Regulatory 2

Overview

ClearBank, in all its activities, will adhere to the cross-cutting rules that articulate the standards of conduct expected by the FCA under Principle 12. The cross-cutting rules set out how ClearBank, and all firms in the distribution chain, should act (proactively and reactively) to deliver good outcomes for retail customers. It requires ClearBank, and all firms in the distribution chain, to act in good faith towards retail customers, avoid causing foreseeable harm to retail customers and to enable and support retail customers to pursue their financial objectives. ClearBank, and all firms in the distribution chain, are responsible for ensuring that the products and services are appropriate for the target market, provide fair value, and that appropriate communications and support is made available to retail customers and support good customer outcomes.

Accounts

Embedded Banking Current Account

Products and services outcome review

ClearBank’s Embedded Banking Current Account is held by Business Customers (SMEs) - either Incorporated firms or Sole Traders and is operated under ClearBank’s Embedded Banking Partnership proposition. The Embedded Banking Current Account attracts Financial Services Compensation Scheme (FSCS) protection for eligible retail customers and balances.

The Embedded Banking Current Account is not appropriate for Partnerships, LLPs, Charities, Financial Institutions or Holding Companies. The Embedded Banking Current Account is not appropriate for any groups/individuals requiring a joint account.

The Embedded Banking Current Account is only available in GBP Sterling. There is no overdraft facility, and the account should always be in a credit position or nil balance. FSCS protection is currently limited, by the Compensation Scheme, to £85,000 for each eligible retail customer. Where a retail customer holds multiple ClearBank accounts, either directly or indirectly, eligible balances may be amalgamated to a total of up to £85,000. There are no cash or over-the-counter services provided by ClearBank associated with this service.

UK registered Micro-enterprises, SME businesses and Sole Traders. The typical needs, characteristics and objectives of customers include micro-enterprises and SME business customers which require the use of a current account to deposit funds generated by and used for business purposes. Retail customers should not require physical branch access. There are no additional or different needs of the target market identified.

The FSCS is currently limited to £85,000 for each eligible retail customer. Retail customers should be made aware that balances may be amalgamated across accounts at the same institution. ClearBank has assessed that Embedded Banking Current Account does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

There is no overdraft facility available to retail customers - this should be articulated by ClearBank’s customers in the communications supporting the product, and extra care should be taken for retail customers with limited capital or in challenging economic environments (as part of eligibility criteria).

The Embedded Banking Current Account is distributed via ClearBank’s Embedded Banking Partners who service the retail customer directly. This distribution strategy remains appropriate for this product.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for Embedded Banking Current Account.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from the Embedded Banking Current Account.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of the Embedded Banking Current Account meets the requirements of the FCA Consumer Duty Products and Services outcome. The Embedded Banking Current Account has been developed to allow ClearBank’s target market customers the means with which to meet the needs, characteristics and objectives of retail customers the product is intended for. ClearBank is satisfied that the intended distribution strategy, via its third-party Embedded Banking Partners, remains appropriate for the target market.

Additionally, ClearBank is satisfied that the price and associated value to the retail customer for the Embedded Banking Current Account is fair relative to its benefits. ClearBank has designed the product to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the Embedded Banking Current Account, and no significant expected non-financial costs to retail customers in the target market.

Embedded Banking Savings Account

Products and services outcome review

ClearBank’s Embedded Banking Savings Account is held by retail customers, who are able to deposit funds into and withdraw funds from their Embedded Banking Savings Accounts. Interest can be earned on the funds held in the Embedded Banking Savings Account. The Embedded Banking Savings Account attracts Financial Services Compensation Scheme (FSCS) protection for eligible retail customers and balances.

The Embedded Banking Savings Account is not appropriate for any Partnerships, LLPs, Charities, Financial Institutions or Holding Companies. The Embedded Banking Savings Account is not appropriate for any groups/individuals requiring a joint savings account.

The Embedded Banking Savings Account is only available in GBP Sterling. There is no overdraft facility available, and the account should always be in a credit position or nil balance. Any funds withdrawn from the account will only be remitted to a nominated bank account held with a third-party provider. FSCS protection is currently limited, by the Compensation Scheme, to £85,000 for each eligible retail customer. Where a retail customer holds multiple ClearBank accounts, either directly or indirectly, eligible balances may be amalgamated to a total of up to £85,000. There are no cash or over-the-counter services provided by ClearBank associated with this service.

Retail customers are required to be UK residents and over 18, seeking to save their funds in an account that attracts FSCS protection. Retail customers should not require physical branch access. There are no additional or different needs of the target market identified.

The design of the Embedded Banking Savings Account allows retail customers to only withdraw their funds, which will be remitted to a nominated bank account at a third-party provider.

The FSCS is currently limited to £85,000 for each eligible retail customer. Retail customers should be made aware that balances may be amalgamated across accounts at the same institution. ClearBank has assessed that the Embedded Banking Savings Account does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

Additionally, there is no overdraft facility available to retail customers for the Embedded Banking Savings Account – this should be articulated by ClearBank’s customers in the communications supporting the product, and extra care should be taken for retail customers with limited capital or in challenging economic environments (as part of eligibility criteria).

The Embedded Banking Savings Account is distributed by ClearBank’s Embedded Banking Partners who service the retail customer directly. This distribution strategy remains appropriate for this product.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for Embedded Banking Savings Account.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from the Embedded Banking Savings Account.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of the Embedded Banking Savings Account meets the requirements of the FCA Consumer Duty Products and Services outcome. The Embedded Banking Savings Account has been developed to allow ClearBank’s target market customers the means with which to meet the needs, characteristics and objectives of retail customers the product is intended for. ClearBank is satisfied that the intended distribution strategy, via its third-party Embedded Banking Partners, remains appropriate for the target market.

Additionally, ClearBank is satisfied that the price and associated value to the retail customer for the Embedded Banking Savings Account is fair relative to its benefits. ClearBank has designed the product to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the Embedded Banking Savings Account, and no significant expected non-financial costs to retail customers in the target market.

