Frequently Asked Questions

BCR has built up a database of FAQ that we hope you find useful. We have split them into relevant sections for ease of reference. 

CIF - Application Form

Relevant to All

A: It is not simply a subset. 2.5.3 is very specific on information around your implementation costs whereas 2.4.2 (ii) requires applicants to give information on financial analysis in the context of the entire bid. 

A: As part of the application process, initially BCR is seeking confirmation from applicants that they will use the funds for permitted purpose. Thereafter, as part of the reporting responsibilities which can be found in Section 4 of the Capability and Innovation Fund Agreement here, we will look for evidence as to how the funds have been spent within the assessment period and we will also look for specific confirmation that the fund have been used for Permitted purposes only.

We have a comprehensive reporting process in place through previous pools and we will share this in due course with successful applicants.

A: You may, in the market research citations in the foot note add your references – if not you should include your references in the body text of the main application where they will be included within the word count. 

A: Applicants have been given the ability to define what this looks like but our recommendation is to make information supplied as concise as you deem appropriate.

A: Yes – as per the Fund Assessment Criteria here, this question is specific to the extent to which the Applicant Company commits to purchasing innovative financial services or software from the SMEs in the United Kingdom as part of this initiative. 

A: 1) In question 2.3.1, Applicant Companies should include all the ‘underpinning assumptions’ which the Applicant Company has considered when putting together their initiative. This includes but is not limited to market, cost and customer switching assumptions.

2) In question 2.3.2, Applicant Companies should include all the ‘underpinning assumptions’ which the Applicant Company has considered when putting together their initiative. This includes but is not limited to the build of the product and wider market assumptions.

3) Yes, in question 2.3.3, the Independent Body is seeking for both a quantitative and qualitative analysis but primarily the former.

A: Applicant Companies are free to choose which information is relevant to answer this question. As a minimum, the Independent Body expects to see what percentage of your SME customer base is using any relevant product.

A: In question 2.6.2, KPIs Applicant Companies are requested to provide include:

(i) the success criteria detailed in Questions 2.3.1 – 2.3.3

(ii) additional KPIs that the Applicant Company would be measured against. Please ensure these are objective and quantifiable

(iii) for each KPI include the target and the annual breakdown.

The KPI template can be found here.

A: In your business case submission, you have the opportunity to create milestones for various aspects of your application. BCR would expect to see a realistic milestone plan for implementation of initiatives, with key milestones highlighted, with a focus on customer impact and market impact.

A: Section 2.1.2 is an opportunity for applicant companies to attach a summary overview of the business case in formats specified. It is for applicants to decide if this is relevant to their individual applications.

A: BCR gives no preference to any type of market analysis. All applications will be reviewed and assessed based on their own merits. 

A: The example should demonstrate to the Evaluation Team that the Applicant Company has delivered a significant change project which is comparable in complexity and scale of their business case submission to the delivery of the Capability and Innovation Fund.

A: As per question 2.6.1, Applicant Companies should define the governance and controls they themselves would put in place. In addition this should include how the applicant would enable monitoring by the Independent Body.

A: It is at the discretion of the Applicant Company as to whether they complete the application in the Excel file or directly within Scout. The Independent Body strongly recommends Applicant Companies to read the Scout RFP user guide to walk through the key functionality of Scout and familiarise themselves with the layout and functionality.

A: 1) No, when typing your response directly into the Scout tool, text formatting such as bold, italicised and underline is not maintained, however, where requested within the Application Documents, Applicant Companies can format text within their attachments.

2) No, when typing your response into the Scout tool, tables cannot be inserted, however, where requested within the Application Documents, Applicant Companies can insert tables within their attachments.

The Independent Body strongly recommends Applicant Companies to read the Scout RFP user guide, which will be available on the BCR website in due course, to walk through the key functionality of Scout and familiarise themselves with the layout and functionality. 

