Review of the CRM Code

The LSB have launched the formal review of the CRM Code with the publication of a consultation document today, Wednesday 15 July 2020.

The Contingent Reimbursement Model Code (CRM Code) launched on 28 May 2019 and has now been in place for over a year. Having assumed governorship of the CRM Code on 1 July 2019, the LSB are carrying out a full review of the effectiveness of the Code and its impact on consumers and the industry, one-year post-implementation.

The consultation sets out questions across four different areas:

  • Implementation – with questions seeking to establish any challenges firms have faced in adopting the Code, any barriers that exist to new firms signing up, and areas where the Code could be improved to take account of insight gained over the first year of implementation.
  • Customer experience – with questions seeking to establish whether the Code has met its objective to increase the proportion of customers protected from the impact of APP scams, both via reducing incidents of scams and by reimbursement, and to determine what the experience of victims of APP scams has been in the year since the Code was launched.
  • Prevention measures – with questions seeking to establish whether consumer education and awareness campaigns, warnings, and Confirmation of Payee are working effectively to support to objectives of the Code.
  • Resolving claims – with questions seeking to establish what challenges firms face when making a decision to reimburse a customer, included in relation to how that reimbursement is funded.

The consultation will run until Wednesday 30 September 2020.

Further details of the consultation can be found here.

You can also get in touch with a member of our team via email at


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