building society. Participants in our research remarked
that they had chosen their bank or building society because its branch location/
opening hours were convenient for them. Some voiced frustration that it was not
possible to speak to customer service staff over the phone in the evening or in branch
‘out–of-hours’ at the weekend. Perceptions that all banks and building societies were
the same were challenged when other participants explained that they did have access
to these services out-of-hours. This prompted participants to think about their own
banking arrangements.
4.77 Information about individual branch locations and opening hours has recently been
made available by the largest banks and building societies in a common format via
the Open Banking API. We understand that all firms publish information about branch
locations and opening hours on their website. Other information about services
available via telephone banking, online banking and mobile banking is available on
providers’ websites but it is not always clear which services can be provided out-of-
hours. For example, telephone banking may be available 24 hours a day but availability
of some services, including the option to speak to an adviser, may be limited in the
evening and overnight.
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4.78 We consider that requiring firms to publish a common set of standing data covering
services of interest to customers will enable customers to differentiate between
brands and make better comparisons to choose the best account for their needs.
Digital comparison services will be able to consider customers’ preferences for
service availability when recommending accounts. This will encourage banks and
building societies to better identify the specific needs of customers and improve the
accessibility of their service to meet these demands.
Proposed standing data related to service availability
4.79 We propose to require providers to publish standing data about their service provision
for each of their products. Firms may choose to publish a single set of data and indicate
any differences that relate to particular products.
4.80 We propose that firms be required to publish standing data showing the availability
(hours and days of the week) of the following services via telephone, telephone
banking, online banking, and mobile banking:
1. Check balance and transactions
2. Send money within the UK including setting up a standing order
3. Make a payment in a foreign currency
4. Pay in a cheque
5. Cancel a cheque
4.81 For each of these services 1-5 above and for the services 6-12 below we propose to
require firms to state whether 24 hour help from a suitably trained person is available,
for example so that a customer can ask and receive an answer to a question about
the service. Where help is available, we propose that firms should state how it can be
accessed. If 24 hour help is not available we propose to require firms to state the days
and times that help can be accessed and how it can be accessed.
6. Discuss withdrawing money abroad
7. Discuss a lack of funds, including unarranged overdrafts, payments taken despite
lack of funds and cancelled payments due to lack of funds
8. Discuss a direct debit or continuous payment authority
9. Discuss third party access, including under power of attorney, to an account
10. Discuss problems using online banking or mobile banking
11. Discuss progress following an account suspension or card cancellation eg
following a fraud incident
12. Discuss account opening, including overdraft eligibility, what is required to open
an account and an indication of what overdraft may be available
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4.82 These services represent those that customers are most likely to access and therefore
make enquiries about and services important to participants in our research.
20
The language we use to describe these services needs to be clear to firms, digital
comparison services and customers. We have based our description of these services
on consumer research conducted to inform the development of terminology required
by the Payment Accounts Directive.
21
There is a balance to be struck between having
too long a list of services and enabling firms to describe their service availability in a
way that is clear. We seek feedback on the descriptions used and may modify this list
following consultation to aid users’ understanding.
4.83 Since branch opening hours are likely to vary by location we are not proposing to
require firms to include branch hours in their service availability table(s). We do not
propose to require firms to publish information and metrics for ATMs, as customers
are not restricted to using their own bank or building society’s branded ATM.
Q17: Do you agree with our proposed requirements for service
availability information?
Q18: Do you agree that the service descriptions we have
chosen will be clear to users? Could some of these
categories be combined to reduce the amount of
information published and make it easier to use? Should
any be omitted? Should any others be added?
Major incidents
Discussion
4.84 Our research found that both PCA and BCA customers would value information
about service reliability. They were particularly interested in the frequency of major
unplanned service outages. They considered that frequent unplanned interruptions
may be a sign of poor investment in the resilience of systems and security. Not being
able to access services for a period of one hour or more would cause them significant
inconvenience.
4.85 Digital comparison services considered this information might be useful but warned
against providing anything that was too granular. They suggested that they may
present customers with a red/amber/green rating or a percentage showing service
availability. A few banks publish dashboards showing current availability of their banking
services, but their performance cannot be compared because they do not measure
service availability in a consistent way. Impacts of major incidents on customers are
widely reported in the media.
4.86 We see benefits to requiring firms to publish consistent information on major
incidents which is comparable between providers. We recognise that firms already put
significant resource into improving the resilience of their systems, but this information
will enable them to compare their performance with other providers and potentially
to compete on the resilience of their systems. It will also allow commentators and
20 Work to implement the Payment Accounts Directive (PAD) has involved the FCA creating a list of the UK’s most
representative payment account services. www.fca.org.uk/publication/feedback/fs15-04.pdf Additional services were prioritised by
participants in our research.
21 www.fca.org.uk/publication/research/payment-accounts-directive-optimisa-research.pdf
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customers to review performance and factor this into their choice of account and
account recommendations.
4.87 When the Payment Services Regulations 2017 come into force, firms will be required to
report major incidents to the FCA.
22
The regulations implement PSD2, which requires
major operational and security incidents to be reported to regulators. Regulators will
be required to notify the European Banking Authority (EBA) and the European Central
Bank, and they may then notify regulators in other Member States so that they can
take all necessary measures to protect the immediate safety of the financial system.
The EBA has consulted on draft guidelines for incident reporting.
23
We recently
published a CP that includes proposals on how we will implement these guidelines.
24
Our proposed metrics
4.88 We propose to require firms to publish the total number of major incidents for which
they submit an initial report to the FCA under the regulations, in the reporting quarter
and in the last year, and also the number of these incidents for each of online banking,
telephone banking and mobile banking. For ease of access by customers, we consider
that this information is best published by firms along with the other service information
we prescribe, rather than the FCA publishing the data separately elsewhere.
Q19: Do you agree with our proposed major incident metrics?
22 http://www.legislation.gov.uk/uksi/2017/752/introduction/made
23 https://www.eba.europa.eu/news-press/calendar?p_p_id=8&_8_struts_action=%2Fcalendar%2Fview_event&_8_eventId=1688807
24 www.fca.org.uk/publications/consultation-papers/cp17-22-revised-payment-services-directive-psd2-implementation
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5 Discussion of metrics we are not pursuing
5.1 As discussed in paragraph 4.21, there is evidence suggesting customers may find too
many service metrics difficult to assess and compare. We are therefore proposing to
require firms to publish a small number of meaningful service metrics that customers
tell us matter to them.
5.2 In this section we discuss areas of service that we do not plan to pursue as service
metrics at this stage. A full list of metrics considered, including those we do not
propose to take forward now, can be found in Annex 5.
5.3 Some of these, for example those specific to vulnerable customers, were partly
supported by the evidence we have collected, and while we are not proposing
requirements relating to them now, we may reconsider this in the future. Firms can, of
course, publish this and any other information about their service if they choose to do
so.
Subjective measures of service quality
5.4 We considered whether to introduce additional subjective measures of service such
as customer satisfaction measures alongside the CMA core service quality indicators.
Our SEG suggested that an ideal mix of indicators would include both objective factual
measures and subjective measures of customer experience. However, they also
noted that surveys of satisfaction measure a different thing from surveys based on
willingness to recommend so they cannot be directly compared.
5.5 From a customer perspective, most participants in our research felt additional
subjective measures of service were not necessary alongside the CMA’s core service
quality indicators. They were sceptical that customer satisfaction data would reflect
the service they would receive. They considered objective measures more reliable.
5.6 Subjective measures of service quality would require regular customer surveys in
addition to that already required by the CMA. Given the findings from our research we
do not consider the costs of this proportionate and we do not intend to pursue any
additional subjective measures of service quality.
Firms'responsetofraud
5.7 Our SEG questioned whether customers would engage directly with fraud metrics
but believed that intermediaries could use the information to create an overall score.
Participants in our research were concerned about fraud but often had limited
understanding of what it meant in practice. They wanted firms’ response to fraud to be
proactive and they expected firms’ investigations and reinstatement of accounts to be
quick.
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5.8 We have identified a likelihood of unintended consequences of requiring publication
of metrics which highlight the speed or frequency with which banks and building
societies identify fraud and alert the customer. One unintended consequence could
be to encourage firms to prioritise speed over the diligence with which they investigate
potential fraud. Another consequence is that such metrics could help criminals to
choose firms to target, resulting perversely in higher levels of fraud.
5.9 While we are not proposing metrics related to the speed with which firms investigate or
alert customers to suspicious activity, we expect all authorised firms to have systems
and controls to counter the risk that they are misused for the purposes of financial
crime of all types, and this includes systems and controls to counter the risk of fraud.
5.10 We are consulting on metrics related to replacement of a lost/stolen or stopped cards
(see paragraphs 4.67-4.69). We also propose to require firms to state whether 24 hour
help is available to discuss issues using online banking or mobile banking (outside
of a major incident) or to discuss progress following an account suspension or card
cancellation, or a suspected fraud incident (see paragraphs 4.79-4.83).
In-branch service
5.11 Participants in our research valued branch services and wanted information about
branch opening hours and locations. This information is already published by
the largest banks via Open Banking and we do not propose to duplicate this. We
understand that firms that are not part of the Open Banking API already publish
information about individual branch opening hours and locations on their websites and
it is possible for digital comparison services to access this information.
5.12 Participants were also interested in how quickly they could expect to get an issue
resolved in branch. We propose to require firms to monitor the speed of resolution
of specific issues, some of which may be raised in branch, such as account opening
and requests for third party access under a power of attorney (see paragraphs 4.70-
4.75). However, we are not taking forward metrics related to general speed of service
in branch, for example average queue times. The CMA remedies include a subjective
measure of branch service quality and banks have argued that objective measures of
branch service, for example average wait times at various times of day, are prohibitively
difficult to measure. Our evidence at this stage is that proxies for this information
for example the number of branch staff or customer service terminals, are not of
sufficient interest to consumers and digital comparison services to warrant requiring
their publication.
Complaints
5.13 As discussed in paragraph 4.57, information about complaints is already published
by firms and we do not consider it proportionate to introduce new requirements to
publish complaints information. However, we will work with intermediaries before
implementation to discuss how they could highlight available complaints data
alongside service information.
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Telephony
5.14 We considered whether to introduce metrics related to telephony, for example, the
speed with which calls are answered, call abandonment rates and average tenure of call
centre workers. Participants in our research were concerned, however, that metrics
related to call answering times may encourage firms to use automated services or
triage services to answer the call quickly but without resulting in improvements to
the service they received. We consider that measures related to service availability
and time taken to resolve a representative selection of issues will instead capture the
importance of meaningful customer contact.
Relationship management
5.15 We tested with BCA customers the same general metrics we tested with PCA
customers and found BCA customers were equally motivated by these metrics. We
therefore consider the general metrics we are progressing sufficient to help BCA
customers choose an account and to improve service offered to BCA customers
by firms. We also considered metrics specific to the experience of BCA customers,
including relationship management, but few SME participants in our research were
motivated by these indicators.
Overdrafts (outside of the account opening process)
5.16 SME consumers were interested in the time taken to get an overdraft granted. We
propose to include overdraft provision (for both PCAs and BCAs) in our account
opening metrics (see paragraphs 4.48-4.55) but have not seen evidence to require
separate metrics related to other overdraft requests. Research has found 97% of SME
overdrafts are made available ‘in good time
25
' and overdrafts are already separately
identified within the core CMA satisfaction metrics. We are committed to looking at
PCA customer overdrafts as part of our prompts remedy and our review of high cost
credit.
26
Vulnerable customers
5.17 We recognise that customers with more complex needs may find it harder to access
services and resolve issues.
27
5.18 Our qualitative customer research tested specific measures of service for vulnerable
customers. Participants wanted to know that banks were looking after people who
might struggle with their banking. However, there was confusion and some concern
about who would be classified as vulnerable, and customers who could be considered
25 SME Finance Monitor Q4 2016, BDRC, March 2017. http://bdrc-continental.com/BDRCContinental_SME_Finance_Monitor_
Q4_2016_Final.pdf
26 www.fca.org.uk/publication/call-for-input/call-input-high-cost-short-term-credit.pdf
27 FCA occasional papers on access and vulnerability
www.fca.org.uk/publications/occasional-papers/occasional-paper-no-17-access-financial-services-uk
www.fca.org.uk/publications/occasional-papers/occasional-paper-no-8-consumer-vulnerability
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to be vulnerable did not place themselves in this group. Participants did not consider
metrics specific to more vulnerable customers particularly motivating when
considering switching – especially if not seen to be relevant to them specifically.
