RCMS contracting and functionality
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FAQs
Would it be possible to share in the chat which organisation will be performing the ID verification for contract signatory on the registration form
Red Flag Alert provides the ID verification service. Only publicly available data is checked, and no footprint is left on the individuals record. Biometric information is required as part of the process
I completed ID&V earlier this week - how long is it taking to receive the email about contracts?
Once you have passed ID&V, the contract will be sent via DocuSign to the person listed as your contract signatory in the registration form. This should happen within a maximum of 3 working days of completing ID&V.
Our organisation requires 2 signatories to sign documentation, how can we manage that?
Please provide one contract signatory when you complete registration. The contract is sent via DocuSign to that named contract signatory and includes “offline” instructions for those PSPs who need to have two signatories.
What thoughts have been given to the way the businesses question the customers around the fraud and their knowledge or no knowledge. Worried this could be a bad experience for the customer which contravenes Consumer Duty
We have released a Best Practice Guide. This has been developed in collaboration with the PSR and with industry. It contains guidance on how to deal with a range of claims scenarios and provides examples of “what good looks like” in dealing with consumers. It will be made available to all PSPs who have registered and passed ID&V. It will be sent out via DataSite.
Does the scheme include business to business faster payments or does it just focus on individual payments?
The PSR’s direction on APP Reimbursement under SD20 is focused on consumers, micro-enterprises and charities. For more information please refer to SD20 on PSR website: https://www.psr.org.uk/publications/legal-directions-and-decisions/app-scams-reimbursement-sd20-on-psps/
How comfortable are you that the industry will be ready for the launch date?
We are developing the RCMS system to ensure that PSPs can comply with their obligations under SD20 and we are confident that the system will be available for 7 October launch date. In addition, we are supporting PSPs in being able to register and contract for RCMS in time. However, it is the obligation of all in scope PSPs to ensure that they comply with the deadlines.
Is there a cost to registration etc.
There is no cost related to registration
Does the claims management system also manage disputes between sending and receiving PSP
The RCMS does not manage disputes. PSPs can register for RCMS Core or RCMS Core plus Claims. The Core system allows PSPs to submit their monthly claims data from 7 October as required under SD20. It includes the directory of all registered PSPs so that sending PSPs can identify the details of the receiving PSPs they need to contact to manage claims. The Core plus Claims option allows the sending and receiving PSPs to manage the full end to end claims management process within RCMS, provided both parties have signed the Core plus Claims contract.
What if the receiving PSP (not registered on RCMS) does not respond to our claim within the timeframe? Who shall sending PSP speak to to escalate?
We will be providing the PSR with regular updates on PSP registrations. If an in-scope PSP has not registered for APPR, or does not respond to a sending bank’s requests, they will be non-compliant to SD20. Sending PSPs should let the RCMS helpdesk know if a Receiving bank is not registered on the RCMS.
Has a date been agreed where all PSPs must migrate to Core+Claims?
The PSR has indicated its support for RCMS to be the single industry solution for APP claims management, but has not yet set a deadline by which in-scope PSPs will have to join the Core+Claims solution. The PSR intends to gather industry feedback later in 2024. Pay.UK is supporting PSPs to move to RCMS Core + Claims as quickly as they wish to and it will be available via web-hosted UI by October 7, and via API integration in January 2025
Will we be able to use RCMS to manage claims both for APP fraud via FPS and CHAPS?
CHAPS has yet to publish their rules. You will be able to see who is a CHAPS member in the Directory
What proportion of the industry do you expect to be RCMS users. I.e. what is the likelihood we'll be able to use full RCMS functionality for a claim?
Until more PSPs have registered and indicated whether they will join RCMS Core or Core plus Claims initially, it is difficult to estimate how many will be on the Claims system for day 1. However, we believe that it will be beneficial for PSPs to join RCMS Core+Claims on day one to allow them to take advantage of the functionality of the full system.
I am a little confused why this is being marketed as a system that stops manual processes yet you have just stated on numerous occasions manual processes will be needed due to the differing levels?
An APP fraud reimbursement claim involving a sending or receiving PSP that is not on RCMS Core plus Claims will require a manual process. It is for that reason that we believe it would be advantageous for the whole industry to be on RCMS Core+Claims as soon as practicable to eliminate the manual element of claims handling.
Why was the decision made not to have just 1 system? That is a consumer friendly process
The expectation is that RCMS Core+Claims will become the single target solution for APP reimbursement claims management. However, we appreciate that SD20 currently only mandates PSPs to join RCMS Core for reporting purposes. Our working assumption is that in-scope PSPs will be mandated to join Core+Claims in 2025, subject to the PSR’s planned consultation in Q4 2024. However, Pay.UK will have everything in place to ensure that all PSPs can move to RCMS Core + Claims ahead of any mandate.