Client Money Account

Products and services outcome review

Client Money Accounts are designed for Financial Institutions that hold money on behalf of their customers in accordance with the Financial Conduct Authority’s CASS 7 rules. It provides ClearBank’s customers with the ability to segregate retail customer funds from its own funds. The account attracts Financial Services Compensation Scheme (FSCS) protection for eligible retail customers and balances. ClearBank’s customers have the choice to use real accounts to manage their customers’ funds or, at least one real pooled account which can have up to 6 million Virtual IBANs attached.

Key benefits include:

- General Client Accounts allow one real account with multiple sub accounts underneath it known as virtual accounts. All the funds paid into virtual accounts reside on the real account ledger. These accounts are often called 'pooled' account as funds of multiple clients can be pooled together in the real account. Multiple real accounts are also available. Virtual accounts support the reconciliation of retail customer funds by providing a unique reference number which can be allocated to individual retail customers

- Designated Client Accounts enable clients to hold funds in a single named account, to support ClearBank’s customers to meet their regulatory obligations

- Confirmation of Payee provides additional security for retail customers

The Client Money Account is designed for businesses that hold client money on behalf of their clients and is not intended for retail customers.

ClearBank’s Financial Insitution customers can link a maximum of 50,000 Virtual IBANs to a General Client account each day. Financial Insitution customers wishing to open more are required to batch requests across multiple days. Virtual IBANs are limited to a maximum of 6 million for each General Client account. There is no overdraft facility available, and the account should always be in a credit position or nil balance. There are no cash or over-the-counter services provided by ClearBank associated with this service.

Financial Institutions required to segregate customers funds under the Financial Conduct Authority’s CASS 7 rules. This could include, for example, investment firms, wealth management companies, and other PRA/FCA regulated financial institutions holding client money.

The FSCS is currently limited to £85,000 for each eligible retail customer. Retail customers should be made aware that balances may be amalgamated across accounts at the same institution. ClearBank has assessed that the Client Money Account does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

Client Money Accounts are distributed via ClearBank’s Agency Banking (Financial Institutions) customers. They are not directly distributed to retail customers.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers for this Account as the Client Money Accounts are not directly used by or sold to retail customers.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this account as the Client Money Accounts are not directly used by or sold to retail customers.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of the Client Money Account meets the requirements of the FCA Consumer Duty Products and Services outcome. The Client Money Account has been developed to enable ClearBank’s customers to meet the needs, characteristics and objectives of retail customers in the identified target market. ClearBank is satisfied that the intended distribution strategy remains appropriate for the target market.

Additionally, ClearBank is satisfied that the price and associated value to retail customers for the Client Money Account is fair relative to its benefits. ClearBank has designed the product to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the Client Money Account, and no significant expected non-financial costs to retail customers.

Flexible Cash ISA

Products and services outcome review

ClearBank’s Embedded Banking Flexible Cash ISA is held by retail customers, who are able to deposit and withdraw funds from their Embedded Banking Flexible Cash ISA Account and hold a maximum of £20,000 in a given tax year as set by HMRC. Retail customers can withdraw funds in the tax year and replace it in the same tax year, without impacting the overall subscription allowance. Customers can transfer out within the tax year. The Embedded Banking Flexible Cash ISA Account attracts Financial Services Compensation Scheme (FSCS) protection for eligible retail customers and balances. The account pays a variable interest rate that tracks at a fixed margin below the Bank of England base rate, dependent on the balance. So, if the Bank of England base rate changes, your interest rate changes as well. In addition the Embedded Banking Client has the ability to vary the interest rate with 14 days notice to the customer.

The Embedded Banking Flexible Cash ISA is limited to customers 18 years or over and is only available for individual customers, joint accounts are not possible.

The Embedded Banking Flexible Cash ISA is only available in GBP Sterling. Any funds withdrawn from the account will only be remitted to a nominated bank account held with a third-party provider or an existing account held at ClearBank with the same Embedded Banking Client. FSCS protection is currently limited, by the Compensation Scheme, to £85,000 for each eligible retail customer. Where a retail customer holds multiple ClearBank accounts, either directly or indirectly, eligible balances may be amalgamated up to a total of up to £85,000. There are no cash or over-the-counter services provided by ClearBank associated with this service. Customers cannot transfer existing ISAs held with other ISA Managers into the Flexible Cash ISA, they can only transfer out.

Retail customers are required to be UK residents and over 18, seeking to save their funds in an account that attracts FSCS protection and protects interest earned from being taxed. Retail customers should not require physical branch access. There are no additional or different needs of the target market identified.

The FSCS is currently limited to £85,000 for each eligible retail customer. Retail customers should be made aware that balances may be amalgamated across accounts at the same institution. ClearBank has assessed that the Embedded Banking Flexible ISA Account does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.​

The Embedded Banking Flexible Cash ISA Account is distributed by ClearBank’s Embedded Banking Clients who service the retail customer directly.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for Embedded Banking Savings Account.

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for Embedded Banking Flexible ISA Account.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of the Embedded Banking Flexible Cash ISA Account meets the requirements of the FCA Consumer Duty Products and Services outcome. The Embedded Banking Flexible Cash ISA Account has been developed to allow ClearBank’s target market customers the means with which to meet the needs, characteristics and objectives of retail customers the product is intended for. ClearBank is satisfied that the intended distribution strategy, via its third-party Embedded Banking Clients, remains appropriate for the target market. ​

Additionally, ClearBank is satisfied that the price and associated value to the retail customer for the Embedded Banking Flexible Cash ISA Account is fair relative to its benefits. Any onward charging to retail customers is at the discretion of ClearBank’s clients. There are no known or expected costs for exiting or transferring from the Embedded Banking Flexible Cash ISA Account, and no significant expected non-financial costs to retail customers in the target market.​

Bare Trust Account

Products and services outcome review

The Bare Trust Account is designed to hold funds on trust for beneficiaries of a Trust. ClearBank’s customer is the Trustee of the Trust, who owes specific fiduciary obligations to the beneficiaries. The account attracts Financial Services Compensation Scheme (FSCS) protection for eligible customers and balances, in accordance with the FSCS’s own Guidance on Bare Trusts.