5.19 Our researchers also conducted ten in-depth interviews with customers with more
vulnerable circumstances. They found that these customers particularly valued access
to the branch network and being able to contact the bank or building society at a time
that suited them to discuss their needs. We consider that the metrics we are proposing
to introduce on service availability meet these needs.
5.20 Due to the complexities identified, and the lack of evidence that metrics related to the
treatment of vulnerable customers will improve competition, we are not planning to
introduce specific metrics in this area at this time. However, we plan to reconsider this
in the future if we identify this as an appropriate response to a specific harm.
Q20: Do you agree that we should not pursue publication
of service information for these aspects discussed in
Chapter 5 at this time?
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6 Next steps
6.1 In this chapter, we set out the next steps on this consultation and other work that is
relevant to our proposal to require publication of service information.
Developing rules
6.2 The rules and guidance on which we are consulting are in the draft instrument in
Appendix 1. The consultation closes on 25 September 2017. During the consultation
period we plan to engage with customer stakeholders, industry and digital comparison
services. We will then review the responses and, subject to the outcome of the
consultation, publish our feedback, policy decisions, final rules and guidance.
Post implementation review
6.3 We intend to review the effectiveness of the final rules after they have been fully
implemented by firms and in operation for long enough to assess competition
outcomes.
Future work
6.4 This CP seeks feedback on service metrics that are representative of the service
provided by firms that we consider can be published by August 2018. Our research and
stakeholder consultation also suggested there would be merit in the introduction of
other current account service metrics. We may consider introducing further metrics
related to current account service in the future.
6.5 There may be consumer and competition benefits to requiring publication of similar
service information for other products such as mortgages, savings accounts and
insurance. We will continue to gather and consider evidence on service metrics in
future policy projects concerning these products and, potentially, different types of
firm that operate in these markets.
6.6 This is one of a set of recommendations made by the CMA to the FCA. Details
of our future work on the other remedies, which are designed to work together
as a package to improve competition were set out in our response to the CMA's
recommendations.
28
28 November 2016, FCA response to the CMA’s recommendations following its investigation into retail banking.
www.fca.org.uk/publications/corporate-documents/our-response-cma-investigation-competition-retail-banking-market
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Annex 1
Questions in this paper
Q1: Do you agree with our analysis that we should require
publication of service information?
Q2: Doyouagreethatrmsshouldpublishservice
information related to the areas of service outlined?
Are there any other areas we should consider (bearing
in mind our discussion of metrics we are not pursuing in
Chapter 5)?
Q3: DoyouagreewithPCAsandBCAsbeingdenedby
referencetothedenitionof“paymentaccount”inthe
Payment Accounts Regulations 2015?
Q4: Do you agree that ‘premium service accounts’ should be
excluded from PCA service information?
Q5: Do you agree with the proposed application of the rules?
In particular do you agree with the providers, customers
and products in scope of the rules?
Q6: Do you agree with the proposed threshold? Do you
agree that providers below the threshold which choose
to publish the same or similar service metrics must
comply with the relevant rules?
Q7: Do you agree that our proposals will make service
information easily accessible to customers?
Q8: Do you agree that comparison services are an important
route through which customers will access and assess
the service information we propose to prescribe?
Q9: Do you agree with the proposals to require publication
viaanAPI,initiallyforthosermsrequiredtobepartof
OpenBankingandsubsequentlyforthosermsthatwill
use an API to for the purposes of PSD2?
Q10: Doyouagreethatweshouldspecifythelanguagerms
use to describe the service information, but not its
presentational format?
Q11: Do you agree with our plans for the timing and frequency
ofpublication?Inparticular,doyouagreethattherst
publication of service information under the rules that
we are proposing should be in August 2018, to coincide
withtherstoftheCMA’sservicequalityindicators?
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Q12: Do you agree with the proposed standing data and
metrics for the account opening process?
Q13: Doyouagreethatrmsshouldpublishseparatemetrics
related to the opening of an account, provision of a debit
card, online banking, and an overdraft?
Q14: Doyouagreewithourproposalnottorequirermsto
publish separate metrics for each channel through which
a customer can open an account?
Q15: Do you agree with our proposed metrics related to time
taken to replace a debit card?
Q16: Do you agree with our proposed metrics related to
providing access under power of attorney? In particular,
doyouagreethatrmsshouldpublishseparatemetrics
related to each stage of the process for giving a third
party access to a PCA under power of attorney?
Q17: Do you agree with our proposed requirements for
service availability information?
Q18: Do you agree that the service descriptions we have
chosen will be clear to users? Could some of these
categories be combined to reduce the amount of
information published and make it easier to use? Should
any be omitted? Should any others be added?
Q19: Do you agree with our proposed major incident metrics?
Q20: Do you agree that we should not pursue publication
of service information for these aspects discussed in
Chapter 5 at this time?
Q21: Do you have any comments on our CBA?
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Annex 2
Cost benefit analysis
Introduction
1. The Financial Services and Markets Act 2000 (FSMA), as amended by the Financial
Services Act 2012, requires us to publish a cost benefit analysis (CBA) of our proposed
rules. Specifically, 138I requires us to publish a CBA of proposed rules, defined as ‘an
analysis of the costs, together with an analysis of the benefits that will arise if the
proposed rules are made’ and an estimate of those costs and those benefits (unless it
is not reasonably practicable to produce those estimates).
2. This cost benefit analysis presents an analysis of the significant impacts of our
proposal. We provide monetary estimates for the impacts where we believe it is
reasonably practicable to do so and where we have been able to obtain robust data.
For others, we provide an analysis of outcomes in other dimensions, based on what
we consider are reasonable assumptions or using what data is relevant and available
to us. Our proposals are based on carefully weighing these multiple dimensions and
reaching a judgement about benefits to competition as well as the appropriate level of
consumer protection, taking into account all the other impacts we foresee.
3. Chapter 4 proposes policy measures to require firms to publish service metrics and
service information which are intended to help personal and SME customers find and
access information about current accounts with better service levels. This analysis
first summarises adverse effects on competition found in this market by the CMA, and
the core service quality indicators it will require firms to publish as a partial remedy,
along with other remedies. With this context set, it outlines a rationale for the FCA to
intervene to require the additional policy measures and presents our assessment of
the benefits and costs that we expect as a result.
AdverseeectsoncompetitionandcontextfortheCBA
4. In its retail banking investigation, the CMA found that, due to the complexity and lack of
information in the retail banking market there are adverse effects on competition:
• Many customers have little information about the service oer and quality of other
banks and building societies and it can be dicult to consider whether there are
better deals elsewhere
• Service information which is available is often not consistently dened, making it
dicult or costly for comparison services and commentators to compare service
oers and quality between providers and rank or recommend them.
5. As part of a package of remedies to address this, the CMA has made an Order requiring
providers of most PCAs/BCAs
29
to publish service quality indicators for each brand
29 For PCAs, providers with more than 150,000 active PCAs in Great Britain and 20,000 active PCAs in Northern Ireland, and for BCAs
more than 20,000 active BCAs in Great Britain and 15,000 in Northern Ireland.
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prominently and in a specified form in branches, on websites and mobile banking and in
leaflets.
6. The indicators will give the percentage of customers willing to recommend to friends
and family / other SMEs the service, according to the:
• brand
• brand’s online and mobile banking services
• brand’s branch service/business centre service
• brand’s overdraft and loan services, and
• for BCAs only, the brand’s relationship/account manager.
7. The CMA’s Order also requires providers to publish their rank in relation to all the
brands surveyed for each indicator, and to display charts showing scores of the top five
named providers (with their logos) for each, along with the provider’s own scores.
8. Another remedy in the CMA package which we consider relevant to this CBA is the
Open Banking standard, which will from early 2018 enable customers to give third
parties and firms controlled access to their banking data to offer previously unavailable
individually tailored services, including innovative comparison services.
9. In addition to the core service indicators, the CMA recommended that the FCA
consider and then require providers of PCAs and BCAs to publish and make available
additional objective measures of customer service performance.
10. The evidence obtained from our research and engagement highlights that there is
a need to improve the availability of meaningful and comparable information about
service quality. Our proposals aim to make these improvements to make it easier for
customers to make informed comparisons and choose the provider that best suits
their needs based on the quality of their service.
Our analytical approach
11. This CBA sets out our analysis and estimates of the benefits and costs of our
proposals. Our analytical approach was designed to assess the impact of our proposed
intervention in the future regulatory environment that will pertain when our proposed
rules would come into force, and when various other changes in the market have
occurred, notably when CMA survey results will be published regularly and Open
Banking and PSD2 are implemented.
30
12. This CBA assesses the impact that requiring providers to publish additional service
information is likely to have. This CBA assesses the costs and benefits of our proposed
rules alone, and not the impact of the publication of core service quality indicators
required by the CMA’s Order (which applies only to the current account providers
above the de minimis threshold in the CMA’s Order), but it assumes that those
30 Under PSD2, customers will be able to give third parties and firms controlled access to their banking data in order to offer them
individually tailored services, including innovative comparison services.
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indicators will be published, and that Open Banking and PSD2 will be implemented, in
setting the baseline for assessing the impacts of our proposed intervention.
13. Our approach is therefore to set out a clear causal analysis of how our policy
intervention is intended to work and, using relevant evidence, set out as best as we can
about what the future benefits and costs may be.
14. The approach we have taken and evidence gathered of potential benefits of requiring
these provisions are set out in Chapter 3. The causal analysis in this CBA reflects
insights from the qualitative customer research and SEG meetings of the likely
customer interest and transmission routes of service information and metrics to
customers through intermediaries.
15. To gain evidence of the likely costs of implementation, we have spoken to the BBA, the
Building Societies Association (BSA) and the Association of Foreign Bankers. We have
also identified the relative costs of collecting various types of service information and
metrics. The costs vary depending on whether the parameters set out in our proposed
rules are the same or close to existing regulatory requirements for measurement or to
data already collected by firms.
Analysisofbenetstoconsumersandcompetition
16. Effective competition means firms striving to win business on the basis of service,
quality, price and innovation. Consumers have the information they need to choose
the product that offers the best outcome for them. If consumers are not satisfied,
they can take their business to another firm. However, when consumers don’t have
the right information it can result in low levels of consumer engagement. Indeed, the
FCA has observed that consumer engagement in some financial markets is low and
this was identified by the CMA’s market investigation as a problem in the PCA and BCA
markets. As a result, consumers may not get the best deal from their current account.
Our proposals are directly aimed at addressing low consumer engagement in the PCA
and BCA markets.
17. We therefore judge that our proposals will create the following positive benefits:
• Objective data on matters that are of interest to consumers will be available and
presented in a consistent manner for consumers to compare between providers on
the basis of service
• Consumers will be able to investigate service metrics which are of particular interest
to them as users on providers’ own websites, on comparison sites which enable
users to compare a number of dierent providers in one place, or in other services
or publications that seek to reduce the complexity of nancial products
• As a result of this, customers will become more aware of the speed and availability
of the services oered by dierent providers, enabling them to make more informed
and better decisions about whether their bank account oers them good service in
comparison with others
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• Better informed customers would be more likely to identify whether they would
benet from switching to an account or to a provider that oers them better service,
better value for money, or nancial benets
• As a result, rms are likely to compete actively both to retain and to attract
customers by improving their products, service and performance
• In turn, this should lead to more customers who are more satised with the service
they receive from their current account provider.
18. As supported by evidence from our consumer research, the metrics we are proposing
relate to areas that are meaningful to consumers, for example, because they help
consumers understand how quickly they can resolve the inconvenience of replacing
a card or arranging essential third party access to an account, or understanding what
services are available from a provider and when they are available, so that they can
determine whether that provider is likely to be able to meet their needs.
19. Almost all adults in the UK (97% in 2014
31
) have a current account. Improvements in
service across the market as a result of these provisions have the potential to benefit
over 50 million people.
32
20. The CMA’s retail banking investigation found that 56% of PCAs have no overdraft
usage.
33
Since these consumers – likely to number almost 30 million people – do not
pay overdraft interest or fees, commentary and account recommendations based on
comparable service metrics and information will offer a new basis for differentiating
between providers. This could significantly increase their engagement with the choice
of a current account. Our qualitative research provides evidence that consumers would
find objective information about certain elements of providers’ service useful because
they value good service and would be willing to switch account to get it.
21. Our proposals are aimed at both PCAs and BCAs, which generated revenues of over
£11 billion in 2014.
