Frequently Asked Questions

CIF Pool E - Application Form

Note – all question numbers refer to application forms used in Pools A-D. We do not expect Pool E application forms to be substantially different – these will be updated post-consultation. 

Relevant to All

A: We will finalise application forms for Pool E when the consultation period has finished and we have taken final decisions on the grant sizes. It is expected that they will be relatively similar to those used in Pools A-D which can be found here. Depending on grant sizes, we will be amending the length of answers required and we may also reorder questions depending on the relative priority of assessment criteria which will also be shared once grant sizes have been finalised.

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: 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: No, there are no specific KPIs that the Financial Analysis should cover, however, Applicant Companies are expected to supply KPIs which align to their individual business and reinforce their public commitments and implementation timeline. 

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.

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. As a reminder, the list of the assessment criteria for Pool D is covered here.

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 2.5.1, Applicant Companies should define themselves the governance and controls they would put in place. In addition this should include how the applicant would enable monitoring by the Independent Body.

A: Applicants are advised that the long answer fields in Scout only permit free text responses. Applicants can choose to include pictures and tables in the attachments requested and reference these in the long answer. 

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.

A:Thank you for pointing this out to us. The application form on the BCR website is incorrect – this has now been updated. It should read “how the funds will be spent with the period.” It is up to the applicant to define the period in which the funds are spent, however, as per the guidance on the assessment criteria, BCR are interested in an applicant’s ability to deliver within timelines given (end 2022.)

A: It is important through this process that BCR treats all potential applicants fairly in the same way. We do not meet any applicants in the pre application closure period to discuss their Pool E business proposals or their previous application(s). BCR also no longer have access to the application documents from 2019.

We do, however, address questions that are not already answered and/or provide guidance where we can and then share this on an anonymised basis with all applicants. What we suggest you do is to look at the wealth of information on our website which can be found here including a comprehensive set of FAQs and if you have any clarification questions you can send those in via the Scout Message Centre.

 

A: No. The information provided by awardees in the previous pools is commercially sensitive. With all awardees, BCR agreed public commitments which were published on the BCR website and progress updates are provided against these on a quarterly basis. 

A: No. The only applications that BCR has retained are those of existing awardees. These are commercially sensitive for those organisations and cannot be shared.

Relevant to D Bodies

A: These terms are not defined and so should be given their ordinary meaning, however, in this scenario, Banking Competition Remedies expects to see as a minimum, the predicted impact of how the initiative will facilitate the commercialisation of financial technology on SMEs in the United Kingdom either directly or indirectly.

A: Our expectation is that applicants should be able to provide an audited balance sheet showing the investment but, if the investment occurred since the last balance sheet date, a management balance sheet showing the receipt of the investment and a confirmation from a director and the company’s auditor that the investment was in fact received/undertaken in that amount.

A: We assume in your question you are referring to 1.2.1 and 1.2.2. of the Pool D application.

Applicants will need to provide evidence of domicile e.g. link to company details on Companies House or appropriate national register.

Applicants should provide evidence of their live product and service offering to SMEs e.g. link to offerings on company website or alternative medium.

A: These terms are not defined and so should be given their ordinary meaning, however, in your responses to the Governance section please ensure you are clear about how you intend to deliver on your public commitments e.g. if in your business case if you have a substantial element of CapEx or marketing cost you will need to demonstrate to BCR, on an ongoing basis, how you are tracking your implementation approach.

A: BCR are using a new instance of the Scout tool therefore your previous application will not be available to the evaluation team. We would suggest that any information you want to include from your 2019 application is included in your submission for Pool E.

 

A: If you meet the eligibility criteria for both application periods, then an Applicant may submit an application in both application periods. Applicants can only be awarded one grant so if you were to be successful in the first period (D Bodies) then your application would be withdrawn from the second period (A/B/C Bodies).

A: BCR would ordinarily expect capital to be raised as equity. As a guide, debt does not qualify as “capital” from a legal perspective, therefore assuming that this is ordinary bank debt this would not meet the following eligibility criteria: (iii) which has raised capital of at least £1,000,000 in the three years prior to the date of submission of its Business Case.

A: Within one application an applicant can apply for up to two grants. Therefore it is perfectly ok to apply for both the £5m and £2.5m, however, an applicant can only win one award.

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. Applicant Companies should describe the core elements of their proposal within the initial word limit and use the additional word count to specify variation to their response in respect of the different amounts. 

Relevant to A/B/C Bodies

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 an extensive reporting suite for existing awardees and this will be shared in due course with successful Pool E applicants. 