Bare Trust Accounts are not suitable for non-Trustees. This account can only be used for Bare Trusts. Other Trust arrangements would not be supported by this account.

Under the Depositor Protection rules, there are circumstances where the FSCS can ‘look through’ a named account holder (in this case the Trustee) to regard each ‘absolutely entitled’ beneficiary as a separate claimant. Each eligible beneficiary is entitled to FSCS protection of up to £85,000 in total. All deposits to which the beneficiary is entitled (held with the same bank or another bank in the same banking group) whether directly or as a beneficiary under a Trust would be aggregated.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

Bare Trust Accounts are intended to hold funds on trust for its beneficiaries. Bare Trusts are therefore suitable for any Trustee of funds being held for identified beneficiaries of the funds, pursuant of the specific fiduciary obligations owed to the beneficiaries.

The FSCS is currently limited to £85,000, and Trust beneficiaries should be made aware that balances may be amalgamated across accounts at the same institution. The FSCS timescale for pay-out for this product is 15 days, and the individuals within the Trust are required to provide valid Trust documentation to prove the ownership of the funds to the FSCS directly.

ClearBank has assessed that the Bare Trust Account does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

Bare Trust Accounts are owned by the Trustee who uses the account to hold trust-related funds. Bare Trust Accounts are not marketed to retail customers.

Price and value outcome review

ClearBank has identified the time taken for pay-out as a non-financial cost for the beneficiaries of the Trust, as FSCS aims to pay out in 15 days rather than 7 days for some other products.

ClearBank is not aware of, and does not expect, any additional costs to Trustees for exiting or transferring away from this account.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of the Bare Trust Account meets the requirements of the FCA Consumer Duty Products and Services outcome. The Bare Trust Account has been developed to meet the needs, characteristics and objectives of retail customers in the identified target market. ClearBank is satisfied that the intended distribution strategy remains appropriate for the target market.

Additionally, ClearBank is satisfied that the price and associated value is fair relative to its benefits. ClearBank has designed the product to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the account, and no significant expected non-financial costs to retail customers in the target market beyond non-direct FSCS pay-out.

Customer Segregated Account

Products and services outcome review

Customer Segregated Accounts are designed for Financial Institutions that hold money on behalf of their customers in accordance with the Financial Conduct Authority’s Safeguarding rules. It provides ClearBank’s customers with the ability to segregate retail customer funds from its own funds. The account attracts Financial Services Compensation Scheme (FSCS) protection for eligible retail customers and balances. ClearBank’s Financial Institution customers can choose from using only real accounts or a mixture of real and Virtual IBANs.

Key benefits include:

  • General Segregated Accounts allow one real account to which multiple Virtual IBANs can be attached. These accounts are often called ‘pooled’ accounts as funds of multiple clients can be pooled together in one account. Virtual IBANs support the reconciliation of retail customer funds by providing a unique reference number which can be allocated to individual retail customers.
  • Customer Segregated Accounts enable clients to hold funds in a single named account to support ClearBank’s customers to meet their regulatory obligations
  • Confirmation of Payee provides additional security for retail customers
  • Allowing retail customers to trade in multiple different currencies

This account is not appropriate unless there is a requirement to segregate funds under the FCA’s Safeguarding rules. This account is not suitable for firms obligated to segregate funds under the FCA’s Client Assets (CASS) regulations.

ClearBank’s Financial Institution customers can link a maximum of 50,000 Virtual IBANs to a General Client Account each day. Financial Insitution customers wishing to open more are required to batch requests across multiple days. There is no overdraft facility available, and the account should always be in a credit position or nil balance. There are no cash or over-the-counter services provided by ClearBank associated with this service.

Financial Institutions who are obligated under the FCA’s Safeguarding rules to segregate their customers’ funds. ClearBank’s customers’ Customer Segregated Accounts are not directly used by or sold to retail customers.

The FSCS is currently limited to £85,000 for each eligible retail customer. ClearBank has assessed that the Customer Segregated Account does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

Customer Segregated Accounts are provided to ClearBank’s customers who use the account to facilitate their business activity and their own regulatory obligations. Customer Segregated Accounts are not directly distributed to retail customers.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for Customer Segregated Accounts.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this account.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of Customer Segregated Accounts meets the requirements of the FCA Consumer Duty Products and Services outcome. The Customer Segregated Account has been developed to provide ClearBank customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market. ClearBank is satisfied that the intended distribution strategy, via its third-parties customers, remains appropriate for the target market.

Additionally, ClearBank is satisfied that the price and associated value to the retail customer for Customer Segregated Accounts is fair relative to its benefits. ClearBank has designed the product to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the account, and no significant expected non-financial costs to retail customers in the target market beyond non-direct FSCS pay-out.

Multi-Currency Accounts

Products and services outcome review

ClearBank’s Multi-Currency Accounts enable its customers to facilitate FX for their customers, with 12 currencies in scope (GBP, USD, EUR, PLN, CZK, HUF, SEK, DKK, NOK, CHF, RON, CAD).

The Multi-Currency Account is only offered to ClearBank’s Agency Banking customers. FSCS will not apply except where Multi-Currency Accounts are segregated accounts for the purpose of holding safeguarded funds, in which case see the section on segregated accounts with regards to FSCS protection.

The Multi-Currency Account is designed for Financial Institutions and is not intended for retail customers.

