Henry Gibbon: Hello, everybody. It's Henry Gibbon here. Just a pleasure to introduce the first Evolving Insurance call of the year. As you know, on today's call, we're going to look at Confirmation of Payee, a new thing that's going to land from Pay.UK on the 31st of March.
I think we've had quite a lot of inbound queries around this because it'd probably fair to say that the general industry kind of messaging hasn't really been there. So a lot of our customers are really keen to understand more about it. We're trying to put an insurance lens on this for you as well, so really look at how it affects your premium collections, any other monies in and then claimed payments and other – and then other monies out.
What we're going to cover on the call today is an introduction to Confirmation of Payee, what's in scope, inbound and outbound payments, as I just said, and what you can do to prepare and practically the steps that you can make your business ready for both payments in and out of your business and I should say further to that, following this call where hopefully you'll get more information, if you've got further questions, please do get in touch with your relationship director. They'd be happy to set up calls bilaterally between us and yourselves to discuss this in more detail.
So without any further ado, I'm going to hand over to my colleague Katherine Moore who lives and breathes this stuff every day. We will have time for questions at the end. Please, please do feel free to ask them and if you'd rather come in and do that via your relationship directors and set something up at a later date, that's fine as well, but please do feel free to ask them, but I'll hand over to, Katherine.
Katherine Moore: OK. Thanks, Henry. Hi, everyone. OK. So I'm just going to talk a little bit today about Confirmation of Payee, as Henry says, and how it works, what it – what it means for all of us. As we know, it's going to go live very soon and you may or may not have heard about it, but hopefully we can take you through some of the general details about it and then there'll be an opportunity, as Henry said, to ask some questions.
So if you haven't heard of it or maybe you have, Confirmation of Payee, it's a regulatory initiative and it's a name-checking service which has gone to a lot to check the name based on the certain account number entered when you go to make a payment. So this is going to impact consumers and businesses alike and what we will see is the first six or seven banks taking part in this initiative from, as Henry said, the 31st of – the 31st of March and then we're likely to see it rolled out much wider in the industry.
So as I said, it's a name-checking service. So what will happen is when this goes live, when you go to make a payment, you will enter the sort code and the account number and enter the name of the individual or business you are paying. You will also then be asked to identify whether it's a person or a business that you're paying and when you enter that information, that will initiate the CoP check and the CoP check will go out to the account holding bank and what it will do is confirm whether those details match or not.
So there'll be four possible outcomes. They will either be a match, which will be a full match, which will confirm the name is correct. There will be a close match and that's where you have maybe typed the name incorrectly or maybe you've used an abbreviation instead of the full name in the case of a business and in a close match, you will be presented with the actual name of the account and then there will be the opportunity to select that account name that's been provided to you and achieve then a full match by doing that check again which will often happen automatically depending on what channel you're using.
The next option or alternative will be a no match. So the no match means that there is nothing or very little similar between the name you've input and the name that has actually been sent back by the beneficiary bank. Where there is a no match, you will not be presented with the actual name on the account. It will simply be a no match and the advice will be to check that name with the beneficiary that you're attempting to pay to make sure that this is not a fraudulent payment.
And the fourth outcome would be an unavailable. So an unavailable might be that the bank that you're trying to pay actually isn't part of the Confirmation of Payee initiative, it could be that whoever you're trying to pay have actually opted out of the service or maybe the account simply is out of scope for this – for this regulation. So there's a number of options that may be behind the unavailable if it comes back.
So no matter which option you get, you can actually proceed with the payment if you wish, but that will it mean that you will need to be accepting the liability for that payment and any future payments you make to that beneficiary. So that's a very different message to be presented with when you go to make a payment and something that will have to be accepted before you proceed to actually go ahead with that payment and that's in the case of a – of a no match.
Henry Gibbon: Can I just ask a question there? When you're going to input a payment on a repeat basis, is this information that you only need to populate once perhaps via a payment template or is it something you need to repopulate each time?
Katherine Moore: So strictly speaking, it will only be new beneficiaries and amended beneficiaries that a CoP check will be applied to and we'll go – I'll go through what the scope is for this first phase of Confirmation of Payee in a few minutes, but some banks may apply this to all payments.