A: As outlined in all documentation shared and various communications, D bodies are not eligible to apply for Pool F awards. The documentation is generic documentation. It is up to the applicant to decide and confirm if they meet the eligibility criteria. To be considered a Pool C Body, an applicant must meet the following criteria:

 

(iii) an entity (not being a Pool A Body or a Pool B Body): which (a) is domiciled in the United Kingdom, the European Union, the European Economic Area or Switzerland; (b) derives (or, if such entity is part of a group, such group derives) the majority of its revenue from the provision of financial services to individuals and businesses; and (c) offers, or has expressed an intention to expand its business offering to include, lending or payment services to SMEs in the United Kingdom or international payments services to SMEs in the United Kingdom (“Pool C Body”).

A: It is up to the applicant to define the period in which the CIF funds are spent. Given the CIF Agreement terminates in December 2022, there is particular interest in the applicant’s ability to spend the CIF grant and deliver some benefits within this timeframe. This does not prevent you from submitting a business case which includes spend and benefits further out and it should be anticipated that there will be monitoring of awards beyond the Agreement timeline.

A: Being a listed company does not preclude you from applying for this funding provided you meet all the eligible criteria as per clause 2.1 of the Terms and Conditions.

A: It is up to the applicant to define the period in which the CIF funds are spent. Given the CIF Agreement terminates in December 2022, there is particular interest in the applicant’s ability to spend the CIF grant and deliver some benefits within this timeframe. This does not prevent you from submitting a business case which includes spend and benefits further out and it should be anticipated that there will be monitoring of awards beyond the Agreement timeline.

A: Aligned to communications, it is up to the applicant to define the period of spend and realisation of benefits being delivered from the initiatives proposed. The CIF Agreement terminates in December 2022 with particular interest in spend and delivery of some benefits within this timeline.

As previously mentioned, this does not prevent you from submitting a business case which includes spend and benefits further out and it should be anticipated that there will be monitoring of awards beyond the Agreement timeline.

A: Pool F Application Period is for Pool A, B and C Bodies only. D Bodies are not eligible for the awards as confirmed in the latest press release on the 31st August 2021 which can be found here.

A: Applicant Companies are permitted to submit one application per application period, however, within an application an Applicant Company is able to apply for two grants, as outlined in section 2 of the application form). Please outline in the application form that you are applying for two grants. Within the business case section, there are questions where Applicant Companies applying for two grants are permitted to submit a longer response, or provide additional attachments. This is clearly signposted in the question text, for example in 2.4.2 where it clearly states “One attachment per grant (Excel, PPT, PDF or Word)”.

Each application is reviewed independently, therefore if you are requesting two grants, you would be required to upload two supporting documents, one per grant, as stated within the application form (in section 2). This is to ensure fairness across all applicants regardless of whether they apply for one or two grants.

A: It is up to the applicant to define how the KPIs are defined and measured.

The KPI template within the Governance section of the application has been provided to capture KPIs that the applicant deems appropriate in supporting the monitoring and reporting of progress against their objectives. BCR would expect to see a selection of KPIs that demonstrate progress against the business case – this can be at both company level (e.g. NPS) or individual initiative level (e.g. # customers using a product or service). We will also expect to see a breakdown of CIF and co-investment deployed during 2022. We recognise that some of the benefits and indeed spend might run into years beyond 2022 and we have indicated that awardees should expect monitoring of these deliverables where this is the case.

You would be considered to be eligible as a “Pool C Body”, providing you feel that you meet the following criteria, as outlined in 2.1 of the Terms and Conditions:

 (iii) an entity (not being a Pool A Body or a Pool B Body): which (a) is domiciled in the United Kingdom, the European Union, the European Economic Area or Switzerland; (b) derives (or, if such entity is part of a group, such group derives) the majority of its revenue from the provision of financial services to individuals and businesses; and (c) offers, or has expressed an intention to expand its business offering to include, lending or payment services to SMEs in the United Kingdom or international payments services to SMEs in the United Kingdom (“Pool C Body”);”.

Relevant to C Bodies

A: Independently of their future offering or their current customer base, the Applicant Company should provide a detailed breakdown of their current range of products and services and their current market share (including both customer numbers and product usage). In this scenario, a breakdown between individuals and businesses would be expected.

CIF - Eligibility and Assessment Criteria

Relevant to All

A: Assessment Criteria are outlined on our website here.