ClearBank’s Financial Institution customers can link a maximum of 50,000 Virtual IBANs to a General Client Account each day. Financial Institution customers wishing to open more are required to batch requests across multiple days. There is no overdraft facility available, and the account should always be in a credit position or nil balance. There are no cash or over-the-counter services provided by ClearBank associated with this service.

ClearBank’s customers who facilitate FX or hold non-GBP currencies on behalf of their customers. ClearBank does not offer this service directly to retail customers.

ClearBank has assessed that the Multi-Currency Account does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

Multi-Currency Accounts are distributed via ClearBank’s Agency Banking (Financial Institutions) customers. They are not directly distributed to retail customers.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for multi-currency accounts.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this account.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of its Multi-Currency Account meets the requirements of the FCA Consumer Duty Products and Services outcome. The Multi-Currency Account has been developed with a focus on meeting the needs, characteristics and objectives of customers in the identified target market. ClearBank is satisfied that the intended distribution strategy remains appropriate for the target market.

Additionally, ClearBank is satisfied that the price and associated value to the customer for the Multi-Currency Account is fair relative to its benefits. ClearBank has designed the product to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the account, and no significant expected non-financial costs to retail customers in the target market.

Payments

Faster Payments Service (FPS)

Products and services outcome review

ClearBank is a direct participant in the Faster Payments Services (FPS) System which entitles ClearBank to benefit from the FPS Service. ClearBank connects directly to the FPS System in order to send and receive payments in accordance with the FPS Rules. ClearBank settles payments made through the FPS Service directly with the Bank of England. FPS provides participants with the ability to initiate and receive near real-time payments 24 hours a day, 7 days a week, 365 days a year (or a 366-day year if it is a leap year). The FPS facilitates the following types of payments: Single immediate payments (“SIP”) (ClearBank supports both inbound & outbound), Payments originating overseas (“POOs”) (ClearBank supports both inbound & outbound), Forward dated payments (“FDP”), being a one-off payment scheduled in advance (ClearBank supports inbound only) and Standing order payments (“SOP”), being a scheduled / fixed amount payment (ClearBank supports inbound only).

While this type of payment service may be suitable for most retail customers, there may be some groups for whom it may not be suitable. For example: retail customers who need to make large payments; FPS Outbound Transaction Scheme Limit may limit the amount that can be sent in a single transaction; and retail customers who require assistance or support. Some retail customers may prefer to use banks or other Financial Institutions that offer more personalised support and assistance.

There is a £1,000,000 scheme limit per transaction for the FPS, which could be considered a limitation for retail customers wishing to make larger transfers. The service is unable to support outbound standing orders and future dated payments.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

ClearBank’s customers who facilitate payments on behalf of their own customers. ClearBank does not offer this service directly to retail customers. The target market is Financial Institutions providing individuals or businesses near real-time payment services.

ClearBank has assessed that the FPS does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank’s FPS is distributed by its customers, who may service the retail customer directly.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for its Faster Payments Service.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that its FPS meets the requirements of the FCA Consumer Duty Products and Services outcome. The FPS has been developed to provide ClearBank customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market. Due to the breadth of the target market and the risk profile of the service ClearBank is satisfied that the intended distribution strategy via third parties remains appropriate.

ClearBank is satisfied that the price and associated value to the customer for the FPS is reasonable relative to its benefits. ClearBank has designed its service to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the FPS and no significant known non-financial costs to retail customers in the target market.

ClearBank’s customers should consider the extent to which retail customers can get the most value out of the FPS, or whether an alternative service may be more suitable.

Bankers' Automated Clearing System (Bacs)

Products and services outcome review

Bacs is a clearing mechanism intended for high volumes of low value payments between GBP Sterling accounts, with a three-day processing cycle. ClearBank is a Direct Participant in the Bacs Scheme, which through its API and Webhooks can offer its Financial Institution customers indirect access to the service, receiving Bacs Direct Credit to, and paying Direct Debits from, the accounts on their allocated sort codes.

Key benefits of ClearBank’s Bacs solution include:

  • Receiving Bacs items as individual transactions as opposed to a bulk file
  • Intelligent processing of transactions so that Direct Credit items to a closed, credit disabled, or non-existent account are automatically returned to the sender
  • Management of Direct Debit Instructions and ensuring that the destination account exists, is open and debit enabled, and that a valid Direct Debit Instruction exists for every Direct Debit payment
  • For Real accounts, ClearBank can make a pay/no pay decision for a Direct Debit based on the account balance. If there are insufficient funds the Direct Debit is automatically returned
  • ClearBank’s Financial Institution customers can make a pay/no pay decision, based on the information available through the linked Virtual IBANs
  • ClearBank’s API offers a simple way for a Direct Debit transaction to be returned
  • Information about Direct Debit Instructions placed on the account is available through ClearBank’s Portal.
  • A comprehensive set of webhooks to keep ClearBank’s Financial Institution customers informed of the status of all Bacs items during the three-day processing cycle is also available

ClearBank’s Bacs service is not appropriate for retail customers requiring real-time payments services or to facilitate overseas direct debit and direct credit transactions.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

Financial Institutions requiring payments to be settled via batch services for direct debit transactions. Use-cases include salary payments, subscription payments, utility bill payments - i.e. payments with a known repeating settlement date.

ClearBank has assessed that the Bacs does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s Financial Institution customers.

ClearBank’s Bacs payment service is distributed by its customers, who may service the retail customer directly.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for this service.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the provision of the Bacs Service meets the requirements of the FCA Consumer Duty Products and Services outcome. The Bacs service has been developed to provide ClearBank’s Financial Institution customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market. Due to the broad nature of the target market, the service’s risk profile and industry standard use-cases ClearBank is satisfied that the intended distribution strategy, via its third party Financial Institution customers, remains appropriate. The ClearBank offering exceeds industry standards with regards to operational capability. Therefore ClearBank is satisfied that the provision of the service meets the requirements of the FCA Consumer Duty Products and Services outcome.