Henry Gibbon: OK.
Katherine Moore: And when I say all payments, these are only FPS payments, CHAPS payments made on a – on a – on a single basis doesn't apply. I'll go through that scope, but I'll talk about that in a few minutes.
Henry Gibbon: OK. That makes sense because I guess it's worth just identifying here that each bank's adoption to this will be slightly different.
Katherine Moore: Right.
Henry Gibbon: So whilst hopefully we'll have – the spirit of everything will be the same, just to note that if you have other banking providers, their approach to it might be slightly different. Just worth nothing that.
Katherine Moore: Yes. Absolutely. So this has – this is being implemented really to tackle authorized push payment fraud. So this where you have impersonation fraud, CEO fraud that we're all very familiar with and really what it – what the industry have looked at is a huge amount of APP scams across the industry. In the first half of 2019, there was £207 million worth of APP scams. So I'd say it's a huge problem, particularly in the FPS and the CHAPS payment space. So that's what – that's what the initiative is trying to tackle.
I'll just talk a little bit about the timeframes. So the participating banks, so Bank of Scotland, Barclays, HSBC, Lloyds, NatWest, Nationwide, RBS, Santander and Ulster Bank.
If you don't have a copy of the presentation, we can share that with you afterwards, but those are the banks that have decided to be part of this first phase of Confirmation of Payee and by the 31st of March, all those participating banks have to be capable of sending out a Confirmation of Payee request and they've got to be able to receive and respond to any incoming requests from those participating banks.
So really by the 31st of March, that is when we will see, in the industry, this really widely rolled out and we'll see other banks taking part in this very soon after that. The expectation is this will ramp up quite significantly after that date and I'll talk in a little bit about what may happen after that date in terms of other phases of Confirmation of Payee.
So in terms of how we are delivering this as one of these participating banks, so this is governed by Pay.UK. It's the payment systems regulator that is regulating this and it's their direction.
So as Henry alluded to, there is a regulation that we have to adhere to, but how that is rolled out may be slightly different across the banks and where you might see that, the differences will be in terms of the actual matching rules applied to accounts. So you may see slightly differences where you have a number of different banking partners.
But broadly speaking, the regulation is very clear about what's in scope and what's not in scope. So I'm just going to read through what is in scope for phase one. So as I said, it's participating banks only. So it's the banks I have – I have mentioned and we can share that with you in more detail. Corporates businesses and consumers are in scope, so everyone is in scope for this. It's single payments only.
So what I mean by that is that it is individually keyed payments, so not where you have a file upload or you have a multiple – a multiple payment input. That would not be in scope of Confirmation of Payee. So these are individual payments only.
Henry Gibbon: So can I – just to – because I know this is a question that often comes up around here …
Katherine Moore: Yes.
Henry Gibbon: … but just for clarity, if you're loading a file of payments, a file of faster payments, 100 faster payments into Barclays.net, Confirmation of Payee doesn't apply at the moment …
Katherine Moore: Correct. Correct.
Henry Gibbon: … and also if you're loading a file of BACs payments into your BACs software, whatever that might be, I know those payments don't apply. It doesn't apply to that either.
Katherine Moore: It doesn't apply. Exactly.
Henry Gibbon: Just being crystal clear on that point as such.
Katherine Moore: Yes. Absolutely.
Henry Gibbon: Thank you.
Katherine Moore: And the same – the same for CHAPS actually as well.
Henry Gibbon: Yes. OK. All right.
Katherine Moore: Yes. So as actually, Henry, you've just alluded to there, it's FPS and CHAPS payments only that this applies to. So their – I don't – you may have heard that BACs within scope. It actually was in scope originally and I has been since removed from the scope. Reason for that is really this APP fraud is primarily based around or targeted around of FPS and CHAPS rather than – rather than BACs. So that's maybe something for the future, but certainly not for right now.
This also only applies to U.K. GBP sterling accounts only. So there's no international payments included in this. There's no – there's no other currency accounts included in this. It is – it is only U.K. sterling accounts. We mentioned earlier about new beneficiaries and amendments to existing beneficiaries. That is what the regulation covers. There will be some banks that include maybe more than that, but that is the minimum that needs to be included.