A: Yes – as per Annex 3, this question is specific to the extent to which the Applicant Company commits to purchasing innovation 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: Independently of their future offering or their current customer base, 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.

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: Using the funds for M&A is not specifically prohibited, however, BCR would expect the applicant to demonstrate how this meets the purpose of Pool D to “facilitate the commercialisation of financial technology that is relevant to SMEs.” Additionally, BCR would expect the spend to be within the control of the applicant, therefore you would need certainty that the transaction will ultimately be concluded i.e. it cannot be a speculative business case.

A: It is up to the applicant to define the period in which the funds are spent, however, BCR’s monitoring and oversight extends up until the end of 2022, therefore 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.

A: Pool C Bodies will only be assessed against the Pool C assessment criteria, under the following purpose:

“to facilitate the expansion of business offerings to include, lending or payments services to SMEs in the United Kingdom or international payments services to SMEs in the United Kingdom.”

The awards are not fixed, so a Pool A, B or C Body could apply for any two of the three grant sizes.  

A: Each application is reviewed independently, therefore you would be required to submit two 3-page documents. This is to ensure fairness across all applicants regardless of whether they apply for one or two grants. 

A: 1) Yes. Pool E is open to all applicants, including those who won awards in the original Pools A-D last year. 2) No. An applicant can submit one application, and within the application, an applicant can apply for a maximum of two awards. If you were to apply for the £35m and £25m grants and your application was unsuccessful you would not be considered for a £10m award.

CIF Pool E - Eligibility and Assessment Criteria

Relevant to All

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: As mentioned in our consultation letter, it is likely to be important for Pool E 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: Yes, applicant companies who have common beneficial shareholders and directors in common can be awarded grants under different application periods.

A: Yes, applicant companies who are members of the same group but operate as separate legal entities and carry out different business activities can be awarded a grant under different application periods. 

A: 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. 

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: 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. Partner entities do not need to meet the eligibility criteria. 

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.

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: Yes. Each Applicant can only be awarded one grant. Applicants should ensure they meet the eligibility criteria, found here before deciding which pool(s) to apply for. It is possible to apply for grants in both pools, however, it is very likely that BCR will not have publicly announced the award winners from the first application period before the application period closes for the second period.

Relevant to D Bodies

The eligibility criteria were agreed between Her Majesty’s Treasury and the European Union as part of Alternative Remedies Package. The definition of a Pool D Body makes it clear that applicants need to have raised at least £1m of capital in the three years prior to submission of the business case and, if this cannot be met, your application would be rejected.

A: It is stressed that it is down to the applicant to look over the assessment criteria and decide whether they think they are eligible. All applications will be assessed on its own merits and BCR are expecting a diversity of applications.

A: A Pool D Body eligibility criteria includes “which has raised capital of at least £1,000,000 in the three years prior to the date of submission of its application (“Pool D Body”).” This means that you need to have raised £1,000,000 in the 3 years preceding the date on which you submit your business case.

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 they have used and why they believe it is appropriate.

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 they have used and why they believe it is appropriate.

A: It is for the Applicant Companies to ensure the content of their application is clear and describes correctly their proposal, however in this scenario, Banking Competition Remedies expects the status of the FCA approval to be made explicit.

A: Banking Competition Remedies has not defined any specific mechanism to flag sensitive / private information, this is for Applicant Companies themselves to define. If the applicant company believes specific information is confidential or commercially sensitive they could highlight this at the relevant point in the application form.

A: Applicant Companies must refer to the eligibility criteria for a Pool D Body which is covered here and ensure their proposal fulfils the Pool’s requirements. In this scenario, Banking Competition Remedies does not see any reason why a lending product would not be acceptable, however, BCR is not in a position to comment on its advantages against other applications. Every application will be assessed based on their own merits.

A: As per the assessment criteria which is covered here, Banking Competition Remedies shall have regard to, and will therefore assess, the amount (if any) of its own funds that any applicant is proposing to invest in relation to the proposals outlined in its Business Case. 

A: The domicile of an entity is the place of its incorporation and, therefore, a company registered in the Channel Islands – Jersey/Guernsey is not eligible to be a Pool D Body irrespective of where its main office or place of business is located.

A: BCR would ordinarily expect the capital to be raised as equity. If this is not the case BCR will consider on a case by case basis any other structures such as convertible loans or subordinated loans, and will need to be satisfied that the proceeds of these structures are genuinely available to the entity and are equity-like, e.g. are subordinated to other liabilities. If this is not the case applicants must be very clear in their submission the nature of the source of funds and BCR will consider these on a case-by-case.