It is important for each applicant to address all of the assessment criteria in your response but please note that the Board is particularly interested in an applicant’s ability to deliver within the timelines given (end of 2022) along with either:

In the case of A and B Bodies, the likely impact on competition in the SME banking market, increase in addressable market and proposed development of products and services; or

In the case of C Bodies the likely impact on competition in the SME lending or payment markets and the extent to which the proposal is innovative and different from its existing offerings (or those of other providers), in terms of product design, service level and/or means of delivery or distribution.

A: No, there is no restriction in the type of Applicant Company who can apply as long as you meet the eligibility criteria which can be found here. An Applicant Company who lends but is a non-bank can apply.

A: This eligibility criteria requires revenue to be derived from the provision of financial services to individuals and businesses. So this criteria is cumulative, which is supported by the next criteria, which requires the applicant to offer, or have expressed an intention to expand its business offering to include, lending or payments services to SMEs in the UK or international payments services to SMEs in the UK. The use of “expand” makes it clear that there must be an existing offering to businesses, and so an applicant that does not derive any revenue from services to businesses or have a business offering would not be able to satisfy this eligibility criteria. 

A: The eligibility criteria and timelines for the Capability and Innovation Fund can be found here. Only applications that meet the eligibility criteria on the closing date of the application period can be considered for a grant.

A: All applications will be considered on their own merits. It is for applicants to form their own conclusion, as part of their wider business case submission, as to what level of commitment they are comfortable making around purchase of innovative financial services or software from SMEs in the UK. All the assessment criteria that BCR will evaluate is found here.

A: The purpose of Pools A, B and C of the Capability and Innovation Funding is for eligible bodies to (i) improve customer outcomes for SMEs in the UK and/or (ii) expand eligible bodies’ business capacity, product offering and/or target markets in order to improve their offering to SMEs in the UK. This is the main focus of the Capability and Innovation Fund, although BCR may also take into account, in respect of Pools A and B, the likely impact on competition in the mid-corporate banking markets in the UK, which is not a defined term and so has its ordinary meaning.

The definition of an SME is a small or medium-sized enterprise, being a business (including incorporated legal entities, sole traders, partnerships, not-for-profit organisations and clubs, charities and societies) that, in respect of any given financial year applying to it, has annual revenues (exclusive of VAT and other turnover-related Taxes) not exceeding £25million. This definition is carried through to all of the Pools.

A: You will find the permitted use of funds in Clause 3 of the Terms and Conditions here. BCR will review and assess all business cases on their own merits. We believe the application form gives any entity the ability to demonstrate its projected financial performance over time. The application form is available on our website here.

A: The eligibility and assessment criteria were agreed by Her Majesty’s Treasury and The European Union as part of the Alternate Remedies Package. The assessment criteria does not require specific detail around the SME leadership team in place – should an applicant feel it is relevant to their submission and wish to provide leadership context in answering various questions within the application form, they are free to do so.

A: No but that isn’t to say we aren’t looking for benefits both direct and indirect. We will have a diversity of applications so applicants should stress in their application how they will deliver benefits and also how they will measure them. 

A: It is likely to be important for Pool F projects to be completed by the end of December 2022. 

A: Section 3 of the Capability and Innovation Fund Terms and Conditions which can be found here extensively addresses the Use of Funds for any applicant. You should review these ahead of making any submission. 

A: It is for the applicant company to make their own assessment of the relevant importance of fintech partners in delivery of their submission and they should complete the relevant sections in question accordingly.

A: Section 3 of the Capability and Innovation Fund Terms and Conditions which can be found here, extensively addresses the Use of Funds for any applicant. You should review these ahead of making any submission to the fund.

A: Section 3 of the Capability and Innovation Fund Terms and Conditions which can be found here, extensively addresses the Use of Funds for any applicant. You should review these ahead of making any submission to the fund.

A: BCR will consider each business case on its merits and does not intend to supplement the CIF Terms and Conditions with other restrictions on the use of funds, for example, by preventing applicants from using funds to acquire another business. However, BCR expects it to be difficult for an applicant to demonstrate that acquiring another business is (i) consistent with the Overarching Principles and the purpose of the Alternative Remedies Package, (ii) sufficiently certain that the applicant can deliver the transaction, yet (iii) is not capital expenditure that would be made by the applicant in any event or has been included in the applicant’s business plan prior to the application. 