It's customer present transactions only and I know that's kind of bank speak, but it's where you are not physically there, either on the phone or online making the payment, the Confirmation of Payee check would not apply. So you've got to be over the phone making the payment or you've got to be actually doing it online yourself.
And the other piece that's included for phase one is confidential invoice discounting and some of you may have confidential invoice discounting accounts or solutions. If you do, those are in scope, but there's specific rules that apply to them. So if you do have any of those and you want to talk to your relationship team about those in relation to Confirmation of Payee, please reach out and do that and we can – and we can give you some more detail around those.
As I said, out of scope, BAC's out of scope, bulk payments, any other payment types are out of scope and if you have a file upload, that is out of scope. If you also have any host-to-host come activities, swift, EBICS, any of those non-online channel based solutions where you hand in your file via your – via your treasury system, they would not be in scope for this – for this phase.
And then the last part that is not included in the phase is actually agency banks. They are not included either. So there is a head office collection account out of scope solution that is in place for them for this phase.
So with that, I'm probably – I've covered quite a lot there in terms of what's in scope and out of scope and we will share that with you after the call if you haven't had it already. So for Barclays specifically, the channels that are in scope for this, the primary channel is Barclays.net. Some of you might also use iPortal, which is for your standing orders, and then BMAP or Virtual Account Solution.
All of those are in scope, so you will see changes in those channels and there will be in-channel communications sent out in the next couple of weeks as those channel – as Confirmation of Payee is rolled out onto those – onto those channels. If you do have any questions in relation to them, please contact your relationship team or servicing team.
The only other thing I just wanted to mention very briefly about Confirmation of Payee for those of you that are interested, it doesn't operate on a database solution. This is not a payment scheme. This is a service that sits before you make a payment.
So the way it works is based on the open banking infrastructure. So it's bank-to-bank APIs, so there's no central point for the information to be held. So your data isn't shared with anybody else or anything like that. It's over the open banking infrastructure.
So where a Confirmation of Payee check comes into us, we, via the API, send it to the beneficiary bank, they confirm the details and send it back, but what it's a common question that has – that has come up.
OK. So just the implications then, particularly for corporates and obviously ourselves as insurance companies. So one of the things internally with Barclays is Confirmation of Payee has meant that we need to update our terms and conditions.
That's a notification that will be sent out to you in the coming weeks and alongside that, there will be a general information document for Confirmation of Payee highlighting some of the changes, but really what we need to think about in terms of this service going live is really our any of your payments actually in scope for this?
So where you're sending out your claims to your clients, are any of those actually in scope? So do you actually key any of those individually into Barclays.net, for example? Are they FPS payments you're making? Are they CHAPS payments you're making?
If so, they will be subject to a Confirmation of Payee check. If you use file based, if you took the host solutions, they will be not in scope. So from an outside perspective, it's really just analysing which of these payments are actually in scope. Some of them may not be if you only upload by file.
The other thing you really need to consider for outline payment where these are in scope is really around your operational processes. So in Barclays.net, whoever the inputter is will be presented with the Confirmation of Payee check and the inputter will then get the response, whether it's a match, no match, close match or unavailable, and you will need to decide within your own companies what your risk appetite is, whether you want to accept that liability in the event of a no match or whether you want to then spare maybe to whoever the beneficiary is or back to your finance team, whatever works for you.
Your inputter then, as normal if they choose to proceed, will send it on then for authorization and authorizers will see the result of a CoP check. So they will see if a CoP check has been done and they will see what the outcome of that is and then they can choose whether to proceed or not or to refer it. So that's something operationally in terms of your processes that you might want to have a – have a think about.
Possibly more relevant for your types of business will be your inbound payments, so the receipts of your premiums. Now, if you're receiving most of your premiums via direct debit, these will not be in scope, but where you're receiving push payments, so FPS or CHAPS payments, so if somebody has defaulted on their direct debit and they need to make a one-off FPS payment to yourselves, they would most likely be asked to do a CoP check. So they'll be asked to input the name of the company that they're paying to.
