Is Your Bank Signed Up To The CRM Code? | Wealth Recovery Solicitors

Is Your Bank Signed Up To The CRM Code?

APP scams (authorised push payment) are a huge problem and the number of those being affected by the scam is on the rise – just last year, victims increased by 22% compared to the year previous. As a result of so many bank users falling victim, in 2019 the CRM code, or the contingent reimbursement model, was set up to tackle APP fraud and scams, with banks volunteering to put methods in place to protect customers from such scams. 

But, as this is a voluntary action, not all banks are signed up to the CRM code. In our latest blog, we take a look at which banks are signed up to the CRM code and what this means for protecting customers from APP and other banking fraud. 

What Is The CRM Code?

The CRM code is a set of guidelines which have been developed to protect customers from APP fraud. This is a voluntary agreement, so not every bank offers this protection for their customers. The CRM bank code is governed by the Lending Standards Board (LSB), which sets out prosecution standards for banks to respond to, prevent and detect APP scams. 

Currently, the CRM code is the only set of consumer protections relating to online scams. Although the code is currently voluntary, there are set to be more stringent requirements coming into place on the 7th of October 2024 to further support APP fraud victims. 

How Does The CRM Code Work?

The CRM code framework is for the banks to follow when they are determining whether or not an individual should get reimbursement after losing money through an APP scam. Under the CRM bank code, banks are required to reimburse victims, given that they meet certain criteria outlined within the code. 

However, banks can choose not to provide a reimbursement under certain exclusions, including:

  • The payment wasn’t a scam, but is seen as a civil dispute instead between a buyer and seller. 
  • There isn’t a reasonable basis for whether there was a legitimate payment or opportunity. 

We believe, however, that banks aren’t always doing as much as they could be to reimburse victims, or that they are wrongly denying customers a refund when they are, in fact, eligible. In some cases, it isn’t as simple as just reporting APP fraud, more action may be required. The CRM code also only applies to UK to UK transactions, where money has been transferred to a UK account, from a UK bank that is part of the code.  If you believe you are eligible for an APP fraud refund, but have been denied, then we can get a case started to recover your money, on a no win, no fee basis. 

What Banks Are Signed Up To The CRM Code?

Currently, the following banks are signed up to the CRM code:

  • Lloyds
  • TSB
  • HSBC, including M&S Bank and First Direct
  • Barclays Bank UK
  • The Co-Operative Bank
  • Halifax Bank of Scotland
  • Metro Bank
  • Nationwide Building Society
  • NatWest Bank
  • Royal Bank of Scotland
  • Ulster Bank
  • Santander
  • Starling Bank
  • Virgin Money
  • Clydesdale Bank

Based on a report from the Payment Systems Regulator (PSR), currently the bank that is best at refunding customers is TSB, with roughly 91% of APP fraud losses reimbursed. Following this, Nationwide get 78% of losses refunded, while HSBC / First Direct get 73% refunded roughly. The TSB figure isn’t wholly conclusive, as they are unable to separate reimbursements from complaints which have been taken to the FOS, so this might be inflated. 

Popular banking providers Monzo and Revolut are currently not signed up to the CRM code, with figures putting Monzo at the top of the list in terms of banks most likely to be targeted by APP fraud criminals. If your bank isn’t part of the CRM code, then this doesn’t always mean that, should you fall victim to an APP scam, you won’t get your money back. We will still be able to trace and likely recover lost funds, but it just means that your bank offers less protections. 


APP scams are becoming increasingly more complex, persuasive and widespread. As such, with more people relying on online banking services, this means that increasing numbers of banking customers are falling victim to APP scams. It’s important to check that your bank offers APP scam protection so that you know should you fall victim to APP fraud your money is protected. If your bank isn’t part of the CRM code and you’ve lost money, or if your bank is unwilling to progress your case and recover your lost funds, contact WRS today for a free consultation. 

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