Estimateofbenetstoconsumersandcompetition
22. We consider that our proposals could have a significant positive impact on a large
number of consumers through increased engagement, better decision making and
improvements in service in the PCA and BCA markets. We expect our proposals
to produce the benefits outlined in paragraph 17. The nature of some of these
improvements means that we cannot quantify their economic benefits robustly
in financial terms. Further, there are developments in these markets, notably
publication of the CMA’s core service indicators and Open Banking and PSD2, that
have not occurred yet but whose impact cannot be reliably foreseen or predicted but
which could significantly affect the impact of our own proposals. It is therefore not
reasonably practicable for us to quantify, in monetary terms, the benefits we expect
31 CMA Retail Banking final report, pg9, https://assets.publishing.service.gov.uk/media/57ac9667e5274a0f6c00007a/retail-banking-
market-investigation-full-final-report.pdf
32 Number of adults with at least one current account using data from Financial Inclusion Annual Report and Office of National
Statistics
33 CMA Retail Banking final report, pg224, https://assets.publishing.service.gov.uk/media/57ac9667e5274a0f6c00007a/retail-banking-
market-investigation-full-final-report.pdf
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our proposals to achieve.
Analysis of costs
23. Firms have told us in roundtable meetings that the cost of collecting service data
varies between metrics and also between firms. The costs are very low if the data
has to be collected to meet another regulatory requirement, and remain low if it is
necessary only to make small system changes to amend similar data already collected.
In cases where a firm must create new mechanisms to collect data, the costs of doing
so may be significant.
24. We were able to acquire cost estimates for the collection of most metrics from a small
number of large and medium-sized banks and building societies. The estimated costs
provided by the firms were high level estimates only. As expected, the cost estimates
varied widely even between similar-sized firms. This is likely to reflect both differences
in firm-specific costs and differences in the approach used to provide these estimates.
25. Our telephone conversations with the sample of firms allowed us to obtain a better
understanding of the relative costs of providing different service metrics. Our
discussions revealed that the costs for third party access and the time taken to get an
overdraft are likely to be more significant than the other metrics. Given the widespread
variation in the estimates provided by the sample for these metrics and the
idiosyncratic nature of these costs, we do not see a reasonable basis for scaling up the
costs for the industry. Firms have told us that costs may vary significantly depending
on the detail of the required metrics, so we do not believe it is proportionate to seek
additional cost estimates from more firms ahead of this consultation.
26. Our engagement with the sample of firms highlighted that the costs of publishing the
metrics (once measured) and service information statements (eg service availability
times and helplines) on websites and API has the potential to involve significant costs,
depending on the provider’s existing systems and the costs involved with building a
new system.
27. Table 1 sets out the reasons for varied costs of implementation across the different
provisions and firms.
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Table 1: Reasons for lower or higher costs of implementation
Type of service
metric/information
Same as regulatory
requirement
Similar data already
collected - minor
changes
No similar data
collected now -
signicantbuild
Major service outages PSD2 service
interruption denitions
will apply to all payment
account providers by
2019
Account Opening Elements of account
opening under rm
control and with digital
footprint
Elements of account
opening requiring
customer action and/or
not digitally recorded
Service availability
information by channel
in and out of normal
hours
Addition of standing
data to Open Banking
data required by CMA
Order for rms subject
to CMA’s Order
Adoption of Open
Banking data format
and an API by rms
outside CMA’s Order
but within these
provisions
Third party access
to accounts under a
power of attorney
Elements of allowing
access which are under
the rm’s control and
with digital footprint
Elements of allowing
access which require
customer action and/
or are not digitally
recorded
Replacing cards Small changes to
existing processes
Major incident PSD2 service
interruption denitions
will apply to all payment
account providers by
2019
Source: BBA roundtables
28. There will also be costs to the FCA of supervising firms’ compliance with our proposals.
However, these are already accounted for in the FCA’s existing budget for supervisory
activities. The costs for supervising these specific rules are of minimum significance.
Estimate of costs
29. We have obtained estimates from a sample of large and medium-sized banks and
building societies of the costs of collecting service metrics where they do not collect
data already and expect costs of doing so to be significant. The estimated one-off
cost of collecting data for those service metrics which require significant changes is
between £30,000 and £1 million per firm.
34
34 The large variation in the cost range is due to the nature of responses from the firms in the data requests. Due to the limitation in our
sample and the costs provided by the firms, we were unable to provide a better cost estimate
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30. We also asked the sample firms to provide one-off cost estimates for making service
metrics and standing data available on their websites and via API. The estimated one-
off costs for making metrics and standing data available is between £50,000 and £2
million per firm.
35
31. Finally, we asked the sample of firms to estimate running costs of collecting the
metrics and standing data and making it available on websites and via API. The
estimated cost is between £17,000 and £200,000 per annum per firm.
36
32. Overall, our sample of firms expected one-off costs per firm of between £70,000
and £1.5 million for collecting data for all our proposed metrics, and £50,000 to £2
million for making these and standing data available on their websites and via API.
The sample of firms expected running costs of between £17,000 and £200,000 per
annum per firm. As noted above, given the widespread variation in the best estimates
provided by the sample for these metrics and the idiosyncratic nature of these costs,
we do not consider that we can scale up the costs for the industry with any degree of
precision. We therefore consider that it is not reasonably practicable for us to produce
an estimate of these costs
Q21: Do you have any comments on our CBA?
35 The £2 million cost estimate provided by one firm was much higher than other estimates.
36 The large variation in the cost range is due to the nature of responses from the firms in the data requests. Due to the limitation in our
sample and the costs provided by the firms, we were unable to provide a better cost estimate.
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Annex 3
Compatibility statement
Compliance with legal requirements
1. This Annex records the FCA’s compliance with a number of legal requirements
applicable to the proposals in this consultation, including an explanation of the FCA’s
reasons for concluding that our proposals in this CP are compatible with certain
requirements under the Financial Services and Markets Act 2000 (FSMA).
2. When consulting on new rules, the FCA is required by 138I(2)(d) of FSMA to include
an explanation of why it believes making the proposed rules is: (a) compatible with its
general duty, under s. 1B(1) of FSMA, so far as reasonably possible, to act in a way which
is compatible with its strategic objective and advances one or more of its operational
objectives; and (b) its general duty under s. 1B(5)(a) of FSMA to have regard to the
regulatory principles in s. 3B of FSMA. The FCA is also required by s. 138K(2) FSMA
to state its opinion on whether the proposed rules will have a significantly different
impact on mutual societies as opposed to other authorised persons.
3. In addition, this Annex explains how we have considered the recommendations made
by the Treasury under s. 1JA of FSMA about aspects of the economic policy of Her
Majesty’s Government to which we should have regard in connection with our general
duties.
4. This Annex includes our assessment of the equality and diversity implications of these
proposals.
5. Under the Legislative and Regulatory Reform Act 2006 (LRRA), the FCA is subject
to requirements to have regard to a number of high-level ‘Principles’ in the exercise
of some of our regulatory functions and to have regard to a ‘Regulators’ Code’ when
determining general policies and principles and giving general guidance (but not when
exercising other legislative functions like making rules). This Annex sets out how we
have complied with requirements under the LRRA.
The FCA’s objectives and regulatory principles: Compatibility statement
6. The proposals set out in this consultation are primarily intended to advance the FCA’s
operational objective to promote effective competition by:
• Making it easier for consumers to access and assess information about providers’
service, enabling them to make informed comparisons and choose the provider that
best suits their needs
• Incentivising BCA and PCA providers to improve their products, service and
performance.
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7. Although not the direct objective of the proposed rules, we will also enhance consumer
protection to the extent that the rules are a catalyst for current account providers to
improve their services offering to consumers’ needs, for example, at more times of
the day, or to avoid consumers being left without access to services, for example when
their debit card has stopped or when a person is left waiting to get access to a current
account under a power of attorney.
8. We consider these proposals are compatible with the FCA’s strategic objective of
ensuring that the relevant markets function well. They seek to address our findings
that there are barriers to accessing information about service quality, which contribute
to low consumer engagement. For the purposes of the FCA’s strategic objective,
relevant markets are defined by s. 1F of FSMA.
9. In preparing the proposals set out in this consultation, the FCA has had regard to the
regulatory principles set out in s. 3B of FSMA.
Theneedtouseourresourcesinthemostecientandeconomicway
10. We limit the burden on FCA resources by exploiting synergies with other measures
being implemented in this market by the FCA and other regulators over the same
time period. We are not requiring firms to report or submit data directly to the FCA.
Implementing these proposals will introduce new rules and guidance. These rules will
need to be supervised and may be enforced, but we do not think that this will impact on
our resourcing.
Theprinciplethataburdenorrestrictionshouldbeproportionatetothebenets
11. We believe that our proposals are proportionate to the benefits that we are seeking.
Competition in this market is not working effectively for many consumers, and barriers
to accessing service information are one of the causes. In considering our proposals,
we have sought to come up with a package of service metrics focused on the areas
of service that are most important and useful for consumers. We have discounted
measures where we thought the desired outcome was likely to be achieved through
other means. We have reduced the burden on firms by basing data required where
possible on data already collected by firms or using existing regulatory definitions
which are flagged in their IT systems.
The desirability of sustainable growth in the economy of the United Kingdom in
the medium or long term
12. We believe that our proposed remedies will increase competition in the current
account market with consumers benefitting from better service quality over time.
They should enable consumers to make informed and effective comparisons and
choices, and drive providers, both incumbents and challengers, to compete by
providing better products, service and performance. We see this as encouraging
sustainable growth in the sector. Disproportionate costs on firms whose brands have
fewer than 70,000 PCAs or 15,000 BCAs are avoided by exempting them from the
requirement to publish service information.
The general principle that consumers should take responsibility for their decisions
13. Our proposals are intended to encourage active and informed comparisons and
choice by consumers. Our qualitative research found that some consumers were
unaware they could receive a better service from another provider. It is difficult for
consumers to know whether they are getting good service for their current account
and consumers have little reason to shop around. This can result in poor outcomes as
customers continue to use products that are not the best for their needs or providing
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the best level of service. We, therefore, believe we are justified in implementing new
rules and guidance to encourage more active and informed decision-making by
consumers. Our proposals will empower more consumers to take responsibility for
those decisions.
The responsibilities of senior management
14. Senior managers will need to ensure compliance with our rules to measure and publish
service metrics.
Thedesirabilityofrecognisingdierencesinthenatureof,andobjectivesof,
businessescarriedonbydierentpersonsincludingmutualsocietiesandother
kinds of business organisation
15. We recognise that firms may have different business models. We believe all our
proposals should be applied consistently, and have taken account of the need to
ensure this takes place in our draft rules and guidance. We will not require firms whose
brands have fewer than 70,000 PCAs or 15,000 BCAs to comply with these rules as we
do not consider this proportionate. These firms will be able to opt-in to provide service
metrics.
The desirability of publishing information relating to persons subject to
requirements imposed under FSMA, or requiring them to publish information
16. Our proposals are compatible with this principle.
The principle that we should exercise our functions as transparently as possible
17. We announced our intention to undertake work to consider whether publication of
service metrics on a consistent basis could further our competition objective in our
response to the CMA’s retail banking review in November 2016. At this time we also
announced our intention to set up a stakeholder expert group (SEG) to inform this
work.
18. Throughout development of the metrics we have sought comment from stakeholders
through the SEG and sought feedback. We have supplemented this with bilateral
meetings and roundtable discussions. We have considered feedback provided by firms,
trade associations and consumer groups, and others when designing our proposals.
This CP provides another opportunity for stakeholder input and we welcome
stakeholder views.
19. In formulating these proposals, we have had regard to the importance of taking action
intended to minimise the extent to which it is possible for a business carried on by: (i)
an authorised person or a recognised investment exchange; or (ii) in contravention
of the general prohibition, to be used for a purpose connected with financial crime
(as required by s. 1B(5)(b) of FSMA). We recognise that our proposals could impact
on the thoroughness of firms’ anti-money laundering and fraud checks, including
customer due diligence (CDD) when opening an account. We will mitigate this by
providing guidance, and monitoring firms in this regard to ensure that the risk does not
materialise.
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Expectedeectonmutualsocieties
20. The FCA does not expect the proposals to have a significantly different impact on
mutual societies unless they choose to opt-in to publishing these metrics. Discussions
with the Building Societies Association which represents the interests of building
societies did not indicate that there were significantly different implications for them in
comparison to other firms.
21. We propose to exclude credit unions from the rules, as providing service information is
unlikely to be proportionate since membership requirements restrict customers’ ability
to choose their credit union and therefore credit unions ability to compete. However,
our rules do not prevent credit unions from publishing service information should they
wish to do so.