So what you need to think about is really are you communicating the name on your account to those payers and that name will need to be the name that is matched with what is on our system. So really your registered name, your legal name, your trading as name would be the best – would get the best match most likely. We match against multiple sources within our system.
So if you do use other names that are not your registered name, trading as name, then we need to maybe have a conversation to make sure that we are most likely to get a match and where not, is there a requirement to communicate to your payers going forward.
Henry Gibbon: Can I just add a point there just from discussions with other people?
Katherine Moore: Yes.
Henry Gibbon: … other insurance companies? I think, sort of in summary to those pieces, the outbound payments, so payments you as an insurance company are either making to your suppliers or clients, and realistically it's probably more the supplier payments that sit outside that bulk upload …
Katherine Moore: Yes.
Henry Gibbon: … kind of process, that we just – from an operational perspective, it's just a real benefit because it's an extra layer of fraud protection and security …
Katherine Moore: Yes.
Henry Gibbon: … and hopefully one that we don't think will cause you too much kind of change, just adds in a small layer that gives you some more comfort of where you're sending money.
Where we see it as being more of an impact to an insurance company in inbound collections and very much not the bulk for the direct debits or the cards, which we understand is where you collect most of your premium, but it is ad hoc payments that people are trying to make to you.
And I think the part that we think the businesses should get ready about is that your call centers are perhaps prepared to deal with these kind of queries because if someone is trying to pay you, they're typing in what their name might be, I think one that was commonly used was if you were typing in BT for British Telecom, it's not a given that that would necessarily be a match and then they're not going to be calling the bank, so they're going to be calling your call centers.
So I think preparation around that part is sort of key to success here so they're prepared to be able to help answer those questions and queries.
Katherine Moore: OK. So just a little bit about what might be next for Confirmation of Payee. As phase one is rolled out, I'm sure we will see some lessons learned both within the banks and at industry level and really then what we will be looking to do is rolling this out to a wider range perhaps of payment types, maybe looking at extending to, well, other participants of course, maybe looking at file upload, bulk checks as a – something for the future.
Now, this is not something that's going to be happening today or tomorrow, but something that – the wider this can be rolled out, the more these APP scams are really tackled and fraud prevention is improved. So we might see – we might see this being rolled out, as I said, to other payment types, maybe Agency Banks and MSBs being included within the scope.
We will also see secondary data references being included potentially. So where you have Building Society Roll Numbers, credit cards, all of that could potentially come in for these – for these CoP checks.
What we may also see is more of a European initiative being rolled out. There are – there are solutions similar to this in country – across other countries in Europe and this is something that the industry here in the U.K. are speaking to other providers across Europe about to try and get – to try and roll this out in the best possible way.
Such as in the – in the Netherlands, there is a solution that allows a check across a number of different places for company names. So where you have a name registered with company types or across other banks, it would allow multiple sources.
So that's something that we may get to in the future, but what it would do is give a more – a wider base for getting that match and hopefully we will see an increase then in the matching rate, particularly when corporates have more complex naming structures then you would see in a – in a retail space.
So that's very – just giving a brief overview of what Confirmation of Payee is and will we open up to questions?
Henry Gibbon: Yes, we'll open up to questions and thank you very much for providing that comprehensive overview. Something I should have said at the beginning of the call, and sorry, that's remiss of me, you should have received the deck beforehand from your relationship director.
Please do reach out and let us know if you haven't because I know this will be useful material for you internally. We'll also be posting a link that you can get this from as well. Apologies. It was meant to be held as a WebEx, but we were slight – had slight limitations around the tech there, so we did it in a low-tech way and on a call.
But without that, operator, please would it be OK if we just opened up the lines to see if there are any questions?
Operator: Thank you. Ladies and gentlemen, we will now begin the question-and-answer session. As a reminder, if you wish to ask a question, please press "star" and number "1" on your telephone keypad and wait for your name to be announced.
Henry Gibbon: Just waiting for the question, would you mind just telling us a little bit more how the liability piece works? So if liability is getting switched on to an individual that's trying to pay an insurance company or to an insurance company trying to pay one of their suppliers, how does that work? A little bit more detail around that would be fab.
