Frequently Asked Questions

Capability and Innovation Fund FAQs

Pool A, Pool B & Pool C

A: Application forms for Pools B and C were posted on the BCR website on the 29th October and can be found here. The Pool B and C test events are also now live and you can request access by emailing BCR Admin which will allow you to access the application forms on line in the test event.

A: There are specific criteria for each of the Pools which has been available on the gov.uk website for some time (please click here). Where possible, there will be similarity in the application forms’ approach and requests for information.

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 will 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.

[Applicants should also refer to the CIF Rules included as schedule 3 to the Trust Deed.]

A: Pool C is open to 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 Pool C 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: Yes. Pool C specifically caters for any applicant 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.

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: 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.

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: The Terms and Conditions set this requirement. If you believe that other forms of supporting “commercialisation of such services” are relevant to your business case then you should include detail on this. All bids will be judged on their relative merits.

A: The application for each grant will be assessed on its own merits and you are, therefore, where additional word count is provided, expected to use the incremental word count to cover information pertinent to each separate grant.

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 are currently building our reporting suite and this will be shared in due course with successful applicants.

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: 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: Applicants should ensure that all attachments are legible on A4 format. 

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.

Pool D

A: All applications will be reviewed based on their own merits. Baringa, an organisation with expertise in procurement and tender management across multiple sectors, are assisting Banking Competition Remedies in the evaluation process. If you review the Pool D application form here, you can see what information we are requesting to enable us to evaluate each application. The assessment criteria can also be found here.  

A: The pool timeline has been set by Her Majesty’s Treasury and the European Union as part of Alternative Remedies Package. It is up to each potential applicant to decide when to submit their application.  There is no advantage or disadvantage on the timing of the submission, although note that questions will continue to be answered up until 1 February 2019 and the responses may impact upon your application.

A: 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 fully expecting that within Pool D we are expecting a diversity of applications. 

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: Yes, this is the way the project has been structured so applicants need to be thinking of the best way to deploy £5m.

A: Pool D 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: Pool D eligibility criteria is covered here. A Pool D applicant must be an entity:

(i) Which is domiciled in the United Kingdom, the European Union, the European Economic Area or Switzerland;

(ii) Which (a) provides or develops financial products or services predominantly to or for SMEs in the United Kingdom or (b) provides products or services to the businesses described in (a): and

(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 (“Pool D Body”).

The eligibility criteria was set for BCR and is clear that, at the time of the application, the applicant needs to either be providing or developing financial products or services for UK SMEs or providing products or services to businesses who do so.

A: This question is already addressed in both Questions 19 and 27 in the FAQ section for All Pools and is already included within the Scout FAQs. We urge all applicants to look at FAQs prior to submitting questions.

A: This is already dealt with in All Pools -FAQ 19 on the BCR website and is already included within the Scout FAQs. We urge all applicants to look at FAQs prior to submitting questions.

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 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.

All Pools

A: You can find our eligibility criteria on our website here

A: The eligibility criteria and timelines for the Capability and Innovation Fund can be found on our CIF Homepage. Only applications that meet the eligibility criteria on the closing date for a pool eg 31st December for Pool A applicants can be considered for a grant.

A: Each potential applicant should consider the eligibility criteria for each Pool for which it wishes to be considered. It must then make a separate application to each Pool and reference which awards in the Pool it wishes to be considered for. As an example, if in Pool A, an applicant wishes to be considered for any of the 3 awards, it will need to make this clear and provide supporting information to enable the Banking Competition Remedies to evaluate its application in respect of the awards. It is expected that any successful applicant will only receive one award from the Capability and Innovation Fund. 

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 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

Furthermore, in respect of Pool A, the Capability and Innovation Fund assessment criteria require BCR to give a preference to Pool A Beneficiaries with an established Business Current Account offering.

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 any subsequent updated business case is not approved. 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: The assessment criteria that applications will be measured against is found here. The application forms for Pools A and D are currently on our website and can be found here

Pools B and C application forms will be added during the week of 22nd October 2018.  The application form is clear in what it is seeking for each criteria.

There is no required form for a business case and it is for applicants to come to their own conclusion as to how to best present their submission.

A: No you do not for Pool D. The eligibility criteria for Pool D can be found here

A: If you meet the eligibility criteria you can apply for any pool – remembering that where applicants are successful there will only be one award made per company.

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: Business cases that deliver a benefit sooner will be viewed more favourably. As part of your application, you should consider if successful,  in what time frame you will spend funds and a realistic time frame in which you will derive benefits from the funds for SMEs. We expect that this will be individual to each applicant and will also depend on the size of any award. If your application is successful, you will be also be required to publish public commitments. If you fail to meet the milestones you have promised, you risk having funds clawed back so it is important that you are comfortable with the timelines in your submission.