Equality and diversity
22. We are required under the Equality Act 2010 to ‘have due regard’ to the need to
eliminate discrimination, to foster good relations between people who share a
protected characteristic and those who do not and to promote equality of opportunity
in carrying out our policies, services and functions. As part of this, we conducted an
equality impact assessment to ensure that the equality and diversity implications of
any new policy proposals were considered.
23. We consider that availability of service metrics will have a positive impact for all
customers. Protected groups that may see a particular benefit include older people
and carers, because we are proposing a service metric on third party access via a
power of attorney. Allowing very small brands not to provide service information may
disproportionately impact customers of small foreign banks not actively competing for
UK customers. These customers will still have access to comparable information about
other banks. We do not expect them to receive a worse service than they currently
receive as a result of our proposals.
24. Overall, we do not consider that the proposals adversely impact any of the groups with
protected characteristics under the Equality Act 2010 but we will continue to consider
the equality and diversity implications of the proposals during the consultation period.
We will also revisit them when publishing the final rules.
Legislative and Regulatory Reform Act 2006 (LRRA)
25. We have had regard to the principles in the LRRA for the parts of the proposals that
consist of general policies, principles or guidance and consider that our proposal is:
• Transparent: We are following a consultation process in making these rules.
• Accountable: We are seeking feedback from this consultation paper on whether
stakeholders agree with our proposed approach.
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• Proportionate: We have carefully deliberated on our approach and believe our
proposals are proportionate. We have sought wherever possible to minimise costs
and we expect signicant benets.
• Consistent: Our proposed approach applies in a consistent manner.
• Targeted at situations in which action is needed, as explained in Chapter 2 of this CP,
we consider there to be a strong case for the introduction of these measures.
26. We have had regard to the Regulators’ Code for the parts of the proposals that consist
of general policies, principles or guidance. We consider that the proposals will be
effective in helping firms understand and meet regulatory requirements more easily,
in a manner that leads to improved outcomes for consumers and addresses the issues
identified in this market.
Treasury recommendations about economic policy
27. In developing our proposals, we have had regard to the Treasury’s recommendations to
us about aspects of the economic policy of the Government to which the FCA should
have regard when discharging its functions. In particular, our proposals should increase
competition and innovation in the retail banking market, leading to better outcomes
for consumers.
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Annex 4
Stakeholder expert group
1. The stakeholder expert group was established by the FCA to highlight the perspectives
of customers and of intermediaries (eg price comparison services and commentators
on retail banking) on service information.
2. Members were invited on the basis of their expertise in customer service in banking or
other relevant products and as representatives of stakeholder interests of consumers,
SME banking customers, or intermediaries/commentators on current account
providers. The following organisations were members of the group:
Association of Independent Professionals and the Self-Employed
British Bankers' Association
British Chambers of Commerce
Citizens Advice
Comparethemarket.com
Competition and Markets Authority
Consumer Council Northern Ireland
Confederation of British Industry
Defaqto
Enterprise Research Centre, Warwick Business School
Federation of Small Businesses
Fairer Finance
Financial Services Consumer Panel
Forum of Private Business
GoCompare
Institute of Customer Service
Institute of Directors
Money Advice Service
MoneySuperMarket and Money Saving Expert
National Association of Commercial Finance Brokers
Ofcom
The UK Regulators Network
Which?
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Annex 5
Metrics considered
1. This annex lists all of the metrics considered. Details of the process we followed to
arrive at the long and short-lists of metrics and the final metrics we are consulting on in
this CP are detailed in Chapters 3 and 4.
2. Details of the metrics vary between the long and short-list and the proposals in this
consultation. This is because we refined the metrics as we engaged stakeholders
including consumers, third parties, and firms. Metrics are shown in bold where a similar
metric is included in the rules in this consultation.
3. Long-list of metrics considered
4. The tables below list all 95 of the metrics considered by our SEG. These fall into six
categories:
• Availability of core services, resilience and cyber
• Issue resolution, payment issues and fraud
• Account opening, account use and product oering
• Channels and customer interaction
• BCA specic indicators (relationship management and lending)
• Others to consider alongside other FCA/Ombudsman Service/CMA information.
Availability of core services, resilience and cyber
Sub-category Indicator Measure type
1 Service
availability
Number of unplanned severe outages across the
rm aecting transactions per week/month/
year
Objective
2 Service availability Average length of severe outage across the rm
aecting transactions
Objective
3 Service
availability
Number of unplanned severe outages of mobile
app per week/month/year
Objective
4 Service availability Average length of severe outage of mobile app Objective
5 Service
availability
Number of unplanned severe outages of internet
banking per week/month/year
Objective
6 Service availability Average length of severe outage of internet
banking
Objective
7 Service availability Number of instances when customers could not
log in to mobile app or internet banking
Objective
8 Service availability Time of downtime on the bank's core services
during the course of a year
Objective
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9 Service availability Number of planned interruptions during working
hours
Objective
10 Service
availability
Number of unplanned severe outages of
telephone banking per week/month/year
Objective
11 Service availability Average length of severe outage of telephone
banking
Objective
Availability of core services, resilience and cyber
Availability Banking
12 Service availability Number of unplanned severe outages of ATMs per
week/month/year
Objective
13 Service availability Average length of severe outage of ATMs Objective
14 Resilience Track record on security/fraud Objective
15 Resilience Investment in technology and security Objective and
subjective
16 Cyber Statistics on breaches of cyber security Objective
17 Cyber Where data are held Objective
Issues resolution, payment issues and fraud
Sub-category Indicator Measure type
18 Issue resolution Call centre opening hours Objective
19 Issue resolution Availability of a UK contact centre Objective
20 Issue resolution % of calls answered within a particular time period Objective
21 Issue resolution Average length of time taken to resolve a
customer query/issue, by channel
Objective
22 Issue resolution Average length of time until a call is answered, by
time period (peak/ o peak)
Objective
23 Issue resolution Average call abandonment rate Objective
24 Issue resolution Average tenure of call centre workers Objective
25 Issue resolution Ratio of incoming calls to operatives Objective
26 Issue resolution Average number of sta customers have to speak
to resolve the query/issue
Objective
27 Issue resolution Whether the bank can be contacted online via
secure message
Objective
28 Issue resolution Average length of time it takes to receive a
response to an online secure message
Objective
29 Issue resolution Average length of time it takes to receive a
response to an online secure message
Objective
30 Issue resolution Record keeping policies on information related to
problems reported by customers
Objective
31 Payment issue Number of payment errors per 1000 accounts Objective
32 Payment issue Proportion of error transactions that were judged
to be the fault of the bank
Objective
33 Payment issue % of payments not made the same day when
customer met criteria
Objective
34 Fraud Track record on fraud Objective
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Issue resolution, payment issues and fraud
35 Fraud Statistics on fraud Objective
36 Fraud Average cost of fraud per customer (or another
measure on fraud levels)
Objective
37 Fraud Average length of time taken to receive a
refund for anunauthorised transaction/ % of
unauthorised transaction refunded.
Objective
Accountopening,accountuseandproductoering
Sub-category Indicator Measure type
38 Account Opening Documents needed to open an account for BCA
and PCA
Objective
39 Account Opening Average number of days between account
application to account being fully functional
(card/PIN received, direct debits transferred
etc.), split by product (current account, savings,
loans etc.)
Objective
40 Account Opening % of customers switching bank account per year Objective
41 Account Opening Quality of communications when opening the
account (clarity, completeness, accuracy)
Subjective
42 Account Opening Average number of employees/directors needed
to verify account opening (BCA only)
Objective
43 Account use Ease of use of banking services Subjective
44 Account use Flexibility of bank's systems to deal with unusual
circumstances
Subjective
45 Account use The extent to which rms assist or inhibit money
management
Subjective
46 Account use Channels available to manage accounts Objective
47 Product Oering Information about product features available Objective
48 Product oering Loyalty rewards oered by rm Objective
Channels and customer interaction
Sub-category Indicator Measure type
49 Branches Number of branches in the UK, by region Objective
50 Branches Number of branches outside the UK Objective
51 Branches Countries where the provider has a branch Objective
52 Branches % of branches open outside normal business
hours
Objective
53 Branches Access to self-serve options in branch (i.e. how
many cash points, pay in machines are available)
Objective
54 Branches Access to sta in branch Objective
55 Branches Number of customer-facing sta in each branch,
by position (e.g. teller, personal bankers etc.).
Objective
56 Branches Number of sta employed in branch who can
complete
Objective
57 Branches Ratio of sta to customer footfall in branch Objective
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58 Branches Branch opening times Objective
Channels and customer interaction
59 Branches Average queuing time for cashier per branch Objective
60 Branches Average length of time it takes to make an
appointment to speak to an adviser
Objective
61 Branches Quality of branch sta (professionalism,
knowledge, politeness)
Objective
62 Customer
Interaction
How easy it is for customers to contact their
bank
Objective and
subjective
63 Customer
Interaction
The extent to which rms keep to promises Subjective
64 Customer
Interaction
Quality of communications (clarity, completeness,
accuracy, volume, bank lets the customer know
when they can get better products)
Subjective
65 Customer
Interaction
Quality of contact with sta (i.e. bank sta listen
and respond to the customer's needs; sta are
sensitive in dealing with unusual situations; friendly
sta)
Subjective
66 Customer
interaction
Readily available information on the website Objective and
subjective
67 Internet Banking Number of transactions which can be completed
via internet banking or mobile app
Objective
68 Internet Banking Number of administrative tasks which can be
completed via internet banking or mobile app
Objective
69 Internet Banking Availability of telephone banking without menus Objective
BCAspecicindicators(relationshipmanagementandlending)
Sub-category Indicator Measure type
70 Lending Time taken to receive overdraft (from application
to overdraft being available)
Objective
71 Lending Documents are needed to apply for overdraft Objective
72 Lending Average size of approved overdraft Objective
73 Lending Approved overdraft as a proportion of applied
overdraft
Objective
74 Lending Time taken to receive SME lending (from
application to lending being available)
Objective
75 Lending Proportion of BCA customers who have one or
more SME lending products
Objective
76 Lending Whether provider subscribes to regimes in place
to allow businesses to access specialist nancial
services with condence, for example, the
Lending Code
Objective
77 Relationship
management
Proportion of SMEs with a relationship manager Objective
78 Relationship
management
Average frequency of contact with relationship
manager
Objective
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79 Relationship
management
By branch, average number of SMEs per
relationship manager
Objective
BCAspecicindicators(relationshipmanagementandlending)
80 Relationship
management
By branch, average number of sectors covered by
relationship manager
Objective
81 Relationship
management
Proportion of customers using automated
account managers
Objective
82 Relationship
management
Criteria which SMEs need to meet in order to have
a dedicated account/ relationship manager
Objective
83 Relationship
management
Data relating to the number of employees
with relevant qualications, memberships at
professional bodies, have achieved a professional
standard
Objective
Others to consider alongside other FCA/Ombudsman Service /CMA
Information
Sub-category Indicator Measure type
84 Complaint
handling
Satisfaction with speed and accuracy of
complaints handling
Subjective
85 Complaint
handling
Number of complaints per 1000 accounts Objective
86 Complaint
handling
Number of complaints regarding switching per
1000 accounts
Objective
87 Complaint
handling
% of complaints resolved within three business
days
Objective
88 Complaint
handling
Average number of days to resolve a complaint
(need clear guidelines on what constitutes a
complaint)
Objective
89 Regulatory
history
Regulatory history, including nes for breaches of
regulatory rules and redress packages
Objective
90 Satisfaction Would recommend provider/ satisfaction with
provider
Subjective
91 Satisfaction Satisfaction with digital oering Subjective
92 Satisfaction Satisfaction with internet banking Subjective
93 Satisfaction Satisfaction with mobile app Subjective
94 Satisfaction Satisfaction with branch service Subjective
95 Satisfaction Satisfaction with telephone banking Subjective
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Shortlist of metrics
5. The following short-list of metrics was developed from the long-list following
consultation with our SEG. Indicators in this short-list were tested with consumer and
SME respondents in our qualitative research. They fall into five main categories:
• Communicating with the bank
• Resolution of issues and complaints
• Technical service reliability
• Ease of opening an account local branch oering.
6. Respondents’ views on each of the indicators is detailed in the research report
‘Understanding customer views on current account service indicators’ published along
with this consultation.