A: The requirements for the use of the funds are set out in the CIF terms and conditions which you can find here. In particular, condition 3.3 explains the purposes for which the funding can be used. You will see that the requirements are essentially that the use of the funds focuses on ensuring that the Fintech Product or Service is improved or developed in the United Kingdom. BCR’s interpretation of this requirement is that, provided the use of funds improves the Fintech Product or Service for use in the UK, the actual expenditure does not need to be exclusively within the UK. So, in your example, employees could be outside of the UK provided that they are working on improving the Fintech Product or Service for use in the UK.

A: It is not clear precisely how you envisage using the CIF funds but the requirements for the use of the funds are set out in the CIF terms and conditions which you can find here. In particular, condition 3.3 explains the purposes for which the funding can be used as well as a list of specific purposes for which the funds cannot be used. It is not permitted to, among other things, use the CIF funds to repay any existing liability or to provide financing directly to customers.

Relevant to A/B/C Bodies

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: 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 of the Capability and Innovation Fund Agreement.

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: 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).

A: Once BCR has received the final results of the Consultation and established the grant sizes, Banking Competition Remedies will aim to provide some guidance on the relative importance of the assessment criteria. As outlined in our press release which can be found here, we have highlighted that it is likely that it is important for projects to demonstrate that they can be completed by 31 December 2022. We recommend you visit our website on a regular basis for updates.

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 E and can evidence that you do meet the criteria, BCR will consider your organisation to be eligible.

A: The criteria for a Pool C Body clearly states that there must be some revenue to show revenue comes from the provision of financial services to individuals and businesses. Note the business does not have to generate a profit. If the applicant or applicant’s group does not generate revenue yet, it will be required to provide proof it has generated the majority of its revenue from financial services prior to submitting its application to ensure it meets the required eligibility criteria. 

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: The criterion you refer to requires the applicant to have revenue at the date it submits its application and for the majority of that revenue to derive from the provision of financial services to individuals and businesses. An applicant that does not have any revenue but that is part of a group can still satisfy this criterion 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 criterion 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 criterion. 

A: This eligibility criterion requires revenue to be derived from the provision of financial services to individuals and businesses. So this criterion is cumulative, which is supported by the next criterion, 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 criterion. 

A: The eligibility criteria for the Capability and Innovation Fund can be found on here. Only applications that meet the eligibility criteria on the closing date for application period 2 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: Within Pool E application period 2, 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 gives any entity the ability to demonstrate its projected financial performance over time. The application forms are expected to be available by the end of May, however, they will not materially change from the application forms used in Pools A-D which can be found here.

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: That is correct. It is not permitted to, among other things, use the CIF funds to repay any existing liability or to provide financing directly to customers. The requirements for the use of the funds are set out in the CIF terms and conditions which you can find here.

CIF Pool E - 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 E fund process. The assessment criteria be found here and we will share the relative priority of assessment criteria when the grant sizes have been finalised post consultation. 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 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 and the tight timelines involved, 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 option will be contact via the Scout tool. BCR may decide to meet applicants where deemed appropriate. 

Relevant to D Bodies

A: When we have received the consultation feedback, we will provide the grant sizes available. Applicants will then need to apply for defined grant sizes.

A: Both application periods 1 and 2 will be running within tight timeframes. It is expected that any successful applicant will only receive one award from the Pool E process and therefore in the event you are awarded a grant within application period 1, your other application will not be considered.

CIF Pool E - Legal Documents

Relevant to All

A: You should take your own legal advice on the terms of the CIF agreement but no, these clauses apply irrespective of which company is applying for funding. The successful applicant is responsible for procuring compliance with the clauses by its group. 

A: You should take your own legal advice on the terms of the CIF agreement, but your options, if you do not comply, would be to breach the contract or to repay the Funding Amount plus interest in accordance with clause 7.1(b) so that the CIF agreement terminates under clause 10.1(B).

A: You should take your own legal advice on the terms of the CIF agreement but no, this clause applies irrespective of which company is applying for funding. The successful applicant is responsible for procuring compliance with the clause. The contractual termination rights are set out in clause 10.

A: You should take your own legal advice on the terms of the CIF agreement which can be found here. There are a number of decisions and determinations that BCR has the power to make. For example, clause 7.1 sets out the right for BCR to determine that a Material Breach has occurred and clause 5.7 allows for BCR to decide in its sole discretion whether to accept an Updated Business Case or a Revised Business Case. Clauses 8.4 and 8.5 make it clear that those decisions and determinations can be exercised by BCR at its own discretion without recourse under the CIF agreement.

CIF Pool E - 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 E, we may look to align reporting dates to the quarterly reporting cycle already in place. 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 continue to publish against Public Commitments beyond the lifespan of Banking Competition Remedies Limited. 