A: Use of funds as a capital reserve required by a regulator is not considered an appropriate use of funds. Section 3 of the Capability and Innovation Fund Terms and Conditions which can be found here extensively addresses the Use of Funds for any applicant. You should review these ahead of making any submission. 

A: Each application will be evaluated on its own merits. The Independent Body is expecting that in all cases, there will be one eligible entity as the applicant and that entity will need to satisfy all of the eligibility criteria. It may be that, in order to deliver on the relevant business case, another entity is critical to the application, and therefore the Independent Body would want to understand the relationship that the applicant has with that entity.

However, the applicant will need to ensure that the CIF funds are used for Permitted Purposes only (and not Prohibited Purposes) (each as defined in the CIF Agreement), and so will need to take this into account when defining its relationship with the other entity.

Relevant to B Bodies

A: As long as you meet the eligibility criteria (ii) – i.e.: “the Applicant Company must be a deposit-taking entity which is authorised by the PRA to take deposits” – ahead of submitting your application for Pool F and can evidence that you do meet the criteria, BCR will consider your organisation to be eligible.

A: Lending may be considered as an ancillary product for Pool B applicants where it is ancillary to the business current account offering, noting that this excludes an account in which credit funds are held and offset against mortgage debt or a loan (other than an overdraft facility).

Relevant to C Bodies

A: Any potential applicant will need to look at the eligibility criteria and decide for themselves what service they are offering to SMEs. Each application will be judged on its merits.

A: These terms are not defined and so should be given their ordinary meaning. Should Applicants be concerned as to how these terms apply to their applications, it is open to them to explain the definition that they have used and why they believe that it is appropriate.

A: BCR’s interpretation of this phrase is that it should be read in the context of “Relevant Business(es)”, and therefore the relevant markets are those used in that definition, i.e. SME lending and/or SME payments markets in the United Kingdom.

A: The Capability and Innovation Fund Agreement includes reporting requirements in respect of “SME business volumes, including, but not limited to, customer numbers, [Business Current Account numbers] and lending and deposit balances” as per Clause 4.1 D.
Applicants should be able to demonstrate new gross lending to SMEs resulting from the funds awarded. They should also be able to provide information on their lending stock and net lending as relevant to the investment of any funds awarded and its impact on their SME lending over time.

A: A Pool C Body is defined as those entities who meet the requirements, which include that the applicant, if it is not a Pool A or Pool B eligible body, is an entity:

(a) which is domiciled in the United Kingdom, the European Union, the European Economic Area or Switzerland;
(b) which derives (or, if such body is part of a group, such group derives) the majority of its revenue from the provision of financial services to individuals and businesses; and
(c) which offers, or has expressed an intention to expand its business offering to include, lending or payments services to SMEs in the United Kingdom or international payments services to SMEs in the United Kingdom;

The purpose of a Pool C Body is to facilitate the development of new and existing SME lending and/or SME payments businesses and/or to facilitate the deployment of new technology to relevant markets. Lending or payments applications will be considered on their individual merits for any eligible bodies. Reporting requirements will be appropriate to any successful applicant’s business.

A:The criteria for a Pool C Body clearly states that there must be some revenue to demonstrate revenue comes from the provision of financial services to individuals and businesses. Note the business does not have to generate a profit.

An applicant that does not have any revenue but that is part of a group can still satisfy this criteria if the group derives the majority of its revenue from the provision of financial services to individuals and businesses. So, in your example, if the applicant has not produced revenue as at the date of its application, it would not satisfy this eligibility criteria unless it could demonstrate that it is part of a group and that group derives the majority of its revenue from the provision of financial services to individuals and businesses. The future intentions of the applicant or the group are not relevant in assessing this criteria.

CIF - Evaluation (Decision Making Process)

Relevant to All

A: All applications will be reviewed based on their own merits. Baringa, an organisation with expertise in procurement and tender management across multiple sectors, and which have assisted Banking Competition Remedies in the previous Pools’ evaluation process will be working again on the Pool F fund process. The assessment criteria be found here. How BCR makes decisions can also be found here.

A: If an applicant is a supplier on another applicant’s bid, it can apply for a grant provided it meets the eligibility criteria.

