Review of the CRM Code

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 LSB launched the formal review of the CRM Code with the publication of a consultation document on Wednesday 15 July 2020.

The consultation set 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 the 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 in the case of ‘no blame’ scenarios.

In addition to the Code itself, the review covers two sets of supporting documents; the Practitioners Guide, which is made available to signatories to the Code, and the Information for Customers document.

The consultation will run until 5pm on Wednesday 30 September 2020. 

You can access the consultation document here: CRM Code Consultation document

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

Read the report of the CRM Code review here.

Click here for supporting reports fed into the review.

As part of our review of the CRM Code, we have published a roadmap outlining the upcoming activity we will be undertaking in 2021. Access a copy of the roadmap here.

Access our further Call for Input here: Call For Input – CRM Code. This will run until 26 May 2021.

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