37
Communicating with the bank
Indicator Measure type
1 Response times through dierent channels Objective
2 Access outside normal business hours Objective
3 Customer satisfaction after communicating with the bank Subjective
4 Service satisfaction of customers in vulnerable circumstances Subjective
Resolution of issues and complaints
Indicator Measure type
5 Time taken for bank to contact you in regards to suspicious activity Objective
6 Response times / average time taken to resolve issues Objective
7 Customer satisfaction with complaints Subjective
8 Customer satisfaction with treatment when there is fraud/
suspicious activity on their account
Subjective
9 Number of customer complaints that the bank rejects but the
Ombudsman service supports
Objective
Ease of opening an account
Indicator Measure type
10 Time taken for the account to become fully functional Objective
11 Clear information on where to open an account (eg online or in
branch)
Objective
12 Type and number of documents required to open an account Objective
13 % of applicants rejected for a current account Objective
14 Time taken to get an appointment in branch to open an account Objective
Technical service reliability
Indicator Measure type
15 Frequency of severe service outages (through dierent channels) Objective
37 Link to research report
59
CP17/24
Annex 6
Financial Conduct Authority
Information about current account services
Localbranchoering
Indicator Measure type
22 Average number of self-service terminals in branch Objective
23 Number of customer facing sta in each branch, by position Objective
24 Average waiting time for an appointment with an advisor Objective
25 Range of services available at most branches Objective
SMEspecicmetrics
Indicator Measure type
26 Criteria to have a dedicated Relationship Manager (RM) Objective
27 Proportion of SME customers with RM Objective
28 Number of sectors covered by RM by branch Objective
29 Number of SMEs per RM Objective
30 Time taken to get an overdraft granted Objective
31 Time taken to get a loan granted Objective
32 Number of sta required to open the account Objective
33 Documents needed to apply for an overdraft/loan Objective
16 Number of instances when customers could not log-in to mobile or
internet banking services
Objective
17 Length of time the bank's core services are down Objective
18 Reason for service outages Objective
19 Customer satisfaction with log-in process Subjective
20 Number/time of planned interruptions during working hours Objective
21 Time of day most major incidents have occurred Objective
60
CP17/24
Annex 6
Financial Conduct Authority
Information about current account services
Annex 6
Abbreviations used in this paper
this paper
API Application programming interface
BBA British Bankers Association
BCA business current account
BCOBS Banking: Conduct of Business sourcebook
BSA The Building Societies Association
CBA Cost-benefit analysis
CDD Customer due diligence
CP Consultation Paper
CMA Competition and Markets Authority
DISP Dispute Resolution: Complaints sourcebook
EBA European Banking Authority
FCA Financial Conduct Authority
FSMA The Financial Services and Markets Act 2000
LRRA Legislative and Regulatory Reform Act 2006
PAD Payment Accounts Directive
PARs Payment Accounts Regulations 2015
PCA personal current account
PSD2 Second Payment Services Directive
SEG stakeholder expert group
SME small and medium sized enterprise
61
CP17/24
Financial Conduct Authority
Information about current account services
We have developed the policy in this Consultation Paper in the context of the existing UK and EU
regulatory framework. The Government has made clear that it will continue to implement and apply
EU law until the UK has left the EU. We will keep the proposals under review to assess whether any
amendments may be required in the event of changes in the UK regulatory framework in the future.
We make all responses to formal consultation available for public inspection unless the respondent
requests otherwise. We will not regard a standard condentiality statement in an email message as a
request for non-disclosure.
Despite this, we may be asked to disclose a condential response under the Freedom of Information
Act 2000. We may consult you if we receive such a request. Any decision we make not to disclose the
response is reviewable by the Information Commissioner and the Information Rights Tribunal.
All our publications are available to download from www.fca.org.uk. If you would like to receive this
paper in an alternative format, please call 020 7066 9644 or email: publications_graphics@fca.org.uk
or write to: Editorial and Digital team, Financial Conduct Authority, 25 The North Colonnade, Canary
Wharf, London E14 5HS
FCA 2017/XX
[Editor’s note: the text in this instrument takes into account the changes proposed by CP17/11 ‘Implementation
of the Payment Services Directive (PSD2): draft Approach Document and draft Handbook changes’ (April
2017) as if they were made.]
BANKING (INFORMATION ABOUT CURRENT ACCOUNT SERVICES)
INSTRUMENT 2017
Powers exercised
A. The Financial Conduct Authority makes this instrument in the exercise of the
following powers and related provisions in the Financial Services and Markets Act
2000 (the “Act”):
(1) section 137A (General rule-making power);
(2) section 137T (General supplementary powers); and
(3) section 139A (Guidance).
B. The rule-making powers listed above are specified for the purpose of section 138G(2)
(Rule-making instruments) of the Act.
Commencement
C. This instrument comes into force on [1 April 2018].
Amendments to the Handbook
D. The Banking: Conduct of Business sourcebook (BCOBS) is amended in accordance
with the Annex to this instrument.
Citation
E. This instrument may be cited as the Banking (Information about Current Account
Services) Instrument 2017.
By order of the Board
[date] 2017
FCA 2017/XX
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Annex
Amendments to the Banking: Conduct of Business sourcebook (BCOBS)
Part 1: amendments to BCOBS 1
In this Part, underlining indicates new text and striking through indicates deleted text.
1
Application
1.1
General application
…
Limitations on the general application rule
…
1.1.5
R
BCOBS 2.2A, BCOBS 4.1.2G(2A) to (2E), (3A), (6A) and (6B), BCOBS
4.1.4AG(2)(a), BCOBS 5.1.3AG, BCOBS 5.1.3BG, BCOBS 5.1.5AR,
BCOBS 5.1.5BG, and BCOBS 5.1.13R and BCOBS 7 (apart from BCOBS
7.1.4R and 7.1.5G) do not apply to a credit union.
Part 2: insertion of BCOBS 7
In this Part, all the text is new text.
7
Information about current account services
7.1
Application
What?
7.1.1
R
(1)
This chapter requires a firm to publish information about its
provision of personal current accounts and business current accounts.
(2)
In this chapter:
(a)
a “personal current account” means an account, other than a
current account mortgage or a premium service account,
which is a payment account within the meaning of the
Payment Accounts Regulations (see BCOBS 7.1.3G(2));
(b)
a “business current account” means an account which would
be a personal current account if the banking customer were a
FCA 2017/XX
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consumer (with the definition of “personal current account”
in (2)(a) applying for the purposes of this sub-paragraph as if
the words “or a premium service account” were omitted) (see
BCOBS 7.1.3G(3)); and
(c)
a “premium service account” means an account of a type:
(i)
in respect of which banking customers receive better
or faster service, assessed by reference to any of the
information which the firm must publish under this
chapter, than that provided in respect of one or more
other types of personal current account held with the
firm under the relevant trading name;
(ii)
which requires the banking customer to do either or
both of the following:
(A)
maintain a credit balance in the account,
exceeding an amount specified by the firm,
and
(B)
make deposits into the account each month,
exceeding an amount specified by the firm;
and
(iii)
which is held by fewer than 10% of the holders of
personal current accounts held with the firm under the
relevant trading name (with the definition of “personal
current account” in (2)(a) applying for the purposes of
this sub-paragraph as if the words “or a premium
service account” were omitted).
Who?
7.1.2
R
(1)
This chapter applies to a firm in relation to a current account
measurement period (see BCOBS 7.7.1R):
(a)
in respect of personal current accounts held with the firm
under a trading name of the firm, if:
(i)
at the start of the current account measurement period,
70,000 or more personal current accounts are held
with the firm under that trading name; and
(ii)
70,000 or more personal current accounts were held
with the firm under that trading name throughout the
previous two current account measurement periods;
and
(b)
in respect of business current accounts held with the firm
under a trading name of the firm, if:
FCA 2017/XX
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(i)
at the start of the current account measurement period,
15,000 or more business current accounts are held
with the firm under that trading name; and
(ii)
15,000 or more business current accounts were held
with the firm under that trading name throughout the
previous two current account measurement periods.
(2)
This chapter does not apply in relation to an account held by a
banking customer in respect of whom the main correspondence
address held by the firm is outside the United Kingdom.
(3)
This chapter does not apply to a credit union.
(4)
But this rule is subject to BCOBS 7.1.4.R.
7.1.3
G
(1)
This chapter applies to a firm separately in relation to personal
current accounts and business current accounts, for each of its trading
names as notified to the FCA in accordance with SUP 16 Annex
16AR. For example, a firm which only has 50,000 personal current
accounts and no business current accounts will not be subject to the
requirements of this chapter (except where BCOBS 7.1.4R applies).
If a firm has two trading names, with 150,000 personal current
accounts held with the firm under the first name and 50,000 personal
current accounts under the second name, and only 10,000 business
current accounts, the requirements of this chapter will apply to the
firm only in respect of the first trading name and only in respect of
personal current accounts (except where BCOBS 7.1.4R applies). The
numbers in BCOBS 7.1.1R and 7.1.2R apply to the number of
accounts, rather than the number of account holders.
(2)
The definitions of “personal current account” and “business current
account” both refer to the definition of a “payment account” under
the Payment Account Regulations, that is: “an account held in the
name of one or more consumers through which consumers are able to
place funds, withdraw cash and execute and receive payment
transactions to and from third parties, including the execution of
credit transfers, but does not include any of the following types of
account provided that the account is not used for day-today payment
transactions: savings accounts; credit card accounts where funds are
usually paid in for the sole purpose of repaying a credit card debt;
current account mortgages or e-money accounts”.
(3)
The FCA has issued guidance on that definition: see FG16/6 –
Payment Account Regulations 2015. A payment account under the
Regulations is one which is held by a consumer, namely a natural
person acting for purposes which are outside that person’s trade,
business, craft or profession. A business current account (defined in
BCOBS 7.1.1R(2)(b)) is not a payment account because it is not held
by a consumer, but is one which would be a payment account if the
account holder were a consumer. The exclusion of “premium service
FCA 2017/XX
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accounts” (see (7)) does not apply to business current accounts.
(4)
Accounts held by banking customers whose main correspondence
address is outside the United Kingdom are excluded both from the
number of accounts and from the requirements of BCOBS 7.3 to 7.6.
(5)
BCOBS applies only to the activity of accepting deposits from
banking customers carried on from an establishment maintained by it
in the United Kingdom (see BCOBS 1.1.1R). Therefore, this chapter
only applies to accounts operated and activities carried out from
United Kingdom branches and not, where a firm also has branches
outside the United Kingdom, from non-United Kingdom branches.
(6)
BCOBS 7.1.2R also makes provision for firms whose current account
businesses are growing or contracting. For example, a firm which
passes the 70,000 threshold for the first time on 29 March and then
stays above it, will have to measure the time it takes do to those
things which BCOBS 7.3 to 7.6 require to be measured starting from
1 October, and publish its first statistics (relating to the period from 1
October to 31 December) on or before 15 February of the following
year. It will also have to publish the other information required by
BCOBS 7.3 to 7.6 from 1 October. (See BCOBS 7.7.1R.)
(7)
Premium service accounts are excluded from BCOBS 7.3 to 7.6.
Premium service accounts are those personal current accounts which
have eligibility criteria relating to minimum balances or minimum
monthly deposits (or both), and whose holders receive better service
than non-premium service accounts, based on any of the information
or data which this chapter requires a firm to publish. For example, an
account which has staff available to respond to relevant queries
through telephone banking for more hours of the day than other
accounts, or whose account holders can replace a lost debit card more
quickly than other accounts, would be a premium service account.
But an account is not a premium service account for this purpose if
accounts of that type of account are held by 10% or more of the
firm’s personal current account banking customers (treating all
accounts as non-premium for the purposes of the 10% calculation).
7.1.4
R
(1)
This rule applies to a firm to which this chapter does not otherwise
apply in respect of either or both of personal current accounts and
business current accounts held under a particular trading name.
(2)
This rule applies to information which covers the same subject
matter as any of the following rules (“regulated information”):
(a)
BCOBS 7.3.5R(1) (information about the speed of the
account opening process);
(b)
BCOBS 7.4.1.R(1) (information about the time taken to
replace a lost, stolen or stopped debit card);
FCA 2017/XX
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(c)
BCOBS 7.4.5.R(1) (information about the speed with which a
firm can give an attorney access to a personal current account
and enable the attorney to take various actions in relation to
the account); and
(d)
BCOBS 7.6.1.R(1) (information about operational and
security resilience).