A: The purpose of the Capability and Innovation Funding is for eligible bodies to (i) develop the capability to compete with RBS now NatWest in the provision of banking services to SMEs and/or (ii) develop and improve the financial products and services which are available to SMEs.

Each Pool Body has various eligibility and assessment criteria and, within this, all applications from eligible applicants will be assessed on their own merits. Information around eligibility criteria can be found here and assessment criteria here

A: During the application window, the Independent Body is entitled to request additional information and clarification of information, request one further iteration of the Business Case submitted by an Applicant Company, request meetings and access to personnel, and make all enquiries it considers necessary or desirable in relation to the application and the Independent Body’s assessment of the application. For clarity and practicality given the volumes of applications expected, the Independent Body is looking for business cases to be as comprehensive as possible to enable evaluation to proceed without further contact. Where this is required, the first approach will be contact via the Scout tool. Meetings and further follow up is envisaged as part of the shortlisting process.

A: As part of the evaluation process, BCR would need to be satisfied that the matched funding stipulated in the business case would be made available by the Applicant. If the funds were not readily available, the Applicant Company would need to evidence their strategy to raise the funds. It will be at the discretion of BCR as to whether this would be deemed acceptable. 

CIF - Monitoring

Relevant to All

A: As has been adopted with previous pools once the Capability and Innovation Fund Agreements have been signed by successful applicants, their Public Commitments will be published on the BCR website on a quarterly basis. BCR is also required to publish a public report on the progress made in achieving the Alternative Remedies Package objectives and the use of funds annually. More information on how BCR monitors BCR awardees can be found here.  

A: Successful applicants to the Capability and Innovation Fund will be required to submit reporting on a quarterly basis. The intended start date is within ten business days of the end of each three-calendar month period, beginning three calendar months immediately following the signature of the Fund Agreement. Depending on when the CIF Agreements are signed for Pool F, we will look to align reporting dates to the quarterly reporting cycles already in place for either Pools A-D or Pool E. Reporting will end in line with the termination of the Fund Agreement but you should note that there is likely to be a market expectation for the company to produce some level of reporting  against Public Commitments beyond the Agreement termination date and lifespan of Banking Competition Remedies Limited.

A: BCR already has a successful template in place for existing awardees which it will be re-using with new awardees. Quarterly MI for successful applications will be based on the core information required in the application form (such as the Implementation Plan, Financial Analysis, KPI Dashboard and any additional KPIs an applicant provides as part of the business case), which is outlined clearly within section 4 Reporting Obligations of the Capability and Innovation Fund Agreement.

Incentivised Switching Scheme

A: BCR can confirm there will be no per institution basis reporting publicly. However, information received by BCR may be disclosed by BCR (i) where required by applicable law or regulation, or (ii) to its directors, officers, agents, employees, advisers, contractors, RBS, the monitor, HMT and RBS’s, the monitor’s and HMT’s directors, officers, agents, employees, advisers and contractors, although in the case of (ii) BCR will use its reasonable endeavours to ensure that the recipient owes a duty of confidentiality in respect of that information.

A: BCR have the right to clawback any dowry already paid out if it believes there has been a ‘Material Breach’ as defined in the Incentivised Switching Agreement.

A: RBS have set-up a dedicated Customer Support Team (CST) (Opening hours: Monday to Friday 8am – 6pm, excluding bank holidays) who will answer calls for our Business Banking customers – RBS: 0800 151 2980 / 0345 050 2978 / 0161 933 8108 (Live on April 2018) and Natwest : 0800 151 2991 / 0345 050 2989 / 0161 933 8119.

A: ‘Rejection’ means any Target Customer who has either signed an application form or submitted an online application to open a Business Current Account and have been notified that their application has been rejected by the Applicant Company.

As per clause 3.18 (B) of the Incentivised Switching Agreement:

…the Company shall, at its own cost, provide to the IB in writing:

if applicable, a list (amalgamated by reason(s) for rejection and by Turnover Band) of Target Customers who have been rejected from becoming customers of the Company during the relevant calendar month and an explanation (in reasonable detail) of the reason(s) for such rejection(s).