ClearBank is satisfied that the price and associated value to its Financial Institution customers for the Bacs service is reasonable relative to its benefits. Any onward charging to retail customers is at the discretion of ClearBank’s Financial Institution customers. There are no known or expected costs for exiting or transferring from the Bacs service and no significant known non-financial costs to retail customers in the target market.

ClearBank’s Financial Institution customers should consider the extent to which retail customers can get the most value out of the Bacs service, or whether an alternative service may be more suitable.

Bankers' Automated Clearing System (Bacs) Direct Debit origination

Products and services outcome review

Bacs is a clearing mechanism intended for high volumes of low value payments between GBP Sterling accounts, with a three-day processing cycle. ClearBank is a Direct Participant in the Bacs Scheme, which allows ClearBank to sponsor Financial Institution customers to originate (collect) Direct Debits from third party bank accounts. ClearBank’s Financial Institution customers are responsible for maintaining compliance with the Bacs Scheme Rules when taking the Direct Debit Instruction from the payer and collecting money subsequently from the account. The Financial Institution must execute a Bacs Indemnity in favour of paying the Payment Service Provider (PSP) which will be used if an error occurs in the collection process.

Direct Debit operates on a three-day clearing cycle, and funds are credited in bulk to the Financial Institutions account on the same day that the payer’s account is debited. Any debit items that cannot be collected are returned as Unpaid Direct Debits individually and will debit the Financial Insitutions account.

Arrangements can be put in place so that Direct Debits may be collected by ClearBank’s Financial Institution customers on behalf of the Financial Institution’s own (corporate) customers, in a model known as Facilities Management.

The ClearBank system offers a set of webhooks to keep ClearBank’s Financial Institution customers informed of the status of Direct Debit items during the three-day processing cycle.

ClearBank’s Bacs Direct Debit Origination (DDO) service is provided to its Financial Institution customers within its Agency Banking proposition, to facilitate payments for themselves and their customers. It is not intended for distribution to, or use by, retail customers.

ClearBank can offer sponsorship of its customers. This entails providing a Service User Number (SUN) which allows ClearBank’s customers to send data to Bacs directly via Bacs software; or indirectly via a bureau. ClearBank offers Direct Sponsorship and Facilities Management Sponsorship but ClearBank does not offer Agency Sponsorship

(sponsorship of the Financial Institution’s own customers).

ClearBank’s Bacs DDO service is provided to Financial Institution customers within its Agency Banking proposition to facilitate payments for themselves and their customers. It is not intended for distribution to, or use by, retail customers

ClearBank has assessed that the Bacs Direct Debit Origination does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s Financial Institution customers.

ClearBank’s Bacs DDO service is distributed via ClearBank’s Agency Banking (Financial Institutions) customers. It is not directly distributed to retail customers.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for this service.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the provision of the Bacs Direct Debit Origination Service meets the requirements of the FCA Consumer Duty Products and Services outcome. The Bacs Direct Debit Origination Service has been developed to provide ClearBank’s Financial Institution customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market. Due to the broad nature of the target market, the service’s risk profile and industry standard use-cases ClearBank is satisfied that the intended distribution strategy, via its third party Financial Institution customers, remains appropriate. ClearBank is satisfied that the provision of the service meets the requirements of the FCA Consumer Duty Products and Services outcome.

ClearBank is satisfied that the price and associated value to its Financial Institution customers for the Bacs Direct Debit Origination Service is reasonable relative to its benefits. Any onward charging to end-consumers is at the discretion of ClearBank’s Financial Institution customers. There are no known or expected costs for exiting or transferring from the Bacs Direct Debit Origination Service and no significant known non-financial costs to retail customers in the target market.

ClearBank’s Financial Institution customers should consider the extent to which retail customers can get the most value out of the Bacs Direct Debit Origination Service, or whether an alternative service may be more suitable.

GBP Cheques

Products and services outcome review

ICS (Image Clearing System), operated by Pay.UK, is a UK based Cheques Payment System that allows cheques to be processed in two working days. The Cheques product offers our clients the ability to process cheques received by their customers. ClearBank provides its clients with beneficiary and collecting bank services.

Cheques can be submitted to the ICS Scheme via Digital Remote Capture or through the Post.

Retail customers wishing to write cheques.

• ClearBank does not offer Issuing (Paying Bank) Capability

• This product is limited to GBP.

• The ClearBank API is open for digital Cheque deposit between 00:00 and 23.59 (Monday to Sunday). Cheques deposited before 19:00 on a Business Day will be accepted for settlement by 23:59 on the following Business Day. Cheques received after 19:00 on a Business Day will be submitted on the next Business Day and will be settled by 23:59 the Business Day following the day on which they are submitted.

• ClearBank allows our clients the ability to limit the value and the number of Cheques submitted on a given day via our Digital Remote Capture Solution.

• Retail customers should engage directly with their provider for assistance with queries or concerns.

Retail customers who have received a Cheque and wish to deposit the Cheque.

ClearBank has assessed that its Cheques service does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank’s Cheques service is distributed by its clients, who may service the retail customer directly.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for Cheques.

ClearBank does not impose any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the provision of the Cheques service meets the requirements of the FCA Consumer Duty Products and Services outcome. The GBP Cross Border service has been developed to provide ClearBank customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market. ClearBank is satisfied that the intended distribution strategy via third parties remains appropriate.

ClearBank is satisfied that the price and associated value for Cheques is reasonable relative to its benefits. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known costs for exiting or transferring from the Cheques service and no significant known non-financial costs to retail customers in the target market.

Internal transfers

Products and services outcome review

ClearBank’s Internal Transfer service is a system designed for its Financial Institution customers to move money between accounts they hold with ClearBank, at no cost. The service is provided 24 hours a day, 7 days a week, 365 days a year.

None.

None.

Any Financial Institution that has more than one customer and wants to facilitate seamless transfers between customers

Internal Transfers are not directly distributed to retail customers. If a transaction qualifies for an Internal Transfer, ClearBank will move the money internally and not to scheme. ClearBank does not envisage that utilising this service would cause any additional risks for the retail customer.