A: BCR already has a successful template in place for existing awardees which it will be re-using as far as possible 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 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.

A: BCR recognises that awardees will need to provide confidential information to BCR in connection with the reporting process. BCR will use reasonable endeavours to keep that information confidential. The only exerts that are published are the updates to the public commitments.

BCR may share confidential information where required by applicable law or regulation. In addition, BCR may share confidential information with its employees, advisers, contractors, the monitor, HMT, the monitor’s and HMT’s employees, advisers and contractors, but will use reasonable endeavours to ensure that the recipient owes a duty of confidentiality in respect of that information.

CIF Pool E - Other

Relevant to All

A: BCR will consider any requests for the funding amount to be tranched over a period of up to 6 months but, given the Pool E timetable and the anticipated spend horizon, BCR does not expect this to be appropriate.

A: BCR expects applicants to use all funds awarded in accordance with the approved Business Case and excess funds achieved through cost savings would not be generally available to the applicant for other purposes. The Business Case can be updated from time to time in accordance with the process set out in the CIF agreement. So if cost savings are achieved then BCR would expect those funds to be used in accordance with the Business Case, and if the Business Case does not cater for the use of these funds BCR would expect the applicant to submit an amended Business Case for assessment by BCR. It is not anticipated that any cost savings would be returned to BCR, but this could happen where, for example, a Updated or Revised Business Case is not approved by BCR or an Awardee offers to return funds as part of its Updated or Revised Business Case.

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. 

A: The circumstances in which BCR can clawback funds is set out in the CIF agreement, which you should take your own legal advice on. You will see that the intention of the clawback mechanic is not to penalise successful applicants if their business cases, when implemented, are not ultimately successful. 

A: There are a number of occasions where funds might be repayable and these are set out in the Capability and Innovation Fund Agreement at clause 7. In summary, these occasions are:

In the event that an applicant is not able to use the funds in accordance with the business case that was submitted and either an Updated or Revised Business Case is not approved or an Awardee offers to return funds as part of an Updated or Revised Business Case. In this instance, Banking Competition Remedies may request the repayment (in full or in part ) of the Funding amount in which case the Company will be expected to make the repayment (together with interest at an annual interest rate equal to 8% above the Bank of England base rate, compounded quarterly and accruing from the date Banking Competition Remedies paid the Funding Amount to the Company until the date of repayment) within 5 business days of the date of the demand.

In the case of a Material Breach which is not capable of remedy or the Company has not provided Banking Competition Remedies with evidence to our satisfaction that the Material Breach has been remedied within the period specified by Banking Competition Remedies. Material Breaches are any material breaches of the Capability and Innovation Fund Agreement and include i) failure to use the Funding Amount for Permitted Purposes or in accordance with the business case or ii) use of the Funding Amount for Prohibited Purposes. In this instance, Banking Competition Remedies may request the repayment (in full or in part) of the Funding Amount in which case the Company will be expected to make the repayment (together with interest at an annual interest rate equal to 8% above the Bank of England base rate, compounded quarterly and accruing from the date Banking Competition Remedies paid the Funding Amount to the Company until the date of repayment) within 5 business days of the date of the demand.

If there is a change of control of the company such that the Company’s parent undertaking or another subsidiary undertaking of such parent undertaking is a bank with an SME market share in the UK of more than 14%, the company shall within 10 business days of such change of control return to Banking Competition Remedies any part of the Funding Amount which it has not spent as at the date that the transaction which would give rise to the Change of Control is announced. 

A: As per section 2.8 of the Capability and Innovation Fund Terms and Conditions, “Applicants should seek their own legal, financial, tax, regulatory and/or accounting advice before making any decision to apply for funding from or to participate in the Capability and Innovation Fund.”

A: BCR recognises that applicants will need to provide confidential information to BCR in connection with the application process. BCR will use reasonable endeavours to keep that information confidential. BCR may share confidential information where required by applicable law or regulation. In addition, BCR may share confidential information with its employees, advisers, contractors, the monitor, HMT, the monitor’s and HMT’s employees, advisers and contractors, but will use reasonable endeavours to ensure that the recipient owes a duty of confidentiality in respect of that information.

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

The Senior Management Function (SMF) serves as an accountable person within organisations participating in either the Incentivised Switching Scheme or the Capability and Innovation Fund. 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.

A: The SMF (for both CIF and ISS) should be the accountable point of contact for BCR from the point of application through to the termination of the Agreement (see Q2 of the FAQs relating to CIF & ISS on the BCR website). 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.

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