(3)
The firm must not publish any regulated information or include any
regulated information in a communication or financial promotion
addressed to a banking customer or a potential banking customer,
unless the information that the firm publishes or includes
(a)
would meet the requirements of BCOBS 7.3.5R(2), BCOBS
7.4.1R(2) , BCOBS 7.4.5R(2) or BCOBS 7.6.1R(2), as the
case may be, and
(b)
had been calculated in accordance with the requirements of
this chapter,
as if the firm were a firm to which this chapter (apart from this rule)
applied in respect of that information in relation to that trading name.
7.1.5
G
If a firm does not have 70,000 personal current accounts, or 15,000 business
current account, under a particular brand (i.e. trading name), this chapter
does not require the firm to publish information about its personal current
account service and/or its business account service (as relevant) for that
brand. However, if a firm chooses to publish information about that brand
that is within the scope of any of the rules in his chapter that relate to speed
of service or operational and security resilience (‘regulated information’),
the firm must comply with the relevant rule in full as if this chapter did
apply to that brand. This means that they must measure and calculate the
information to be published, and publish it, as required by this chapter. The
same applies to a credit union that publishes any regulated information.
7.2
What information is to be published and how is it to be measured?
Publication of information about personal current accounts and business current
accounts
7.2.1
R
(1)
A firm to which this chapter applies must publish the information and
statements specified in BCOBS 7.3 to 7.6:
(a)
separately, in relation to each trading name in respect of
which the firm has 70,000 or more personal current accounts;
(b)
separately, in relation to each trading name in respect of
which the firm has 15,000 or more business current accounts;
and
FCA 2017/XX
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(c)
subject to (2), separately for personal current accounts and
business current accounts in relation to each of those trading
names.
(2)
Where any of the information or statements which a rule in (3)
requires a firm to publish is the same for both personal current
accounts and business current accounts, the firm may publish a single
set of information or a single statement for both personal current
accounts and business current accounts.
(3)
The rules are:
(a)
BCOBS 7.3.1R (information needed to open a current
account);
(b)
BCOBS 7.3.3R (information about how an account may be
opened); and
(c)
BCOBS 7.5.1R and 7.5.2R (information about the availability
of certain services and helplines).
7.2.2
G
(1)
Where a firm is subject to this chapter in respect of more than one
trading name, BCOBS 7.2.1R requires the firm to publish separate
information for each of its trading names. And where a firm is
subject to this chapter in respect of both personal current accounts
and business current accounts, BCOBS 7.2.1R requires the firm to
publish separate information for personal current accounts and
business current accounts, for each trading name. (BCOBS 7.2.1R(3)
provides for an exception, where standing information about
personal current accounts and business current accounts is the same:
in that case, the firm may publish a single set of information required
by the rules listed in BCOBS 7.2.1R(3) but should indicate that it
applies to personal current accounts and business current accounts.)
(2)
But the following rules apply to personal current accounts and
business current accounts separately: firms should not publish a
single set of information covering both categories. These rules apply
to the category as a whole and not to different types of product or
account within those two categories. If a firm offers more than one
type of current account within either or both of those two categories
under the same trading name, the information in relation to all those
types of account is to be aggregated within the relevant category. The
rules are:
(a)
BCOBS 7.3.5R(1) (information about the speed of the account
opening process);
(b)
BCOBS 7.4.1.R(1) (information about the time taken to
replace a lost, stolen or stopped debit card);
(c)
BCOBS 7.4.5.R(1) (information about the speed with which a
FCA 2017/XX
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firm can give an attorney access to a personal current account
and enable the attorney to take various actions in relation to
the account); and
(d)
BCOBS 7.6.1.R(1) (information about operational or security
resilience).
(3)
BCOBS 7.4.3R and 7.4.5R only apply in respect of personal current
accounts. Firms do not need to publish information under those rules
in respect of business current accounts.
7.2.3
R
For the purposes of BCOBS 7.3 to 7.6:
(1)
a working account number is to be treated as generated for a banking
customer only when the account number has been issued to the
banking customer and the banking customer is able to make deposits
into the account;
(2)
a thing is be treated as issued to a person:
(a)
on the same day, if the person receives it that day; else
(b)
on the day on which the person would ordinarily be expected
to receive it, in accordance with the delivery method by
which the firm sent it;
(3)
a reference to an average number of days is a reference to the mean,
expressed as a whole number of days;
(4)
“telephone banking” means a facility provided by the firm, other than
mobile banking, which enables a banking customer to use voice
telephony to ascertain the balance on an account and initiate a
payment transaction on the account;
(5)
“mobile banking” means a software application provided by the firm
which enables a banking customer, by use of an electronic device
(including a smartphone, a tablet computer and a desktop computer)
on which that application is installed, to ascertain the balance on an
account and initiate a payment transaction on the account;
(6)
“internet banking” means a facility provided by the firm, other than
mobile banking, which enables a banking customer to use the
internet to ascertain the balance on an account and initiate a payment
transaction on the account; and
(7)
internet banking is to be treated as enabled only when the firm has
issued all information, and any devices specific to the firm (for
example, a card reader), necessary for the banking customer or
attorney to use internet banking.
7.2.4
G
(1)
BCOBS 7.2.3R(2) specifies that a thing is to be treated for the
purposes of BCOBS 7.3 to 7.6 as having been issued to a banking
FCA 2017/XX
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customer only when the banking customer would ordinarily be
expected to have received it. For example, if a debit card is sent to a
customer by first class post, it will be treated under BCOBS 7.2.3R(2)
as issued on the day after the day on which is was posted (or, if
posted on a Saturday, as issued on the Monday).
(2)
When counting the number of days taken:
(a)
firms should count each part of a day as a whole day (but the
day from which the thing is to be counted may be
disregarded); and
(b)
a thing done on the following day should be counted as done
within one day.
(3)
Where BCOBS 7.3 to 7.5 require a percentage or an average to be
published, the percentage is to be expressed as an integer and an
average is to be expressed as a whole number of days, with a
fractional part of a figure which is 0.5 or over being rounded up and
a fractional part of less than 0.5 being rounded down.
7.3
Account opening information
Information needed to open a current account
7.3.1
R
(1)
In relation to each type of personal current account and each type of
business current account that it offers, a firm must publish either:
(a)
a statement that the firm has published a list of the
information and documents which, as a minimum, the firm
requires to open an account for a banking customer who is
not currently a customer of the firm; or
(b)
a statement that the firm does not publish such a list.
(2)
A firm must not publish a statement as in (1)(a) unless the statement
either includes the list or indicates where the list is available.
(3)
For the purposes of (2), a list is not to be treated as available unless it
has been published in the same manner as the statement in (1).
7.3.2
G
(1)
BCOBS 7.3.1R requires a firm to publish a statement indicating
whether or not a list is available of the minimum information and
documents necessary to open each type of account that it offers. That
list must itself be published on the firm’s website: this is the effect of
BCOBS 7.3.1R(3) and BCOBS 7.7.2R. The statement must either
include the list or provide a link to it.
(2)
The list should set out the minimum information and documents that
the firm needs to open each type of account that it offers, for a new
FCA 2017/XX
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customer. For example, the list might specify what types of proof of
identity or proof of address the firm requires, whether they must be
original copies or certified copies, etc.
(3)
Firms have discretion about how to present the list. If the list is the
same for all, or most, of their accounts, they may choose to publish a
single list and indicate any exceptions or differences that relate to
particular accounts.
(4)
In individual cases, the firm’s obligations under the Money
Laundering Regulations, or its other anti-fraud procedures, might
mean that the firm requires additional or more particular information
or documents to open an account: BCOBS 7.3.1R does not affect a
firm’s responsibility for discharging those obligations or carrying out
those procedures fully and properly.
(5)
Firms may wish to include a comment in their statement that
additional information or documents may be required on a case-by-
case basis. But BCOBS 7.3.1R does not prevent a firm from
publishing a more comprehensive list if it wishes to do so.
Information about how an account may be opened
7.3.3
R
(1)
In relation to each type of personal current account and each type of
business current account that it offers, a firm must publish
information about whether it is possible to open the account:
(a)
without visiting a branch;
(b)
where a visit to a branch is required, without an appointment;
(c)
on the basis of documents and information supplied in
electronic form; and
(d)
by post.
(2)
Unless the information is true in all cases, the information must
include a statement to the effect that, although the information may
be true for some cases, it may not be true in all cases.
7.3.4
G
BCOBS 7.3.3R requires a firm to publish information about the manner in
which an account may be opened. The firm has discretion over how the
information is presented; for example, it may choose to make a series of
statements, or present the information in a table.
Information about the speed of the account opening process
7.3.5
R
(1)
This rule applies to information about the speed with which a firm
can open an account.
(2)
A firm must publish the information in (3) about each of the
following things done in a current account measurement period (see
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BCOBS 7.7.1R):
(a)
generating a working account number for a banking customer
who is not already a customer of the firm;
(b)
issuing a debit card to a banking customer who requests one
as part their application to open the account or for whom
issue of a debit card is a term or condition of the account
contract;
(c)
enabling internet banking for a banking customer who
requests it as part their application to open the account or for
whom provision of internet banking is a term or condition of
the account contract; and
(d)
providing credit under an authorised non-business overdraft
agreement or an authorised business overdraft agreement
where the banking customer has requested such credit as part
of their application to open the account.
(3)
The information is:
(a)
the percentage of banking customers for whom the firm did
that thing on the same day;
(b)
the average number of days the firm took to do that thing; and
(c)
the number of days within which the firm did that thing for
99% of banking customers for whom that thing was done.
(4)
The firm must use the words specified in Table 1 of BCOBS 7 Annex
1R when publishing that information about those things.
(5)
For the purposes of (2)(a) and (3):
(a)
where the firm has published a list under BCOBS 7.3.1R in
relation to that type of account:
(i)
the firm need only publish information about those
cases where the firm does not require any information
or documents additional to those specified on that list;
and
(ii)
the number of days taken to generate a working
account number is to be counted from receipt of a
complete application which includes all the
information and documents specified on the list;
(b)
where the firm has not published a list under BCOBS 7.3.1R
in relation to that type of account, the number of days taken
to generate a working account number is to be counted from
receipt of an application (irrespective of whether the
FCA 2017/XX
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application is complete, or the firm requires information or
documents not included in or submitted with the application).
(6)
For the purposes of (2)(b), (2)(c), (2)(d) and (3), the number of days
taken is to be counted from the day on which the firm generates a
working account number for the banking customer.
7.3.6
G
(1)
Firms must publish information under BCOBS 7.3.6R(3) separately
for each of their trading names, and separately for personal current
accounts and business current accounts for each of their trading
names. (See BCOBS 7.2.1R(1).)
(2)
Firms can choose how and where they publish information under
BCOBS 7.3.5R, provided that they use the language in Table 1 of
BCOBS 7 Annex 1R and comply with BCOBS 7.7.2R. These rules do
not prevent a firm from using its own font or presentational style,
provided that the language in Table 1 is used and the information is
easily accessible.
(3)
Each of the things mentioned in BCOBS 7.3.5R(2) should be
measured and published in relation to the current account
measurement period in which that thing is done, irrespective of the
current account measurement period in which each of those other
things is done and irrespective of the current account measurement
period in which the banking customer submitted the application for
the account.
(4)
If the firm has published a list of the minimum information and
documents it needs to open the account under BCOBS 7.3.1R, it need
only measure the time taken to generate a working account number
for those straightforward cases where it does not need to request
additional information or documents from the banking customer. If
the firm has not published such a list, it should measure the time
taken to generate a working account number from receipt of an
application, irrespective of whether the application is complete or the
firm requires additional information or documents not included in the
application.
(5)
The firm should only treat credit as having been provided, for the
purposes of BCOBS 7.3.5R(2)(c), when the funds under an arranged
overdraft granted at the time of account opening are available for the
banking customer to withdraw. An arranged overdraft with a limit
other than that requested should be counted; if no overdraft is
granted, the account should not be counted for the purposes of
BCOBS 7.3.5R(2)(c).
(6)
Firms are reminded of their obligations under CONC 5.2
(Responsible lending) to carry out a creditworthiness assessment
before entering into an agreement for an arranged overdraft. Firms
are also reminded of their obligations under the Money Laundering
Regulations. Firms should discharge those obligations, and carry out
FCA 2017/XX
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any other appropriate affordability and anti-fraud checks, fully and
properly without curtailing or omitting them for the purposes of the
information to be published under BCOBS 7.
7.4
Information about certain services requested at a time later than the opening
of an account
Time taken to replace a stolen, lost or stopped debit card
7.4.1
R
(1)
This rule applies to information about the time it takes a firm to
replace a debit card which has been lost, stolen or stopped.
