PSR consultation on APP fraud: Excess and maximum reimbursement level for Faster Payments and CHAPS - Which? response

Summary of Which? views:

• The proposals set out in this consultation for a claims excess and maximum reimbursement level represent a significant backward step in the protections for consumers who fall victim to APP fraud compared to the PSR’s previous proposals.
• They also represent a dilution of the protections currently given to consumers under the voluntary Contingent Reimbursement Model (CRM) Code.
• The PSR’s post-implementation review must look not only at data reported by firms but also scrutinise banks’ assessment of reimbursement claims and their identification, and treatment, of vulnerable customers.
• We do not support the imposition of a claim excess, which is not justified by the evidence. We are particularly concerned that an excess will have a negative impact on different groups of consumers, including those on lower incomes. We recommend that this proposal is abandoned.
• We do not support the imposition of a maximum reimbursement level for Faster Payments. Similarly, a maximum reimbursement level should not apply to CHAPS, which is used for high value transactions such as house purchases.