ClearBank has assessed that the Internal Transfers does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability.

Internal Transfers are an underlying capability across ClearBank’s payment infrastructure, and no distribution strategy is required.

Price and value outcome review

ClearBank are not aware of, and does not expect, any significant non-financial costs to customers in the target market for Internal Transfers.

No.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the provision of the Internal Transfers service meets the requirements of the FCA Consumer Duty Products and Services outcome. ClearBank’s Internal Transfers service is not visible and not interacted with directly by retail customers.

ClearBank is satisfied that the price and associated value to customers for the Internal Transfers service is reasonable relative to its benefits. ClearBank does not presently charge for its Internal Transfers service.

Confirmation of Payee (CoP)

Products and services outcome review

Confirmation of Payee (CoP) is an ‘account name checking service’ that can help avoid payments being misdirected due to errors, and address certain types of Authorised Push Payment (APP) fraud. It is a way of giving retail customers of payment systems greater assurance that the account name they are checking / sending their payments to is the intended recipient. CoP is a P2P API messaging service between participants which sits outside of the payment journey. Payments can be initiated irrespective of the outcome of the name check.

The service is less appropriate for some retail customers with characteristics of vulnerability, who may not want to be identified by these means. It is possible for retail customers to opt out of this service following a request and review, managed by ClearBank’s customers. ClearBank’s customers are responsible for managing the opt-out process for their retail customers, whereby they can request an opt out, and ClearBank's customers manage the request, decide on the outcome of the request, notify ClearBank of any successful opt out requests and manage retail customers’ queries or appeals related to the process.

ClearBank’s customers must mitigate against opt outs being used by fraudsters wishing to conceal their identity or retail customers opting out on an uninformed basis. ClearBank's customers’ decisions to approve opt outs should be based on careful consideration of each individual circumstance and the risk of detriment of remaining in the CoP service. The reason why a retail customer has been opted out of CoP must be provided to ClearBank. The decision to approve or decline an opt out request is at ClearBank’s customers’ discretion. Decisions made must also comply with any relevant legislation or regulations. ClearBank’s customers must also allow retail customers to opt into CoP after they have previously opted out. A reason does not need to be provided as to why the account has been opted in. There is no limit on how often an account can be opted in and opted out.

CoP can only be offered to customers with a ClearBank Bank Code. Customers with their own Bank Code will not be able to access the ClearBank CoP solution until the indirect CoP solution is formalised with Pay.UK.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

CoP is targeted at Financial Institutions to facilitate payments for themselves and their customers, using ClearBank payment services (any customer on the ClearBank Bank Code).

Retail customers with characteristics of vulnerability may not wish for others to be able to identify them through the use of CoP. However, customers can request to opt out of CoP, which does not restrict the customer from sending a CoP request themselves. Beyond considering suitability and impact of opt-out, ClearBank has assessed that the CoP does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

The CoP service is used by ClearBank’s customers to facilitate their own and retail customers’ payments.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to customers in the target market for CoP.

ClearBank is not aware of, and does not expect, any additional costs to customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the provision of the CoP service meets the requirements of the FCA Consumer Duty Products and Services outcome. The CoP service has been developed to provide ClearBank customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market.

ClearBank is satisfied that the price and associated value for the CoP service is reasonable relative to its benefits. ClearBank has designed its service to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the Confirmation of Payee service and no significant known non-financial costs to retail customers in the target market.

Payments Originating Overseas (POOs)

Products and services outcome review

ClearBank is a direct participant in the Faster Payments Services (FPS) System which entitles ClearBank to benefit from the FPS Service. ClearBank connects directly to the FPS System in order to send and receive payments in accordance with the FPS Rules. ClearBank settles payments made through the FPS Service directly with the Bank of England. FPS provides participants with the ability to initiate and receive near real-time payments 24 hours a day, 7 days a week, 365 days a year (or a 366-day year if it is a leap year). The FPS facilitates Payments originating overseas (“POOs”).

The central FPS infrastructure provides a response to the sending bank within 15 seconds, confirming that the receiving bank has accepted or rejected the payment. When rejected the receiving bank will also provide a reason for the rejection. Sometimes the receiving bank is unable to take the payment immediately, in which case the retail customer should be given a response indicating when they can expect the funds to reach the account.

ClearBank's FPS facilitates POOs as long as the payment is originally drawn on an account held outside the UK. Therefore this service is not suitable for retail customers with only a UK-based account. Due to the limitations on this payment service, POOs are not suitable for retail customers that wish to send and/or receive Standing Orders or Future Dated Payments. This service is not suitable for individuals who wish to make transactions over £1,000,000.

There is a £1,000,000 scheme limit per transaction for the POOs service, which could be considered a limitation for retail customers wishing to make larger transfers.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

Individuals or businesses who require inbound cross-border payments, where the payment is initiated from an account held outside the UK.

ClearBank has assessed that its POOs service does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank’s POOs service is distributed by its customers, who may service the retail customer directly.

Price and value outcome review

ClearBank is a direct participant in the Faster Payments Services (FPS) System which entitles ClearBank to benefit from the FPS Service. ClearBank connects directly to the FPS System in order to send and receive payments in accordance with the FPS Rules. ClearBank settles payments made through the FPS Service directly with the Bank of England. FPS provides participants with the ability to initiate and receive near real-time payments 24 hours a day, 7 days a week, 365 days a year (or a 366-day year if it is a leap year). The FPS facilitates Payments originating overseas (“POOs”).

The central FPS infrastructure provides a response to the sending bank within 15 seconds, confirming that the receiving bank has accepted or rejected the payment. When rejected the receiving bank will also provide a reason for the rejection. Sometimes the receiving bank is unable to take the payment immediately, in which case the retail customer should be given a response indicating when they can expect the funds to reach the account.