(2)
The firm must publish the following information about debit cards
replaced in the relevant current account measurement period (see
BCOBS 7.7.1R):
(a)
the percentage of debit cards which the firm replaced on the
same day;
(b)
the average number of days the firm took to replace a debit
card; and
(c)
the number of days within which the firm replaced 99% of
the debit cards it replaced.
(3)
The firm must use the words specified in Table 2 of BCOBS 7 Annex
1R when publishing that information.
(4)
For the purposes of this rule:
(a)
the time taken is to be counted from the earlier of the day on
which:
(i)
the debit card is reported to the firm as lost or stolen;
and
(ii)
the firm stopped the debit card for any other reason;
and
(b)
a debit card is to be treated as replaced only when both the
card and (where relevant) personal identification number
have been issued to the banking customer.
7.4.2
G
(1)
The time taken to issue a replacement debit card need not include
activation of the card.
(2)
Firms are reminded that regulation 71(6) of the Payment Services
Regulations requires a payment service provider to allow the use of
the payment instrument or replace it with a new payment instrument
“as soon as practicable” after the reasons for stopping its use cease to
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exist.
Information needed to give an attorney access to a personal current account
7.4.3
R
(1)
In relation to each type of personal current account that it offers, a
firm must publish either:
(a)
a statement that the firm has published a list of the
information and documents which, as a minimum, the firm
requires to give an attorney access to an account; or
(b)
a statement that the firm does not publish such a list.
(2)
A firm must not publish a statement as in (1)(a) unless the statement
either includes the list or indicates where the list is available.
(3)
For the purposes of (2), a list is not to be treated as available unless it
has been published in the same manner as the statement in (1).
(4)
In this rule and in BCOBS 7.4.5R:
(a)
an “attorney” means an attorney under:
(i)
in England and Wales, a power of attorney, a lasting
power of attorney or an enduring power of attorney;
or
(ii)
in Scotland, a general power of attorney or a
continuing power of attorney; or
(iii)
in Northern Ireland, a power of attorney or an
enduring power of attorney; and
(b)
an attorney is given access to an account when the firm has
informed the attorney that the firm recognises the attorney’s
entitlement to ascertain the balance on the account and obtain
information about payment transactions on the account.
7.4.4
G
(1)
BCOBS 7.4.3R requires a firm to publish a statement indicating
whether or not a list is available of the minimum information and
documents necessary for the firm to give an attorney access to each
type of personal account that it offers. That list must itself be
published on the firm’s website; the statement must either include the
list or provide a link to it. The list should set out the minimum
information and documents that the firm needs. For example, the list
might specify what documents and what types of proof of identity or
proof of address the firm requires, whether they must be original
copies or certified copies, and how and by whom those copies should
be certified.
(2)
Firms have discretion about how to present the list. If the list is the
same for all, or most, of their personal current accounts, they may
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choose to publish a single list and indicate any exceptions or
differences that relate to particular accounts.
(3)
In individual cases, the firm’s obligations under the Money
Laundering Regulations, or its other anti-fraud procedures, might
mean that the firm requires additional or more particular information
or documents: BCOBS 7.4.3R does not affect a firm’s responsibility
for discharging those obligations or carrying out those procedures
fully and properly.
(4)
Firms may wish to include a comment in their statement that
additional information or documents may be required on a case-by-
case basis. But BCOBS 7.4.3R does not prevent a firm from
publishing a more comprehensive list if it wishes to do so.
(5)
For the purposes of BCOBS 7.4.3R and 7.4.5R, “access” to an
account for an attorney means the attorney being able to check the
balance on the account and obtain information about transactions on
the account. Access is granted when the firm acknowledges the
attorney’s right to access: for the purposes of the rules, this may be
done orally or in writing.
Giving an attorney access to an account and enabling an attorney to operate an
account
7.4.5
R
(1)
This rule applies to information about the speed with which a firm
can give an attorney access to a personal current account and enable
the attorney to take various actions in relation to the account.
(2)
A firm must publish the information in (3) about each of the
following things done in a current account measurement period (see
BCOBS 7.7.1R):
(a)
giving an attorney access to a personal current account;
(b)
issuing a debit card to an attorney, where the attorney has
requested one;
(c)
enabling internet banking for an attorney, where the attorney
has requested it; and
(d)
enabling an attorney to withdraw money and initiate payment
transactions, where the attorney has requested that ability.
(3)
The information is:
(a)
the percentage of attorneys for whom the firm did that thing
on the same day;
(b)
the average number of days the firm took to do that thing; and
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(c)
the number of days within which the firm did that thing for of
99% of attorneys for whom that thing was done.
(4)
The firm must use the words specified in Table 3 of BCOBS 7 Annex
1R when publishing that information about those things.
(5)
For the purposes of (2)(a) and (3):
(a)
where the firm has published a list under BCOBS 7.4.3R in
relation to that type of account:
(i)
the firm need only publish information about those
case where the firm does not require any information
or documents additional to those specified on that list;
and
(ii)
the number of days taken to give the attorney access is
to be counted from receipt of all the information and
documents specified on the list;
(b)
where the firm has not published a list under BCOBS 7.4.3R
in relation to that type of account, the number of days taken
to generate a working account number is to be counted from
receipt of an application or request for access.
(6)
For the purposes of (2)(b), (2)(c), (2)(d) and (3), the number of days
taken is to be counted from:
(a)
the day on which the firm gives the attorney access to the
account, where the attorney requested the relevant thing
before the day on which the firm gives the attorney access to
the account; else
(b)
the day on which the attorney requested the relevant thing.
7.4.6
G
The guidance in BCOBS 7.3.6G applies to BCOBS 7.4.5R, with necessary
modifications (for example, replacing references to account opening with
references to the attorney gaining access to the account).
7.5
Availability of certain services and helplines
7.5.1
R
A firm must publish information about the days on which and the times at
which a banking customer may, by each of the methods specified in BCOBS
7.5.3R, carry out each of the actions specified in BCOBS 7.5.4R.
7.5.2
R
(1)
A firm must publish a statement as to whether or not it is possible,
twenty four hours a day and every day of the year, for a banking
customer and, in relation to BCOBS 7.5.5R(i) and (j), a potential
banking customer to discuss with the firm:
FCA 2017/XX
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(a)
each of the actions specified in BCOBS 7.5.4R; and
(b)
each of the matters specified in BCOBS 7.5.5R.
(2)
A firm may publish a statement that it is so possible only if it is
possible to discuss those actions and those matters, by one or more of
the methods specified in BCOBS 7.5.3R, with a member of staff of
the firm who has been trained to discuss the relevant action or matter.
(3)
If it is so possible, the firm must specify in the statement:
(a)
by which of those methods it is possible; and
(b)
if it is possible by telephone, the telephone number.
(4)
If it is not so possible by all of the methods specified in BCOBS
7.5.3R, the firm must publish information about the days on which
and the times at which a banking customer and, in relation to BCOBS
7.5.5R(i) and (j), a potential banking customer may, by each of the
methods specified in BCOBS 7.5.3R, discuss with the firm:
(a)
each of the actions specified in BCOBS 7.5.4R; and
(b)
each of the matters specified in BCOBS 7.5.5R.
(5)
In the information published under (4), the firm may only indicate
days on which and times at which the banking customer or potential
banking customer may discuss the action or matter with a member of
staff of the firm who has been trained to discuss the relevant action or
matter.
(6)
In the statement published under (1) and in the information published
under (4), the firm must use the descriptions in the right hand column
in each of BCOBS 7.5.4R and BCOBS 7.5.5R to refer to the actions
and the matters.
7.5.3
R
The methods are:
(1)
telephone (other than telephone banking);
(2)
telephone banking;
(3)
internet banking; and
(4)
mobile banking.
7.5.4
R
The actions are:
Action
Description
(a)
ascertain the balance on the account
check balance and
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(b)
access a transaction history covering
at least the previous 90 days
transactions
(c)
initiate a payment transaction to a
payee in the United Kingdom
send money within the UK,
including setting up a
standing order
(d)
set up a standing order to a payee in
the United Kingdom
(e)
initiate a payment in a currency
other than a currency of the United
Kingdom to a payee, whether in the
United Kingdom or outside the
United Kingdom
make a payment in a foreign
currency
(f)
make a deposit by cheque
pay in a cheque
(g)
cancel a cheque
cancel a cheque
7.5.5
R
The matters are:
Matter
Description
(a)
use of a debit card to withdraw
money in a currency other than a
currency of the United Kingdom
from a machine or at an
establishment outside the United
Kingdom
discuss withdrawing money
abroad
(b)
overdrawing without a pre-arranged
overdraft or exceeding a pre-
arranged overdraft limit
discuss lack of funds,
including unarranged
overdrafts, payments taken
despite lack of funds,
cancelled payments due to
lack of funds
(c)
a payment made from the account
although the result of the payment is
that the banking customer overdraws
without a pre-arranged overdraft or
exceeds a pre-arranged overdraft
(d)
a payment not made from the
account where the result of the
payment would be that the banking
customer overdraws without a pre-
arranged overdraft or exceeds a pre-
arranged overdraft
(e)
a direct debit within the meaning of
the Payment Services Regulations
discuss direct debit or
continuous payment authority
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(f)
an attorney obtaining access to the
account
discuss third party access to
an account, for example
under a power of attorney
(g)
inability of a banking customer to
access or use:
discuss problems using on-
line banking or mobile app
(i)
internet banking; or
(ii)
mobile banking
(h)
the stopping of a debit card, the
suspension of transactions on the
account, or a transaction which is
suspected to be fraudulent
discuss progress following an
account suspension or card
cancellation, e.g. following a
fraud incident
(i)
opening an account
discuss account opening
including overdraft
eligibility, what is required to
open an account and an
indication of what overdraft
may be available
(j)
eligibility for an overdraft
7.5.6
G
(1)
This section requires firms to publish various types of information:
(a)
information about how and when banking customers can
carry out certain actions on their account;
(b)
a statement about whether or not 24-hour help is available for
banking customers to raise queries about carrying the actions
on their account specified in BCOBS 7.5.4R or about the
matters specified in BCOBS 7.5.5R, and for prospective
banking customers to raise queries about account opening and
overdraft availability; and
(c)
where 24-hour help is not available under one or more of the
methods specified in BCOBS 7.5.3R, information about how
and when banking customers can raise queries about carrying
out certain actions on their account and about various other
matters, and prospective banking customers can raise queries
about account opening and overdraft availability.
(2)
A firm should only indicate that help is available (i.e. an action or
matter may be discussed) where the banking customer or prospective
banking customer is able to discuss the action or matter with a
member of staff who has been appropriately trained to respond to
such queries. This might mean, for example, a customer call centre
responding to telephone queries or live webchat for internet banking,
operated by appropriately trained staff. Automated responses, an
FAQ list which filters out queries, or a messaging or mailbox system
would not be sufficient; the discussion must involve real time
FCA 2017/XX
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interaction.
(3)
A firm should only indicate that 24-hour help is available by one of
the methods specified in BCOBS 7.5.3R if all of the specified actions
and all of the specified matters can be discussed by that method.
(4)
Firms may present the information and the statement in a format of
their choosing, but must describe the actions and the matters using
the terms specified in the right hand column of the tables in BCOBS
7.5.4R and BCOBS 7.5.5R
7.6
Publication of information about major operational or security incidents
Major operational or security incidents
7.6.1
R
(1)
This rule applies to information about the firm’s operational or
security resilience.
(2)
The firm must publish the information in (3) about the major
operational or security incidents in respect of which the firm has
submitted an initial report to the FCA under regulation 99 of the
Payment Services Regulations in a current account measurement
period (see BCOBS 7.7.1R).
(3)
The information is:
(a)
the total number of major operational or security incidents
reported in the relevant current account measurement period
(see BCOBS 7.7.1R);
(b)
the number of major operational or security incidents reported
in that period, for each of:
(i)
telephone banking;
(ii)
mobile banking; and
(iii)
internet banking;
(c)
the total number of major operational or security incidents
reported in that period aggregated with those reported in the
preceding three current account measurement periods; and
(d)
the number of major operational or security incidents reported
in that period aggregated with those reported in the preceding
three current account measurement periods, for each of:
(i)
telephone banking;
(ii)
mobile banking; and
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(iii)
internet banking.
(4)
The firm must use the words specified in Table 4 of BCOBS 7 Annex
1R when publishing that information unless (5) applies.
(5)
Where the firm did not report any incidents to which a category of
information specified in (3) applies, the firm may indicate that it did
not report any incidents in that category.
