This chapter applies to a firm in relation to a current account measurement period (see BCOBS 7.7.1R):
(a) in respect of personal current accounts held with the firm under a trading name of the firm, if:
(i) at the start of the current account measurement period, 70,000 or more personal current accounts are held with the firm under that trading name; and
(ii) 70,000 or more personal current accounts were held with the firm under that trading name throughout the previous two current account measurement periods; and
(b) in respect of business current accounts held with the firm under a trading name of the firm, if:
(i) at the start of the current account measurement period, 15,000 or more business current accounts are held with the firm under that trading name; and
(ii) 15,000 or more business current accounts were held with the firm under that trading name throughout the previous two current account measurement periods.
Where:
The effect of TP 9 is that a firm that on 15 August 2018 has 70,000 or more personal current accounts, or 15,000 or more business current accounts, under one of its trading names, and which has had the requisite number of accounts since 1 February 2018, must comply with BCOBS 7 from 15 August 2018.
Which seems to me to mean they have not had 70,000+ personal current accounts or 15,000 business current accounts from 1 February 2018. As to whether they now have 200,000+ is anyones guess.
I think this might be the key bit, they wonât have had over 70k accounts for the preview two measurement periods.
Also, how long does a measurement period last? Edit - A) 6 months.
We proposed that where firms have fewer than 70,000 PCAs or 15,000
BCAs but later meet this threshold, they should not be required to measure service
information for two quarterly reporting periods. This allows firms at least six months to
introduce the required measuring and reporting capability.
As the first measurement period began in February 2018, the first reporting period is August. If they had 70,000 in February they would have had to report now.
All that said, arenât Starling now compliant? When I first looked at the FCA website, I did think that they were missing. Theyâre now present and the info is also in the blog post I linked toâŚ
I donât believe thatâs the case. I think thatâs an ongoing clause. The implementation details state any bank with 70,000+ from the first reporting period starting 1 February 2018 have to report in August 2018.
As a new challenger bank Starling has not yet reached the threshold for publishing customer satisfaction scores, but with a user base growing at a rate of 20 per cent a month, we soon will be.
Which is the important bit for the purposes of this regulation. The information they have published they have to do so regardless of customer numbers.
1.20 The rules set out in Appendix 1 will come into force on 15 August 2018. On this date,
providers will be required to publish standing data related to account opening and
service availability and major incident metrics.
1.21 Transitional provisions will allow firms not to publish account opening metrics and debit
card replacement metrics until 15 February 2019. To publish these metrics from this
date, firms will need to start recording and measuring the time taken to open accounts and to replace a debit card from 1 October 2018.
as you said, it looks like they didnât have more than 70k customers in Feb & we have a long wait to find out how many they do have
If they had, had 70k accounts in February then with a 20% growth rate, theyâd have only got to 200k+ users this month. But theyâve only recently stepped up their advertising
The worst part of this for me is that Starling can now charge interest to customers with a positive overall balance just like Monzo do.
Iâm just asking because a lot of the folks who were upset about this justified using Starling over us because of it. I am genuinely interested in how it works on their end compared with our present offering.
I guess what Iâm saying is - I understand why we do it, because we believe the user is in control over whether or not they have money in Pots that theyâd like to keep separate from the main balance, but I donât know enough about the Starling offering to know whether itâs the same kind of thing?
This refers to the new âloansâ product. If you take out a loan then you will be charged interest regardless of your overall balance. Overdrafts continue to be offset by any money held in âGoalsâ.
The loan is an option for people, and whilst itâs linked to the overdraft (and the potential overall borrowing is linked), itâs still a different product.
So if you arenât using a loan, itâs business as usual.
If you take out a loan, youâll be charged interest - Even if you have ÂŁ100,000 in goals (which is fair enough).
Cool. I get that itâs a different product. Practically speaking though, they are both borrowed money, just that people view overdrafts and loans in a different light (and I guess you commit to a specific re-payment plan in advance?)
When you dip into your overdraft to re-pay the loan though⌠thatâs where it gets confusing
Which begs a question I hadnât even considered. If you do have say ÂŁ10,000 in your Goals, and and overdraft of ÂŁ5000, will they let you know a loan is a terrible idea as youâd never be charged interest on your overdraft?