Katherine Moore: Yes. I mean, it comes down to the responsibility of the payer to actually pay who they thinks they're paying and be a little more stringent around the opportunity for maybe someone who has come in to impersonate a CEO or where you have that kind of scenario.
So it's really around that stringency to make sure that the payer is taking that responsibility and that's very different to what has – what has happened in the past. It very clearly lays out that the payer then is paying who they think they're paying.
Henry Gibbon: OK.
Katherine Moore: It really puts responsibilities on them to check that detail in a little more detail and this actually prompts them then to make that additional check and that comes back to for four companies, they've got to make sure that their servicing teams are equipped to actually handle these types of queries because it's very different to be presented with now you must accept liability …
Henry Gibbon: Yes.
Katherine Moore: … for the payment. If you think it might be less scary in the business world than in the corporate world, but for an individual making a payment to be presented with that, that's a very – it's a very different thing and something that will take a little while for the industry to get – to get used to, but when you accept the liability, it is for that payment and future payments. So we will see when this goes live what the appetite is. We don't have a sense of that at the moment.
Henry Gibbon: No. Of course. OK. Thank you very much and thanks for that detail. Operator, were there any questions on the line?
Operator: Yes, sir. We do have questions. Your first question comes from the line of Angela Gainey. Please ask your question.
Angela Gainey: Hi, Henry. Just wanted to check, is the check optional or do you have to do the check?
Henry Gibbon: Hey, Angela. Thanks for your question. No, there's no optionality around this. This is industry legislation. So just to – just to be clear, banks are adhering to legislation that has been put in, it's been formulated by Pay.UK, so the guys who look after U.K. payment infrastructure, things like BACs and faster payment schemes. So no, it's not optional. There's no opt-out kind of functionality around it.
Angela Gainey: What …
Henry Gibbon: Katherine, was there anything to add to that? Oh, sorry. Go on.
Angela Gainey: If we was to put a CHAPS payment through Barclays.net, would you have to go through the checking mechanism or is it – is it something that the user can opt to use or not use?
Henry Gibbon: No, you have to use it.
Angela Gainey: All right.
Henry Gibbon: I guess your optionality is around whether you're willing to – if you don't use it and you don't put a name in, you're accepting liability that it's potentially going to the wrong place …
Angela Gainey: Yes.
Henry Gibbon: … which, to be entirely honest, you kind of were before anyway by the nature of sending a push payment out, but this just makes it more explicit, I would say.
Angela Gainey: OK. I've got a few questions. Is that OK?
Henry Gibbon: That's no problem at all.
Katherine Moore: Yes.
Angela Gainey: Yes. How quick is the response once you've made the request?
Henry Gibbon: So I'm fairly sure, because it's working off the API rails, and this is open banking, that it's all instantaneous. So it's in real time. So something we should have mentioned on that point is you can use this using Barclays.net as a really good kind of fraud prevention or third sort of factor authentication of comfort of who you're sending your money to.
For instance, I know often that companies – insurance companies are worried that they're paying the correct beneficiary or claimant of that insurance policy. Here, if it was Paul Smith that was receiving that, you could check that before it – before you actually send that payment. So we do see this as potentially quite a powerful tool for you guys to use sort of going forwards and be more confident, but anything to add to that?
Katherine Moore: Yes. Hi, Angela.
Angela Gainey: Hi.
Katherine Moore: The way – the way it works in .net is when – so when you go to put in your payment there in the CHAPS screen or the FPS screen, you put in your account number, your sort cord and account number and the beneficiary name you think you're paying.
The only additional phase will be you need to click whether it's a business or person that you believe that you're paying. There's no button to say do a CoP check. It happens instantaneously by itself. It happens in less than two seconds. The response …
Angela Gainey: Great.
Katherine Moore: Yes. The response comes back and then – and then it's your choice what you do with that, whether you want to go ahead and pay or not. So the CoP check will happen by itself …
Angela Gainey: Right.
Katherine Moore: It's what you want to do with that response then that falls into your responsibility.