A: We will be publishing our reporting requirements online so you will be able to find them on our website.  Monthly MI for successful applications will be based on the core information required in the application form which is outlined clearly within section 4 Reporting Obligations of the Capability and Innovation Fund Agreement and any additional KPIs the successful applicant provides as part of the business case.  

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: When the agreement is signed, funding will either be released in full within 40 days which is the default approach or can be, on request, released in tranches up to a maximum of six months from the signing of the Agreement. 

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: Applicants should look at the eligibility criteria for each Pool and, if they believe, they meet the criteria, they are able to apply for various Pools and awards within Pools. All applications will be assessed on their own merits for awards within Pools.

A: Business cases that deliver a benefit sooner will be viewed more favourably. As part of your application, you should consider if successful,  in what timeframe you will spend funds and a realistic timeframe in which you will derive benefits from the funds for SMEs. We expect that this will be individual to each applicant and will also depend on the size of any award. If your application is successful, you will be also be required to publish public commitments. If you fail to meet the milestones you have promised, you risk having funds clawed back so it is important that you are comfortable with the timelines in your submission.

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.

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: BCR will consider, in light of the applications received, the appropriate scope and frequency of information to be made public.  Once the Capability and Innovation Fund agreements have been signed by successful applicants, their public commitments will be published on the BCR website. 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.  

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: 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 face-to-face 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 option will be contact via the Scout tool. Face to face meetings and further follow up are only envisaged in exceptional circumstances.

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: 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.  In addition, on announcement of the successful applicants for grants, their public commitments will be published on the BCR website.

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: 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: Yes provided the eligibility criteria is met.

A: Successful applicants to the Capability and Innovation Fund will be required to submit reporting on a quarterly basis. The first of these reports will be required 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. Successful applicants should be prepared to enter into a Fund Agreement in the form provided on the website promptly following being awarded the grant. BCR may also request additional reporting where it considers it is appropriate. Reporting templates will be made available on the BCR website prior to Pool application windows closing.  Reporting will end in line with the termination of the Fund Agreement.

A: BCR is satisfied that it has access to the necessary breadth and depth of expertise and experience to assess applications. 

A: The requirement is for the Application Documents to have been approved by the board. BCR will look for evidence that the substance of the Application Documents has been approved, rather than any particular format or use of words.

A: This question is already addressed in both Questions 19 and 27 in this FAQ section and is already included within the Scout FAQs. We urge all applicants to look at FAQs prior to submitting questions.

A: This question is already addressed in both Questions 19 and 27 in this FAQ section and is already included within the Scout FAQs. We urge all applicants to look at FAQs prior to submitting questions.

Incentivised Switching Scheme FAQs

A: No, the named holder of Senior Management Function for the Incentivised Switching Scheme does not need to be involved with the submission/upload of the Application Pack. 

A: Applicant Companies who do not currently have a BCA offering should submit with their Application, a Switching Proposal and Customer Offer for the offer which will be made available in the future.  They should clearly state:

  • The launch date of their BCA offering to all customers
  • The effective date of the Incentivised Switching offer (the date on which they will be in a position to start accepting Incentivised Switching Eligible Customers)
  • A clear explanation of how their BCA offering to all customers differs from the offer made to Incentivised Switching Eligible Customers

This information should be provided within the Incentivised Switching Application Pack documents and no special or separate correspondence is required.

Should these Applicant Companies be successful, the timing of publication of their Customer Offers will be considered and discussed on a case by case basis in light of the timing for the launch of their BCA offering.

More details on this process will be shared in due course.

There is no deadline by which BCA offers must be available so long as the criteria are met. Of course, the term of the scheme and the availability of funding remaining should be a consideration.

A: Incentivised Switching Eligible Bodies can obtain aggregate data on Williams and Glyn customers direct from RBS (upon signing their Non Disclosure Agreement). Details on this and the data itself can be obtained by contacting jon.simpson@rbs.com or nick.perkins@rbs.com. 

Participating banks will be able to accept or reject customers at their own discretion, however dowry will obviously only be passed to participants for those accepted switched customers.
Also, 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).

In this case an applicant should submit the application under its holding company. The holding company or wholly-owned subsidiary named in the application must meet the eligibility criteria to be considered for Incentivised Switching.