Where can we find a template for a manual claim?
This will be available in the future training information released for firms that have registered and contracted. We caution that this is a simple template to create some standardisation of manual processes; however it is not a fully fledged process document. Only by all customers joining RCMS Core + Claims will operational effectiveness and simplification be achieved for industry.
If a PSP isn't using BPS - do they have to use Core+Claims? or can they choose to use offline processes and "Core" only? Is my understanding correct that it is not mandatory for the PSP to have the RCMS Core+Claims for now? As long as they have the access to the RCMS core?
SD20 only mandates PSPs to use the RCMS Core element for monthly data reporting. Until the mandate is extended to cover Core plus Claims, PSPs can join RCMS Core only and manage their claim processes outside the system. However, we believe it would be advantageous for the whole industry to be on RCMS Core plus Claims as soon as practicable to eliminate the manual element of claims handling.
As a sponsor bank, do we need to oversee the registration of our indirect clients? and report back to pay.uk on their eligibility under SD20 and RCMS registration?
We are encouraging Sponsor Banks to work with their Indirect PSP clients to ensure they register and claim their sort code and account number combinations. This will avoid the risk of non-compliance, as well as the possibility that the Sponsor receives claims routed to them that should have gone to their Indirect clients. We will be reporting to the PSR on registration against their list of in-scope PSPs. If you have not yet recieved an IAP support pack with information for you to share with your FPS indirect participant clients, please request one by emailing CBDO@wearepay.uk . Materials can be adjusted to match a PSPs corporate branding and tone of voice.
A couple of questions please: do you have a best guess how many participants will not be using by RCMS by 7 October and will there be a drop dead date by which all participants must be enabled? Secondly, do you know if there will be any changes to REP017 Reporting, i.e. I currently report APP fraud losses to the bank, will I need to report reimbursements sent to and received from other PSPs?
Registration is open and PSPs have until 20 August to register with us to remain compliant to SD20. We expect there will be many PSPs that will register in the final few days. We cannot comment on any possible changes to the regulations, as this is a matter for the Regulator.
For PSPs are not in the scope of provide service to consumers, only have corporate customers, will they also need to register in RCMS
It is up to PSPs to determine based on the wording of SD20 whether they are in scope or not. If they are, they have to register with us. If you believe you are out of scope of SD20, please send an email to CBDO@wearepay.uk with the subject line “out of scope” and we will provide you with next steps to formally inform us of that.
Will the directory also articulate what platform the PSPs are using - i.e. we can clearly see they are using SSI, RCSM or only phone call email etc.?
The directory search results will indicate whether a PSP is a full RCMS claims+ user or just using the RCMS Core functionality
In effect, on 7 October we will have PSPs on BPS/SSI / RCMS Core + Claims / email or maybe all three - operationally this is going to be a huge challenge. Or are we saying if Bank 1 is RCMS Core and Bank 2 is on SSI that they should default to a manual template?
Unless both sending and receiving banks are on RCMS Core plus Claims, the claim will have to be managed outside the RCMS system. Operational efficiency will be achieved by all PSPs join RCMS Core plus Claims as soon as practicable. Pay.UK is supporting PSPs to move to RCMS Core + Claims as quickly as they wish too and it will be available via web-hosted UI by October 7, and via API integration in January 2025
Will RCMS only be for APP fraud and not regular non fraud recall claims?
The RCMS is specifically for APP scam fraud on FPS,. It has been developed to faciliatate compliance with the FPS Reimbursement Rules, and therefore support the APP scams reimbursement policy to deliver the policy outcomes for industry and for victims of fraud. (with CHAPS as a potential later addition once that scheme has developed their rules and approach)
Considering the PII data being entered into RCMS, are we able to see outputs of security reviews and do we need to include any additional information sharing consents in our standard T&Cs? What about other information that I need for my due diligence - is this in the contract?
Please register as in scope, pass ID&V and then receive the contract. The contract is a suite of artefacts including security schedule, service outline, Ts and Cs and more. Within the Ts and Cs are the Data Terms which include clauses that create an “intra-participant data sharing agreement”. We proposed this to industry through our legal working group to design the contract. While not technically required, industry agreed that including this was efficient and avoids the need for potentially millions of individual data sharing agreements between the potential more than a thousand PSPs in scope. A Data Assessment for Controllers is also included in the contractual suite to enable PSPs to undertake their own DPIAs. Our BPC summary is being released by the end of August.
I need to sign a contract for the Reimbursement Claims Management System (RCMS) , but I am not currently a customer of Pay.UK. Who should I contact to do my supplier assessment and other due diligence of Pay.UK?