Angela Gainey: OK. That's fine.
Katherine Moore: Yes.
Angela Gainey: Yes. It was just the – it was the time elapse. I didn't know whether it was like a 15-minute window in terms of it going away and checking this and we have to wait for the response back, but you're saying it's seconds or minutes really we'd get that response.
Katherine Moore: Yes. Exactly. It's seconds.
Angela Gainey: Great.
Katherine Moore: Now, if it – if it didn't happen within seconds, it actually is outside of the regulations. So it has to happen that quickly. If for whatever reason it doesn't happen that quickly, there'll be a notification comes up to say it's not possible at this time and it will be as if there never was a CoP check there.
It'll just – you can go ahead and proceed with the payment. So it'll never stop you making the payment. It's an additional service before the payment happens.
Angela Gainey: Yes. And then my last point is, is there a cost of check? Are we likely to see – as a company, are we likely to see any cost of those checks being done?
Katherine Moore: No. I mean, we really want to make sure that we are introducing as many fraud prevention tools as we possibly can and this is – it's going to help us, it's going to help yourselves. So it's not something that we're going to be adding a cost to users for.
Angela Gainey: Great stuff. Thanks very much.
Katherine Moore: OK.
Henry Gibbon: Thanks. Thanks very much for your question, Angela. Appreciate that, Operator, do we have any other questions on the line?
Operator: Your next question comes from the line of Bipin. Please ask your question.
Bipin: Henry, Bipin here, CIB.
Henry Gibbon: Hi, Bipin.
Bipin: Hi. In the past, we've made check payments, we got lots of trading names and sort of permutations of the same name, but the branch hasn't really recognized it on your system. Will we be able to get access all the different names you've got logged against other company and then make sure all are there?
It's very mergers, acquisitions through that over the last few years, we've got various trading names registered. Don't log with Barclays, but locally, here staff still have problems finding it on the system. So what I have fear that is this check not recognizing some of the beneficiary names we've got.
Henry Gibbon: Hi, Bipin, and thanks for that question. So the check payment itself falls outside of this …
Bipin: I know, but this will be the same system because it will be against your database it will be checking against, won't it?
Henry Gibbon: So no. So on the checks, the checks being a bit more of an antiquated process don't have any checks into the – into the – into the open banking infrastructure. That's just whether we have an indemnity for those individual names. Sorry. I'm interrupting you.
Bipin: Yes, yes, yes. I appreciate name, but for even this payment, for CHAPS payment, will it be checking in the same sort of records you've got?
Katherine Moore: Yes. So we check – we're going to – we'll check multiple sources within our system. So I said – I said the registered name and the trading as name. Now, we also have internal account names that would have been set up either when you opened your account or subsequent to that if you had any changes.
What I would suggest if you're concerned that the name that you are giving out to your beneficiary is not – or your payer is not what we hold in our system, then what we can do is provide to you what exactly that we hold in our system to make sure that the two tally up because otherwise, you're going to see a surge in servicing queries when this goes live. So I suggest that we probably do that …
Bipin: Yes. That's exactly what I need. Do I go through my relationship manager to get that, Henry?
Henry Gibbon: Yes. You can come to me, Bipin, and we can – we can help you with that.
Bipin: Thank you. That'll help. That's …
Henry Gibbon: OK?
Bipin: Thank you. Yes.
Henry Gibbon: Thank you very much.
Katherine Moore: Thank you.
Henry Gibbon: Operator, any other questions please?
Operator: Your next question comes from the line of Lindsey Burne. Please ask your question.
Lindsey Burne: Oh, hi, Henry. It's Lindsey.
Henry Gibbon: Hi, Lindsey.
Lindsey Burne: Hi. I've got two questions please, if that's OK.
Henry Gibbon: Sure.
Lindsey Burne: So the first one is sometimes – so I appreciate this only applies to payments in sterling accounts. Sometimes we'll use IBANs for the account number. Will that check still apply?
Henry Gibbon: I'm going to hand you over to Katherine on that one because I'm not sure actually.
Katherine Moore: So are these payments done via Barclays.net, Lindsey?