ClearBank's FPS facilitates POOs as long as the payment is originally drawn on an account held outside the UK. Therefore this service is not suitable for retail customers with only a UK-based account. Due to the limitations on this payment service, POOs are not suitable for retail customers that wish to send and/or receive Standing Orders or Future Dated Payments. This service is not suitable for individuals who wish to make transactions over £1,000,000.

There is a £1,000,000 scheme limit per transaction for the POOs service, which could be considered a limitation for retail customers wishing to make larger transfers.

There is an industry-wide limitation of return of funds capability, which may impact retail customers as ClearBank’s customers are unable to initiate return of funds directly. Instead, ClearBank’s customers are required to request with the ClearBank servicing team.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

Individuals or businesses who require inbound cross-border payments, where the payment is initiated from an account held outside the UK.

ClearBank has assessed that its POOs service does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank’s POOs service is distributed by its customers, who may service the retail customer directly.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for POOs.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the provision of the POOs service meets the requirements of the FCA Consumer Duty Products and Services outcome. The POOs service has been developed to provide ClearBank customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market. ClearBank is satisfied that the intended distribution strategy via its third party customers remains appropriate.

ClearBank is satisfied that the price and associated value for the Payments Originating Overseas (POOs) service is reasonable relative to its benefits. ClearBank has designed its service to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known or expected costs for exiting or transferring from the service and no significant known non-financial costs to retail customers in the target market.

Clearing House Automated Payment System (CHAPS)

Products and services outcome review

Clearing House Automated Payment System (CHAPS), operated by the Bank of England, is a UK-based electronic payment system that enables same-day payments to be made within the UK. Associated capabilities include MT103 and MT202 messages, used in the SWIFT payment network – a global messaging system used for international payments – to instruct the transfer of funds between ClearBank and its customers. ClearBank provides its customers with indirect access to CHAPS. CHAPS provides participants with the ability to make same-day payments, with finality of settlement, for any amounts of money during the CHAPS Availability Period.

Retail customers requiring same-day payment services to facilitate overseas transfer of funds.

CHAPS Payment Service is limited to GBP Sterling and UK-only payments. There is no limit to the size of a CHAPS transaction; however ClearBank reserves the right to impose a maximum limit for outbound payments. There are no cash or over-the-counter services provided by ClearBank associated with this service.

Outbound CHAPS payments can only be initiated by ClearBank’s customers during the CHAPS availability period (08:00 to 17:00 on Business Days). ClearBank has a cut-off time of one hour before the CHAPS scheme cut-off time. If the approval of the outbound payment occurs outside of the CHAPS availability period ClearBank treats that payment instruction as having been received during the next CHAPS availability period when the approval has been received.

Once a payment has been initiated by ClearBank, ClearBank’s customer cannot cancel or amend the CHAPS payment, per scheme rules. However, ClearBank’s customer can request that the CHAPS payment be recalled at any time after it has been settled.

ClearBank’s customers are not entitled to query an inbound payment made via the CHAPS service, per scheme rules. However they can return any inbound payment made via the CHAPS service to the originating customer where a payment has been made in error.

Retail customers who require same-day secure payments to any other UK bank accounts in near real-time via the SWIFT Network.

ClearBank has assessed that its CHAPS service does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank’s CHAPS service is distributed by its customers, who may service the retail customer directly.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for CHAPS.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the provision of the CHAPS Service meets the requirements of the FCA Consumer Duty Products and Services outcome. The CHAPS service has been developed to provide ClearBank customers the means with which to meet the needs, characteristics and objectives of retail customers in the identified target market. ClearBank is satisfied that the intended distribution strategy via third parties remains appropriate.

ClearBank is satisfied that the price and associated value for CHAPS is reasonable relative to its benefits. ClearBank has designed its service to be free at the point of use to retail customers. Any onward charging to retail customers is at the discretion of ClearBank’s customers. There are no known costs for exiting or transferring from the CHAPS service and no significant known non-financial costs to retail customers in the target market.

Multi-Currency

Foreign Exchange (FX)

Product and services outcome review

The Foreign Exchange (FX) service enables ClearBank to offer FX execution in specific currency pairs to our regulated customers.

The FX service supports flexible settlement: same day (TOD), next day (TOM) and SPOT value dates.

The FX service is not appropriate for any customers that require the execution of FX trades via channels other than API (e.g. electronic trading platforms). This service is not available to Crypto clients or customers with double nested flows.

This service is not appropriate for retail customers who wish to exchange currencies that are not supported within ClearBank's currency offering.

The multi-currency payments service is not suitable for ClearBank’s customers within its Embedded Banking Partner proposition.

The FX service supports 64 currency pairs, with a cut-off time of 22:00 for TOM and SPOT value. There is no service or support available on weekends or UK bank holidays.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

Any UK-regulated customer of ClearBank looking to provide FX services (i.e. FX trade execution) to a range of underlying customers, including retail. Customers in the target market use the FX service to buy and sell currencies for up to spot value, normally (but not limited to) in support of payables/receivables business.

ClearBank has assessed that its FX service does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

The FX service is distributed via ClearBank’s Agency Banking (Financial Institutions) customers. It is not directly distributed to retail customers.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for the FX service.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of its FX service meets the requirements of the FCA Consumer Duty Products and Services outcome. The FX service is provided with a focus on meeting the needs, characteristics and objectives of ClearBank’s customers, offering payments and FX capabilities in currencies outside of GBP to regulated customers.

This service has no underlying retail customers directly using or accessing the service. The service has been reviewed to establish the degree to which requirements of the Duty currently apply due to the potential for material impact to underlying retail customers, including via ClearBank’s customers who utilise the service.

ClearBank is satisfied that the price and associated value for the FX service is reasonable relative to its benefits. Underlying FX rates are provided by an FX market maker. In addition, automated incentivised pricing (inversely proportional to FX value/flow) is part of the service. Regular external benchmarking is carried out to ensure the pricing structure remains fair and in line with industry standards.