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: The Incentivised Switching Communication Framework is available on the Reports, Publications and Documents section of the BCR website. Details on the Minimum Information Security Standards or ‘Minimum Information Security Requirements’ can be obtained by Incentivised Switching Eligible Bodies direct from RBS (upon signing their Non Disclosure Agreement) by contacting Jon Simpson or Nick Perkins

A: Clauses 6.1-6.5 do indeed afford the opportunity to amend offers subject to the agreement of Banking Competition Remedies Limited. However, bearing in mind the potential number of applicants for the scheme and the need to be fair to all, it is not envisaged that any amended offers will be entertained between award and launch. Once the Scheme is live and customer behaviour understood then proposals to amend will be considered in line with the provisions of the agreement.

A: This relates to information provided by RBS and as such has been confirmed by them. Clause 12 of the IS Agreement applies to all Personal Data (as defined in the IS Agreement with reference to the relevant data protection legislation) of in-scope customers passed by RBS to a relevant challenger bank and this will include certain details contained in the ‘consent file’ in relation to each customer sent via secure FTP. 

Where the relevant sub paragraph of clause 12 refers to “other information relating to Target Customers” or “other information relating to customers of the Group”, this captures data which RBS has also passed to the relevant bank (via the secure FTP or otherwise) which may not meet the definition of Personal Data but still relates to customers and to which a duty of confidentiality is owed. Clause 12 of the IS Agreement does not apply to any data (personal or otherwise) which the relevant challenger bank obtains directly from an in-scope customer.

RBS and BCR appreciate that the drafting of clause 12 of the IS Agreement may be interpreted more widely and will consider in due course to what extent a technical clarification may be required.

A: Details of Operational Readiness will be shared in due course. In the meantime, all Applicant Companies should expect to be able to demonstrate Operational Readiness in line with the nature of their offer and when it is proposed for launch. Both these pieces of information should be provided in their application as per Incentivised Switching Q2 above. 

A: Please see FAQ25 for response. 

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: Applicant companies that have their offers rejected will be notified individually. Applicant companies who have been successful will be publicly announced on 19th December 2018.

All the key dates are on the BCR website. 

A: BCR will consider submitted applications as final. You should therefore ensure your application is accurate and complete before you submit.

A: The deadline for submission is final and cannot be extended.

A: MI & Reporting requirements, templates and guidance for both Eligible Bodies and BCR is available here

A: BCR will aim to respond to all queries within five business days although this may take longer if the query is complex. You will not receive an automated response in the ISS data room, but we will get back to you.

A: No, it is the responsibility of the applicant to comply with the requirements of the form (including the word limit).

A: Yes, a version marked as redacted should be provided along with the application (even if no redactions have been made within) in order for the application to be compliant. Redacted content should be clearly marked as “[REDACTED]”.

A: You may only provide additional information which is directly requested in the application form. You should not attach files or provide URLs as part of your answers.

A: Only in certain circumstances. The process and application form is designed in such a way to reduce or avoid the need for clarifications. Applicant Companies are strongly urged to submit clear and complete applications early to allow time for BCR to raise and resolve and clarifications. Where bids are unclear and submitted close to the application window closing, BCR can only process clarifications on a best efforts basis.

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: No, Applicant Companies should ensure they download the latest version of the Application Form (currently v1.2) and should note the two minor changes which have been implemented since 16th October:
• Field 5.1 in the Authorisation section has been de-coupled from Turnover Band 5 in the Offer Description. This was an error which meant that content typed into one field would replicate in the other. This has now been resolved.
• The confidentiality clause (7th bullet in the Terms of Application) has been updated to provide greater clarity.

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: Participating in CASS means to be a member of the Current Account Switching Service.

The criteria for eligibility is assessed at the time the application is submitted. This criteria has been set and is not variable at this stage.

A: The indemnity set out at Clause 9.2 of the Incentivised Switching Agreement covers a limited series of specific categories, all of which are within the control of the Company.

In the context of the Incentivised Switching Scheme, and in particular the roles played by the BCR and RBS, the indemnity is reasonable as neither BCR nor RBS should bear liability for matters within the Company’s remit.

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: RBS will not comment or advise on whether an Applicant Company’s offer is suitable for the purposes of the scheme. BCR will receive and evaluate all applications and Customer Offers and will comment on their suitability.

A: No, the definition of a rejection can be found on Q25 of the FAQ section of the BCR website and only refers to applications for switching after the offer goes live. 

A: Yes, as Clause 12.16 of the Agreement states; The provisions of this Clause 12 shall survive the term of this Agreement.

*Please note this answer is no longer current and has been superseded by the answer to Q51*

A: Yes, as Clause 12.16 of the Agreement states; The provisions of this Clause 12 shall survive the term of this Agreement. 