Lindsey Burne: Yes. So they'll be CHAPS – they'll be payments keyed directly to Barclays.net based on the criteria that you've set and what we would – we would normally know as a CHAPS payment in value.
Katherine Moore: OK. So if – it depends what screen your keying them into. So if you're – if you're keying those into the – there's a couple of different ways that you can do a CHAPS payment I guess in Barclays.net.
So if you're keying it into the CHAPS screen, it does give you the opportunity to put an IBAN in there. That will – what that will do in the background is actually – the IBAN is just the International Bank Account Number.
Lindsey Burne: Yes.
Katherine Moore: That's what it's short for and account number in it, as you know.
Lindsey Burne: Yes.
Katherine Moore: So what it'll do is pull that information out and do the CoP check based on that. So you don't – you won't need to change the information that you actually input.
Lindsey Burne: OK.
Katherine Moore: We can still do that for you in the background, so that's fine. If you – if you don't key those payments via the CHAPS screen and you do that via another screen in .net, we might need to just have a – have a conversation about that to make sure that those are covered if those are CHAPS payments going through, but if they go through the CHAPS screen, then they will be covered by Confirmation of Payee.
Lindsey Burne: OK. And then the other question I just had was a point that you made at the start around the before outcomes that you'd be prevented backward. So a match, a close match, no match or unavailable because I think you gave the examples because I feel the bank wouldn't be participating.
Where would the liability stand then? Would that just be normal business process if the beneficiary bank weren't participating in the scheme at present and you were presented with an unavailable match, if you like, or an unavailable response?
Katherine Moore: Yes. I mean, if it's unavailable, it would be – the liability would sit exactly as it is right now. It would be as if there was – there was no CoP check in place. I mean, really the CoP check is to give you assurances around who you're paying and to flag any potential issues with that name you've put in.
Where it's unavailable, there's lots of different reasons why it could be unavailable. So that wouldn't – that wouldn't come into the change in liability or anything like that. That would be as if there wasn't a CoP check in place so that's as-is right now.
Lindsey Burne: OK. Thank you.
Henry Gibbon: Thanks, Lindsey. Any further questions please, operator?
Operator: Once again, for questions, please press "star," "1" on your telephone keypad.
Henry Gibbon: Just give everyone a few seconds to do that, but just really to wrap up the call, thanks, everybody, very much for your time. As we've said sort of on multiple times, please do get in touch if you've got further queries. We're here to help with them and we'll pick them – we'll pick them up individually. Operator, thank you very much. Was there – did any other questions come through or should we close?
Operator: Yes, sir. We do have one more question.
Henry Gibbon: Fab.
Operator: And comes from the line of Stephanie Moxon. Please ask your question.
Henry Gibbon: Hi, Stephanie.
Operator: Hi …
Henry Gibbon: Are you there?
Operator: Stephanie, your line is now open.
Henry Gibbon: Looks like we might have lost Stephanie, but …
Stephanie Moxon: Sorry. Sorry.
Henry Gibbon: Oh, no, we can hear you. Fab.
Stephanie Moxon: I'm sorry. Sorry. I forgot I'd put myself on mute.
Henry Gibbon: No worries.
Stephanie Moxon: The Barclays portal that you've got there and then you've got the Barclays.net. What's the BMAP? Sorry.
Henry Gibbon: So I'll take that one. BMAP is our virtual account platform, so the ability to open multiple bank accounts. So to be honest, you would know if you had it, Stephanie, because it's …
Stephanie Moxon: Right.
Henry Gibbon: … rather a large amount of instruction that you'd set up to it. I don't actually believe any insurance clients do have it because it's not quite fit for purpose for them, but it's just on our general communications. Is that all right?
Stephanie Moxon: No, that's absolutely fine. Thank you.
Henry Gibbon: Fab. Any more questions on the line, operator?
Operator: No more questions, sir. Please continue.
Henry Gibbon: OK. Well, that's all for today. Thank you very much for your time, everyone, and as said, please do get in touch if you have any further questions. OK. Thank you and bye-bye.
Operator: That does conclude our conference for today. Thank you for participating. You may all disconnect.