Multi-Currency Payments (MCCY)

Products and services outcome review

Foreign Exchange (FX) and Multi-Currency Payments (MCCY) service enables ClearBank to offer payments and FX capabilities in currencies outside of GBP to its regulated customers. ClearBank supports 11 currencies which allows its customers to send and receive electronic payments via API and execute FX trades (these are currently separate activities and two separate APIs).

This proposition improves ClearBank’s customers’ international payments experience by combining a superior multi-currency account and transactional solution. This solution is simple and automated, and offers a wide range of currencies and payment ‘track and trace’ capabilities. ClearBank’s Multi-Currency Accounts, where 1 IBAN is enabled for multiple currency balances, reduces operational complexity for customers.

The Multi-Currency Payments service is not appropriate for any customers that require the execution of FX trades via other means e.g. electronic trading platform. This service is only available via electronic payments. This service is not available to support cryptocurrency clients or customers with double nested flows.

This service is not appropriate for retail customers who wish to exchange currency that is not supported in the 11 currency offerings.

The Multi-Currency Payments service is not suitable for ClearBank’s customers within its Embedded Banking Partner proposition.

The MCCY service is limited to 11 currencies, supports only electronic payments, and there is no support offered on weekends or UK Bank Holidays.

There are no cash or over-the-counter services provided by ClearBank associated with this service.

ClearBank’s customers who facilitate FX on behalf of their customers. ClearBank does not offer this service directly to retail customers. The target market may include individuals, small businesses and other organisations who wish to hold or transfer funds in non-GBP currencies.

ClearBank has assessed that its MCCY service does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

The Multi-Currency Payments service is distributed via ClearBank’s Agency Banking (Financial Institutions) customers. It is not directly distributed to retail customers.

Price and value outcome review

ClearBank is not aware of, and does not expect, any significant non-financial costs to retail customers in the target market for its MCCY service.

ClearBank is not aware of, and does not expect, any additional costs to retail customers for exiting or transferring away from this service.

ClearBank has assessed that this product does not, as a matter of its design, limit retail customers with characteristics of vulnerability from making use of the relevant product benefits to the same extent as other customers. Any increased risk to vulnerable customers resides in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

No performance-related service level agreements have been breached that would challenge the price and fair value to the customer.

Summary

ClearBank is satisfied that the design of the MCCY service meets the requirements of the FCA Consumer Duty Products and Services outcome. The MCCY service is provided with a focus on meeting the needs, characteristics and objectives of ClearBank’s customers, offering payments and FX capabilities in currencies outside of GBP to regulated customers.

This service has no underlying retail customers directly using or accessing the service. The service has been reviewed to establish the degree to which requirements of the Duty currently apply due to the potential for material impact to underlying retail customers, including via ClearBank’s customers who utilise the service.

ClearBank is satisfied that the price and associated value for the MCCY service is reasonable relative to its benefits. Underlying FX rates are provided by an FX market maker. In addition, automated incentivised pricing improvements (inversely proportional to FX flow) are in operation. Regular external benchmarking is carried out to ensure the pricing structure remains fair and in line with industry standards.

Other

Institution Portal

Products and services outcome review

The Institution Portal is a front-end User Interface (UI) web page that can be used by ClearBank’s customers to view accounts / balances and transact on accounts (i.e. initiate a payment). There are two aspects to the portal – internal and external. Both versions exist to allow for user-specific changes to be made without impacting each other. The primary tool used by ClearBank’s ‘Non-API’ customers is to review the status of their accounts held with ClearBank, search for transactions, set up user profiles and make payments.

Retail customers do not have access to the Institution Portal, cannot interact with it and have no knowledge of its functionality or use. The primary benefit of the Portal is that it allows ClearBank’s customers to view and enact transactions / balance movements on behalf of retail customers. There is no direct feature or benefit that retail customers have exposure to.

The Institution Portal is used by ClearBank’s customers to search for transactions, set up user profiles and make payments. Making payments through the portal requires a manual process of inputting instructions - the portal is therefore not appropriate for ClearBank’s customers who wish to make large volumes of payment initiations.

The Institution Portal was created before ClearBank’s API strategy – it is therefore unable to consume and display new API events and Banking as a Service (BaaS). This limitation means that payments need to be inputted individually as API instructions.

Regulated Financial Institutions, to review the status of their accounts held with ClearBank, search for transactions, set up user profiles and make payments. Retail customers are not the intended target market for this service.

For ClearBank’s customers there is a risk that a payment could be incorrectly handled when acting on behalf of a retail customer.

For ClearBank, payments can also be held in the Portal for repair, return or screening (sanctions) and therefore there is a risk that payments may be held for retail customers, and payments not released that are suspected to be fraudulent or that breach sanctions.

ClearBank has assessed that the Institution Portal does not, as a matter of its design, raise any additional or enhanced risks for retail customers with characteristics of vulnerability. Any increased risk to vulnerable customers may be introduced in the Customer Services (systems, processes and support) and Customer Communications provided by ClearBank’s customers.

The Institution Portal is used by ClearBank’s customers. It is not distributed further to retail customers.

Price and value outcome review

N/A - no direct use of the portal by retail customers.

N/A - no direct use of the portal by retail customers.

N/A - no direct use of the portal by retail customers.

ClearBank expects its customers to experience at least 99.7% per annum uptime for the product.

N/A - no direct use of the portal by retail customers.

Summary

ClearBank is satisfied that the design of the Institution Portal meets the requirements of the FCA Consumer Duty Products and Services outcome. The Portal is not intended to be used by or interact with retail customers.

Additionally, ClearBank is satisfied that the price and associated value for the Institution Portal is fair relative to its benefits. The Institution Portal forms part of the overall service ClearBank provides to its direct customers and there is expected to be no financial or non-financial impact to retail customers.