A: Yes, and RBS will also waive break costs as long as Customers switch their Primary Business Current Account under the Incentivised Switching Scheme. RBS has produced the Customer Reimbursement Policy which reflects and implements the ‘Fees Waiver Schedule’ referenced in the Incentivised Switching Agreement. Incentivised Switching Eligible Bodies can obtain the Customer Reimbursement Policy direct from RBS (upon signing their Non Disclosure Agreement) by contacting Jon Simpson or Nick Perkins.

A: Yes, BCR can clawback in full (or in part) the dowries paid to successful Applicant Companies as stated in Clause 6.7 (B). In exercising its discretion, BCR will take into account all the circumstances and it is only likely to clawback dowries that have already been paid in exceptional circumstances.

A: Clause 13 refers to payments between BCR and participating banks. Applicant companies should take the responsibility of determining the tax treatments on any transactions between the Company and Switching Customers in line with its usual course of business.

A: Applicant companies should take the responsibility of determining the tax treatments on any transactions between the Company and Switching Customers in line with its usual course of business.

A: The IS Agreement sets out all termination rights. There is no express right for an applicant to terminate for business exigency.

A: The unique customer reference identifier will be the main identifier of a customer. The dowry will be paid when the customer becomes a Transferring Target Customer i.e. a Target Customer that closes its Primary Account(s) with RBS and has opened a BCA with an Applicant Company, i.e. they have successfully switched their account.

A: The ISS Terms & Conditions state that ‘…The Applicant Company may only use the Dowries it receives in connection with Incentivised Switching in accordance with its Switching Proposal’. 

Therefore if any Dowries paid to Eligible Bodies have not been used in the manner outlined in the Switching Proposal these will need to be reported to BCR in the normal cycle of reporting and Eligible Bodies will be required to repay those Dowries to BCR. These may include:

– Dowry to be paid out as cash.
– Dowry for direct incentives other than cash.
– Dowry retained for indirect incentives.

Updated guidance on reporting will follow nearer the time here.

A: a. Details on this report can be found under the ‘BCR Target Customer Report’, ‘Requirements’ on the reporting guidance page found here. It is envisaged this will be a high-level report without details of individual Eligible Bodies or SME customers.

b. RBS will provide BCR with this information.

A: Eligible Bodies should use the process set out in clause 6 to make a change to their Switching Proposal and/or Company Offering. This should be used regardless of whether the update is in relation to an amendment which BCR has made under clause 3.9 or whether it has been instigated by the Eligible Body independently of an amendment under clause 3.9. In all instances BCR will retain discretion as to whether to accept the updated Switching Proposal and/or Company Offering. However, in practice, updates which are evidently required to bring the offer in line with changes under clause 3.9 are not likely to be rejected.

BCR will communicate more details on the process in due course.

A: Eligible Bodies are expected to fulfil the incentivised switching offers which are current at the point that customer select them on the microsite. It is not envisaged that the dowry amount will change. In the unlikely event that this does occur, then BCR will provide Eligible Bodies with guidance on how this will take place so as to ensure that no Eligible Body is disadvantaged. 

A: As per the ISS Reporting Guidance for each dowry payment you are required to state any amounts that were planned to benefit customers in that Assessment Period which were unable to be used. These should be reported under ‘PROPORTION (£X.XX) OF THE RELEVANT DOWRY UNABLE TO BE USED TO BENEFIT CUSTOMERS’ in the EB Monthly Dowry Report with an explanation.

The relevant details for repayment of those amounts from Eligible Bodies to BCR will follow. 

FAQs Relating to Both Schemes

A: The Senior Management Function (SMF) serves as an accountable person within organisations participating in either the Incentivised Switching Scheme or Capability and Innovation Fund. The SMF should be the accountable point of contact for BCR from the point of application through to the termination of the Agreement. This accountability covers submission of an Application Form, entrance into an Agreement (if successful) and delivery of and reporting on the Company’s obligation within the Agreement (if successful). The Applicant Company’s Board is ultimately accountable and should establish its own governance accordingly, including accountabilities of parties within the organisation. Even if the individual in the SMF post changes, there should be continuity of this role from the point of application through to termination of the Agreement.

A: We do not have this facility available on our website. We will be updating FAQ’s regularly and other information as required. The Scout Tool, which will be used to manage the application process, does have an alert capability and this will be deployed.

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