*Please note this answer is no longer current and has been superseded by the answer to Q52*

A: Applicant’s should take their own legal advice on the meaning of the provisions in the Incentivised Switching Agreement. The clause in question requires the prior written approval, except where required by Applicable Law, of RBS where the announcement relates to a Data Security Breach which would lead to the identification of RBS or any member of the Group. Data Security Breach is defined in clause 12.13.

A: Reporting templates will be available here well in advance of entering agreements. These will provide definitions and guidance to Eligible Bodies regarding providing relevant MI.

A: An Applicant Company is expected to provide clear evidence that it “has publicly stated its intention to launch” a Business Current Account offering. This evidence should demonstrate that the statement has been made in a public forum and that this statement has firm intent and commitment.

A: To meet the requirements in Section 3.e, the Applicant Company should set out their Company Offering in the Offer Template provided on the BCR website.

A: The text provided within the offer template is at the discretion of the Applicant Company subject to the applicable template guidelines, law and regulations. Please bear in mind however, RBS has stated that it will not be using the term ‘Dowry’ in its communication to customers on the grounds that the ‘Dowry’ is paid to the Applicant Company not the customer.  

A: Clauses 6.1-6.5 of the Incentivised Switching Agreement afford the opportunity to amend offers subject to the agreement of Banking Competition Remedies Limited. This includes changing the range of segments offers are proposed to. 

A: By submitting an application, you confirm that you will, if successful, enter into the relevant scheme agreement on the terms set out on BCR’s website.

A: RBS have stated that, on entering the microsite, Target Customers are asked to select the sort order of offers by choosing either A-Z or Z-A, ahead of the offer listing relevant to them being displayed. They can then easily filter these offers by selecting features of the offers that are important to them and/or by selecting the Eligible Body brand logos shown across the top of the screen.

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: Applicants should take their own legal advice on the IS agreement.

12.1 is an acknowledgment by the Company that is a controller. 12.4 is an acknowledgment by the Company that RBS is also a controller. As two parties can both act as controllers in relation to the same data, there is no conflict.

12.1 goes on to acknowledge that RBS and the Company are not “joint” controllers. It follows that, to the extent they process the same data, that they must be independent controllers. Again, there is no conflict with clause 12.4.  

A: Please contact Nick Perkins or Jon Simpson if you would like to request RBS approval for transferring personal data provided by them under the Incentivised Switching Scheme outside of the EEA.

A: Applicants should take their own legal advice on the agreement. The intent of this clause is that the applicant is responsible for ensuring that other members of its group comply with the provision.

A: Applicants should take their own legal advice on the agreement. The intent of this clause is that the applicant is responsible for ensuring that other members of its group comply with the provision.

A: As set out in Clause 21.1, this is applicable where the Company has applied for participation in the IS Scheme in whole or in part for other eligible group members. If this is not the case, then it is not applicable.

A: Applicant Companies should ensure that the evidence provided clearly demonstrates its intention along with significant or reasonable commitment to deliver its expressed intention to expand its business offering to SMEs in the United Kingdom.

A: BCR believes the warranties are appropriate. Applicants should take their own legal advice on the IS Agreement.

A: In the event that the Applicant Company is unable to comply with the necessary steps identified by BCR in 7.5 (c), then clause 7.5 (b) is likely to apply.

A: RBS has stated that if the data is being processed after the Target Customer has in fact switched to a participant bank, then it would not be Personal Data for the purposes of clause 12 of the IS Agreement and clause 12.6 would not apply.

A: RBS has stated that if the data is being processed after the Target Customer has in fact switched to a participant bank, then it would not be Personal Data for the purposes of clause 12 of the IS Agreement and clause 12.13 would not apply.

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: All applications will be considered on their own merits. It is for applicants to form their own conclusion as to how they meet the criteria set.

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

A: BCR will only pay the amount of dowry to participant banks as set out in the Dowry Calculation Schedule. In respect of all other aspects, the Applicant Company should seek their own advice.

A: Please click here for the Reporting requirements and guidance for Incentivised Switching. 

A: All applications will be considered on their own merits. It is for applicants to form their own conclusion as to how they meet the criteria set.

A: BCR will pay dowries as set out in the Dowry Calculation Schedule. It is the Company’s responsibility to determine when payments are made to customers.

A: Applicant Companies should state as part of their application “any phasing or conditions attached to any cash amounts to be paid”. There is no limit imposed.

FAQs relating to CIF & ISS

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: BCR is prepared to accept, in place of a certified Board resolution, a certified resolution of a duly formed committee of the Board provided that an officer of the company also certifies that the relevant committee was duly authorised by the Board to pass that resolution.

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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