What is the Contingent Reimbursement Model “CRM” Code?

The Contingent Reimbursement Model, also known as the CRM Code is a set of guidelines designed to protect consumers who fall victim to authorised push payment (APP) fraud. 

There are many banks who have signed up to follow these guidelines and you can find the list at the bottom of this post. The CRM Code is a voluntary agreement, which means that not every bank provides this protection for their customers.

How does the CRM Code work?

It is a framework for the bank to follow when determining if an individual should be reimbursed, after they have fallen victim to an APP scam. Under the code, banks are expected to reimburse victims of APP fraud provided that they meet certain criteria outlined in the code. 

Banks can choose not to reimburse you under exclusions such as:

• The payment was not a scam but is deemed to be a “civil dispute” between a buyer/seller. For example, you bought a product that you are not happy with. 

• You didn’t have a reasonable basis for believing this was a legitimate opportunity or payment

• The bank provided you with an effective warning that you didn’t heed

Unfortunately, it’s recognised that banks are wrongly denying victims of fraud refunds under the code. In fact, the CRM code is being applied so poorly that the HM Treasury has announced plans to put legislation in place to make reimbursement mandatory. Therefore, unfortunately it’s not as simple as just reporting the fraud in some cases and often you’ll have to fight for your rights. Refundee can help you do this and you can complete our fraud claim form to get started, but this is also something you can do yourself by making a complaint to the bank and then taking them to the Financial Ombudsman Service. 

One of the key principles of the CRM Code is the fair treatment of their customers. This means that every bank has the responsibility to assess each case of APP fraud on its own merits and make decisions on reimbursement fairly and promptly. 

It is important to note that this code only covers you if you’ve transferred money to a UK account from a UK bank that has signed up to the code. It also only covers payments made the 28 May 2019 when the code came into effect and the 6th October 2024 when it was then replaced by the Payment Services Regulator’s Mandatory Reimbursement.

If you think you are eligible and have unfairly been denied a refund, Refundee can help you get your money back from your bank and you can fill in our fraud refund claim form for a free consultation. Our fee is 15% plus VAT on anything that we get back, and we don't charge anything if we are not successful. For larger cases, the fee is subject to a maximum of £10k plus VAT per case.   

Remember, you don’t need to use a company like Refundee - you could work your case yourself for free! If you’d like to get a refund yourself. You can do this by following the ‘Claim Yourself’ guide here: https://www.refundee.com/claim-yourself

Who is signed up to the CRM?

Barclays Bank UK 

The Co-Operative Bank

HSBC including First Direct and M&S Bank 

Lloyds

Halifax Bank of Scotland

Metro Bank 

Nationwide Building Society

NatWest Bank 

Royal Bank of Scotland 

Ulster Bank 

Santander 

Starling Bank  

Virgin Money and Clydesdale Bank

Monzo Bank has also committed to applying the principles of the CRM code but hasn’t officially signed up. Therefore the Financial Ombudsman holds them to CRM standards. 

To be eligible:

• You must have paid via a transfer of funds via the faster payments network, CHAPS or an internal bank transfer to another UK account. 

• The transfer(s) must have happened on or after 28 May 2019

• The payment must have been from one of the banks above. 

If you aren’t covered by the CRM code it’s not the end of the world. In fact, most cases that Refundee helps with are not covered by the CRM. Banks have general obligations to prevent their customers from being defrauded. If you want to know more about other options you can speak to us at Refundee.

What if you think you’ve been unfairly denied a refund under the Contingent Reimbursement Model Code (CRM)?

If you’ve told your bank and they either didn’t refund you or only partially refunded you, you can raise a complaint against them or Refundee can help you get your money back. To do this you can fill in our fraud refund claim form for a free consultation. Our fee is 15% plus VAT on anything that we get back, and we don't charge anything if we are not successful. For larger cases, the fee is subject to a maximum of £10k plus VAT per case.   

Remember, you don’t need to use a company like Refundee - you could work your case yourself for free! If you’d like to get a refund yourself. You can do this by following the ‘Claim Yourself’ guide here: https://www.refundee.com/claim-yourself.