The Contingent Reimbursement Model – Obligations Under The Code

My previous article looked at the development of the Contingent Reimbursement Model (CRM) code, its purpose in dealing with Authorised Push Payment Fraud (APP) and the principles underpinning the scheme.

In this second piece I want to explore the standards it sets for those payment service providers (PSPs) who have committed to the code and how those standards may affect the landscape for all PSPs when they respond to APP fraud.

The CRM code breaks down participants' obligations into two parts – general expectations and the standards for firms.

General expectations

The general expectations provide a baseline of expected behaviours on the part of the participant PSPs. For instance, the code emphasises the importance of education and awareness as a responsible activity for PSPs to undertake. Further, it requires that the PSPs will collect statistics and measure impacts on the incidents of APP fraud.