7.6.2
G
BCOBS 7.6.1R requires firms to publish information about the number of
initial reports about major operational or security incidents that it makes to
the FCA under regulation 99 of the Payment Services Regulations. The
published numbers relate to: the total number of initial reports in the last
current account measurement period, and in the last four current account
measurement periods; and the numbers relating to telephone banking, mobile
banking and internet banking, again in the last current account measurement
period, and in the last four current account measurement periods. Firms are
not required to publish separate numbers for commercial channels affected
by a major operational or security incident other than telephone banking,
mobile banking and internet banking.
7.7
Publication of information about current accounts
How frequently must information be published?
7.7.1
R
(1)
The information published under the rules specified in (2) must be
published in respect of each current account measurement period on
or before the publication date immediately following the end of that
current account measurement period as set out in the table below.
Current account measurement
period
Publication date
the period beginning on 1
January and ending on 31 March
15 May
the period beginning on 1 April
and ending on 30 June
15 August
the period beginning on 1 July
and ending on 30 September
15 November
the period beginning on 1
October and ending on 31
December
15 February
(2)
The rules are:
(a)
BCOBS 7.3.5R(1) (information about the speed of the account
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opening process);
(b)
BCOBS 7.4.1.R(1) (information about the time taken to
replace a lost, stolen or stopped debit card);
(c)
BCOBS 7.4.5.R(1) (information about the speed with which a
firm can give an attorney access to a personal current account
and enable the attorney to take various actions in relation to
the account); and
(d)
BCOBS 7.6.1.R(1) (information about operational and
security resilience).
(3)
The information and statements published under the rules specified
in (4) must be published and kept up-to-date.
(4)
The rules are:
(a)
BCOBS 7.3.1R (information needed to open a current
account);
(b)
BCOBS 7.3.3R (information about how an account may be
opened);
(c)
BCOBS 7.4.3R (information needed to give an attorney
access to an account); and
(d)
BCOBS 7.5.1R and 7.5.2R (information about the availability
of certain services and helplines).
How must information be published?
7.7.2
R
(1)
A firm to which this chapter applies must:
(a)
publish on its website the information and statements which
this chapter requires it to publish;
(b)
ensure that the information and statements are easily
accessible by a banking customer or a potential banking
customer; and
(c)
notify the FCA of the website location where the information
and statements are published, no later than the day of their
publication.
(2)
A firm to which this chapter applies must include alongside the
information and statements it publishes under the rules specified in
BCOBS 7.7.1R(2) a statement to the effect that the FCA requires the
firm to publish the information.
(3)
A firm must make the information and statements published in
accordance with this chapter publicly available free of charge by
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means of an application programming interface, if it is a firm:
(a)
to which this chapter applies;
(b)
which is subject to the provisions of either or both of:
(i)
clause 13 (release of service quality indicators) of the
Retail Banking Market Investigation Order 2017; and
(ii)
regulations 69(2)(a) and 70(2)(a) of the Payment
Services Regulations; and
(c)
which uses an application programming interface for the
purposes of a provision specified in (b).
(4)
A firm to which (3) applies must:
(a)
use the same application programming interface to make
information and statements available for the purposes of (3)
as it uses for the purposes of:
(i)
clause 13 (release of service quality indicators) of the
Retail Banking Market Investigation Order 2017,
expanding that interface as necessary for the purposes
of this rule; or
(ii)
if clause 13 of that Order does not apply to the firm,
regulations 69(2)(a) and 70(2)(a) of the Payment
Services Regulations; and
(b)
ensure that the application programming interface is itself
also publicly available free of charge.
7.7.3
G
(1)
Firms should publish information and statements under this chapter
on their websites. The FCA would view the information and
statements as “easily accessible” if the information and statements, or
a link to the webpage(s) on which the information and statements are
published, is prominently displayed on the firm’s or the brand’s
homepage for personal current accounts or, as the case may be,
business current accounts.
(2)
Firms may notify the FCA of the webpages on which they publish
information under this chapter by sending a link to the webpages to
(3)
The FCA will treat the following statement as satisfying the
requirements of BCOBS 7.7.2R(2): “The Financial Conduct
Authority requires us to publish the following information”.
(4)
A firm which is required to publish information under clause 13 of
the Retail Banking Market Investigation Order 2017 (that is, the
service quality indicators required by the Competition and Markets
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Authority) may wish to publish information under this chapter
alongside information published under that Order. If so, the firm
should ensure that a reader of the relevant webpage would not infer
from the wording or position of the statement required by BCOBS
7.7.2R(2) that the FCA has required the firm to publish the
information which that Order requires the firm to publish.
(5)
Clause 13 of the Retail Banking Market Investigation Order 2017
requires certain firms to use an API to publish the service quality
indicators specified by the Competition and Markets Authority.
Regulations 69 and 70 of the Payment Services Regulations require
payment service providers to “communicate securely” with payment
initiation service providers and account information service providers
in accordance with the regulatory technical standards adopted under
Article 98 of the Payment Services Directive; firms might use an API
for that purpose.
(6)
Where a firm uses an API for the purposes of clause 13 of that Order
or, if clause 13 of that Order does not apply to it, for the purposes of
regulations 69 and 70 of the Payment Services Regulations, BCOBS
7.7.2R requires the firm to make information and statements
published under this chapter also available through that API; both the
API and the information and statements made available through it
should be publicly available and free of charge. Firms that are not
subject to the Order or those provisions of the Payment Services
Regulations are, however, free to choose to make the information or
statements published under this chapter available by API.
7 Annex
1R
Publication of information: specified language
Table 1: account opening information, published under BCOBS 7.3.5R
The speed of our [personal/business] account opening process
How quickly do we open [personal/business] current accounts?
[(for firms that publish a list under BCOBS 7.3.1R) When all we need is the
information and documents we ask for on our account opening list, OR (for firms
that do not publish a list under BCOBS 7.3.1R) When we receive an application,]
we give customers an account number and enable them to start paying into the
account:
the same day, for [x]% of customers;
on average, in [x] days; and
within [x] days for 99% of customers.
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How quickly do we give customers a debit card?
Once an account is open, we give customers a debit card:
the same day, for [x]% of customers;
on average, in [x] days; and
within [x] days for 99% of customers.
How quickly do customers get internet banking?
Once an account is open, customers have internet banking:
the same day, for [x]% of customers;
on average, in [x] days; and
within [x] days for 99% of customers.
How quickly is an overdraft available?
Once an account is open, the overdraft is available:
the same day, for [x]% of customers;
on average, in [x] days; and
within [x] days for 99% of customers.
Table 2: time taken to replace a lost, stolen or stopped debit card published under
BCOBS 7.4.1R
The speed with which we can replace a debit card
How quickly do we replace debit cards which have been lost, stolen or
stopped?
We replace debit cards:
the same day, for [x]% of customers;
on average, in [x] days; and
within [x] days for 99% of customers.
Table 3: information about giving an attorney access to a personal current account,
published under BCOBS 7.4.5R
The speed with which we can give another person access to a personal
current account under a power of attorney
How quickly can we give another person access to a personal current account
under a power of attorney?
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[(for firms that publish a list under BCOBS 7.4.3R) When all we need is the list of
information and documents we have published, OR (for firms that do not publish
a list under BCOBS 7.4.3R) When we receive a request for access,] we enable
another person acting under a power of attorney to check the balance on the
account and get information about transactions on the account:
the same day, for [x]% of attorneys;
on average, in [x] days; and
within [x] days for 99% of attorneys.
How quickly can we give an attorney a debit card?
Once the attorney has access to the account, we give them a debit card:
the same day, for [x]% of attorneys;
on average, in [x] days; and
within [x] days for 99% of attorneys.
How quickly can an attorney get internet banking?
Once the attorney has access to the account, they have internet banking:
the same day, for [x]% of attorneys;
on average, in [x] days; and
within [x] days for 99% of attorneys.
How quickly will an attorney be able to withdraw money and make payments
out of the account?
Once the attorney has access to the account, they are able to withdraw money and
make payments out of the account:
the same day, for [x]% of attorneys;
on average, in [x] days; and
within [x] days for 99% of attorneys.
Table 4: information about major operational or security incidents, published
under BCOBS 7.6.1R
Information about the operational and security resilience of our services
We are obliged to report major operational or security incidents to the Financial
Conduct Authority.
Overall:
we reported [x] incidents between [e.g. 1 January 2019 and 30 March
2019], and [x] between [e.g. 1 April 2018 and 30 March 2019].
For telephone banking:
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we reported [x] incidents between [e.g. 1 January 2019 and 30 March
2019], and [x] between [e.g. 1 April 2018 and 30 March 2019].
For mobile banking:
we reported [x] incidents between [e.g. 1 January 2019 and 30 March
2019], and [x] between [e.g. 1 April 2018 and 30 March 2019].
For internet banking:
we reported [x] incidents between [e.g. 1 January 2019 and 30 March
2019], and [x] between [e.g. 1 April 2018 and 30 March 2019].
TP 1
Transitional provisions for information about current account services
(1)
(2)
(3)
(4)
(5)
(6)
Material to
which the
transitional
provision
applies
Transitional provision
Transitional
provision:
dates in
force
Handbook
provision
coming into
force
1.1
BCOBS
7.1.2R
R
For the purposes of
BCOBS 7.1.2R(1)(a)(ii)
and BCOBS
7.1.2R(1)(b)(ii), references
to preceding current
account measurement
periods should be read as
including periods which
predate 1 April 2018.
From 1 April
2018 to 30
September
2018
1 April 2018
1.2
BCOBS
7.1.2R
G
Firms will not be subject
to BCOBS 7 in respect of
the current account
measurement period 1
April 2018 to 30 June
2018 if they have not
continuously had 70,000
or more personal current
accounts, or 15,000 or
more business current
accounts, since 1 October
2017. And firms will not
be subject to BCOBS 7 in
respect of the current
account measurement
period 1 July 2018 to 30
From 1 April
2018 to 1
October 2018
1 April 2018
FCA 2017/XX
Page 28 of 29
September 2018 if they
have not continuously had
70,000 or more personal
current accounts, or
15,000 or more business
current accounts, since 1
January 2018.
1.3
BCOBS
7.3.1R,
7.3.3R,
7.4.3R,
7.5.1R and
7.5.2R.
R
Firms are not obliged to
publish a statement or
information.
From 1 April
2018 to 14
August 2018
1 April 2018
1.4
BCOBS
7.3.1R,
7.3.3R,
7.4.3R,
7.5.1R and
7.5.2R.
G
The rules to which TP 1.3
applies require firms to
publish various statements
and information. TP 1.3
permits firms not to
publish those statements or
that information until 15
August 2018.
From 1 April
2018 to 14
August 2018
1 April 2018
1.5
BCOBS
7.3.5R,
7.4.1R,
7.4.5R and
7.6.1R
R
Firms are not obliged to
publish information that
relates to a current account
measurement period
ending before 1 April
2018.
From 1 April
2018 to 14
August 2018
1 April 2018
1.6
BCOBS
7.3.5R,
7.4.1R,
7.4.5R and
7.6.1R
G
The rules to which TP 1.5
applies require firms to
publish various
information. TP 1.5
permits firms not to
publish information that
relates to a current account
measurement period
ending before 1 April
2018. Firms must,
however, collect
information relating to the
current account
measurement period
beginning on 1 April 2018
and publish it no later than
15 August 2018.
1.7
BCOBS
R
Firms may disregard
From 1 April
1 April 2018
FCA 2017/XX
Page 29 of 29
7.6.1
current account
measurement periods
ending before 1 April 2018
2018 to 30
June 2019
1.8
BCOBS
7.6.1
G
BCOBS 7.6.1R(3)(c) and
(d) require firms to publish
information about the total
number of incident reports
in a current account
measurement period
aggregated with those
reported in the previous
three periods (i.e. a twelve
month total). TP 1.7 means
that firms do not have to
aggregate for periods
which end before 1 April
2018.
From 1 April
2018 to 30
June 2019
1 April 2018
Sch 1
Notifications and reporting requirements (if any)
1.1G
Handbook
reference
Matter to be
notified
Contents of
notification
Trigger event
Time
allowed
BCOBS
7.7.2R(1)(c)
The website
location(s)
where
information
and statements
published
under BCOBS
7 are available
The website
location(s)
where
information
and statements
published
under BCOBS
7 are available
The
publication
of
information
and
statements
under
BCOBS 7
No later than
the date of
publication
© Financial Conduct Authority 2017
25 The North Colonnade Canary Wharf London E14 5HS
Telephone: +44 (0)20 7066 1000
Website: www.fca.org.uk
All rights reserved
Pub ref: 005493
