Changes to current account information requirements: to be implemented next week

The FCA has published further changes to new current account information requirements which were originally finalised last December. Discussions with the industry had revealed that some of the final rules were not necessarily applicable to standard business models and might not have achieved the FCA's aims. While the changes are a welcome response to industry concerns, providers are left with little time to react: they must publish their first data set under the new rules on 15 August 2018.

What are the new requirements?

Following a consultation in 2017, the FCA decided to introduce amendments to the Banking Conduct of Business Sourcebook ("BCOBS") to require certain current account providers to publish a range of specified information on their website, including:

  • information about account opening, the channels which customers can use to access different services and whether there is 24/7 capability for customers to give certain instructions; 
  • metrics about how quickly a customer can access a bank account and get a debit card, internet banking or an overdraft; and 
  • information about the number of major operational or security incidents reported under the Payment Services Regulations 2017 ("PSRs").

The data must be published at brand level in a standardised format and, for those within the scope of the CMA's Open Banking remedy or TPP access requirements under the PSRs, must also be available through an API. Standing data must be kept up to date on an ongoing basis with certain specific metrics subject to a quarterly refresh. The date for first publication is 15 August 2018, subject to exceptions for account opening and debit card replacement metrics which are not required until 15 February 2019.

The FCA hopes that the new rules will increase competition by enabling customers to compare performance and incentivising providers to make sure that their service levels are up to scratch.

What are the latest changes?

The changes that have recently been published will apply from the date of first publication and are designed to respond to some practical issues raised by impacted firms.

Account opening information: Allowing for data on existing customers

One of the new requirements is to publish information about how quickly working account numbers can be generated for new applicants. Originally, the FCA had taken the view that this should be calculated based only on new applicants who were not already customers of the firm. This has now been amended so that firms who do not distinguish between new and existing customers at the point of account opening can include data relating to existing customers in their figures.  

Standard practices on contact channels and telephone banking

The changes also deal with a number of other standard industry practices such as providing different contact channel availability to different types of customer and requiring customers to provide security details before giving instructions by phone (meaning that a distinction between "by telephone" and "by telephone banking" was not necessary).

Clarity on APIs

Finally, for those providers within the scope of the CMA's Open Banking remedy, the rules originally required this information to be available using the same API that would be used for those purposes (expanding it as necessary). However, following discussions with the Open Banking Implementation Unit, the FCA has decided that this is not strictly necessary. It has instead clarified that firms can either publish the information using the relevant Open Banking standard specification or a substantially similar API.

Building on existing requirements or "indicator overkill"?

These requirements are another challenge for providers in a market that is already undergoing significant change, including as a result of the CMA's Retail Banking Market Investigation Order (the "CMA Order"). The FCA has been clear that the new rules are "designed to build on and complement" the service quality indicator requirements that the CMA Order has already put in place and the dates for first publication have been deliberately aligned. However, there was concern in consultation that full alignment may not have been achieved. For example, the relevant de minimis thresholds mean that much smaller brands can be caught by the new BCOBS rules. Business current accounts will also only be in scope for BCOBS purposes to the extent that they are offered to micro-enterprises and charities. The timing requirements also differ: the CMA Order requires bi-annual (rather than quarterly) publication.

While the measures should certainly put providers under the kind of competitive pressure that the FCA envisaged, questions remain about the tension that this might create with other requirements such as customer due diligence and incident reporting. It also remains to be seen whether the new rules will help to make customers savvier about switching or whether this is a case, as some consultation respondents warned, of "indicator overkill."

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