On 15 July 2020, shortly after the first anniversary of its assumption of governorship of the Contingent Reimbursement Model (“CRM”) Code, the Lending Standards Board (LSB) launched a consultation which will form the basis of its post-implementation review of the CRM Code. The LSB’s review also extends to its Practitioners Guide (which is made available only to signatories of the CRM Code) and its Information for Customers document.

The LSB’s consultation follows its review of the approach to reimbursement of customers between October 2019 and January 2020. The consultation also comes the day after the Investment Association warned of an increase in fraud targeting retail investors in the wake of the COVID-19 lockdown.

The consultation sets out questions across four different areas:

  • implementation of the CRM Code;
  • the experience of APP scam victims since the CRM Code’s launch (and whether the CRM Code has met its consumer protection objective);
  • whether measures to prevent APP scams (such as consumer education and awareness, and Confirmation of Payee) are supporting the objectives of the CRM Code; and
  • the challenges faced by firms when reimbursing customers under the CRM Code, including in ‘no blame scenarios’.

The LSB has invited responses to the consultation by 5pm on 30 September 2020.


Clive Cunningham
Clive Cunningham
Partner, London
+44 20 7466 2278
Mark Staley
Mark Staley
Senior Associate, London
+44 20 7466 7621
Harry Millerchip
Harry Millerchip
Associate, London
+44 20 7466 6447