“Pay.UK is a Recognised Payment System Operator for the UK. The systems that we operate are used by such a large number of entities that we cannot complete lengthy questionnaires on an individual basis. This even applies when PSPs join our core payment systems. However, the contract artefacts includes a security schedule, service schedule, data terms and other relevant information, specific to the RCMS for PSPs to conduct their due diligence. PSPs must register as in scope of SD20 and pass ID&V to receive the contract for review, governance and signing.
Public information about Pay.UK applicable to any due diligence appraisal is also available. In particular, we are the owner and operator of the UK’s digital inter-bank retail payment infrastructure and are heavily regulated by multiple regulatory bodies, including the Bank of England, the Payment Services Regulator and His Majesty’s Treasury. A useful description of the Bank of England’s regulatory oversight of us is Financial market infrastructure supervision | Bank of England
We are required to provide attestations to ensure that our processes are at the required standards here – Self-Assessment-Against-The-Principles-For-Financial-Market-Infrastructures-–-2023.pdf (wearepay.uk)
You can also find our Annual Reports, detailing our Risk and Compliance posture, our Governance structure and our Financial statements, at this link: https://www.wearepay.uk/who-we-are/corporate-information/ – and our not-for-profit status.”
Can a receiving PSP reject a claim from a sending PSP?
The final decision remains with the sending PSP, but the receiving PSP will have the opportunity to discuss and provide their input to the sending PSP as part of the claim decision making process. Please refer to the FPS reimbursement rules for details.
Is there a RCMS system functional spec doc that can be shared? This would be useful to understand all the fields and variables within them.
Please register as in scope, pass ID&V and then activate the DataSite registration that we will send to you. DataSite holds a large amount of useful and detailed information to help PSPs prepare for October 7 2024, including detailed information on the functional specifications of RCMS. Please note near-final API specifications are also now available to allow PSPs to design and scope the build of their API integration ahead of the APIs going live in January 2025.
Fraudsters know about these regulations. Why is this a UI form and not an API ?
We are making it as easy as possible for PSPs to register and comply with SD20. Before being given access to the live system, they will have to have passed ID and Verification (ID&V) checks that ensures they are bona fide in-scope PSPs.
Are you not required to include any excess added to the claim?
Calculations surrounding excess have been built into the RCMS. Once registered and contracted for RCMS, PSPs will have access via DataSite to training material and helpful guides on using the system.
Are you not required to include any excess added to the claim?
Calculations surrounding excess have been built into the RCMS. Once registered and contracted for RCMS, PSPs will have access via DataSite to training material and helpful guides on using the system.
Why is an account number required?
The account number requested on the registration form is added to the directory, so that Receiving PSPs are able to search for the Sending PSP’s account details where the Reimbursable Contribution needs to be sent to. Even if you believe that your organisation is only ever going to be a receiving PSP, please complete this information anyway. The APP scam reimbursement policy is a world-first and we want to prepare for every eventuality to reduce potential future friction.
What is the policy on PCI data (specifically card number) being entered into the free text fields, or payment reference fields? Is PayUK PCI certified?
Once registered and contracted for RCMS, PSPs will have access via DataSite to training material and helpful guides on using the system.
What about sort codes which are used by multiple indirect PSP's? How will the system differentiate between these
Please see the FAQs on RCMS registration and Directory Set up available on our website. More detailed information is also available via DataSite to PSPs who have registered and passed ID&V.
Will there be more in depth training provided by Pay.UK on using the system with PSP's team members that will have to use this?
Once registered and contracted for RCMS, PSPs will have access via DataSite to training material and helpful guides on using the system.
Can Receiving PSP upload any evidence regarding the claim transaction if they think it is not SCAM?
There is a 2-way comments facility for any notes etc. There is currently no ability within the RCMS to attach files.
If a sending PSP is using BPS after October 7th, but the receiving firm is using RCMS, will the manual process need to be used to report? Similarly if a receiving firm is using BPS but the sending PSP is using RCMS – does the manual process need to be used?
Until all PSPs are using RCMS Core plus Claims to manage their claims processes, all PSPs have to use RCMS Core to report their claims data on a monthly basis (Reporting Standard A). Once all PSPs are on the full system, the reporting will be automated via the RCMS Core plus Claims.
Would multiple users from the same firm have access to update claim progress
Yes. System Administrators can grant users the relevant role access in the system.
Can we get an example template added to the documentation pages listing what sort of information a receiving PSP is likely to need to provide?
This is included in the Best Practice Guide, which is available on DataSite once you have registered and passed ID&V
There is a possibility of having multiple payments within a single claim. In that case do we have to fill in each payment separately as a Sending PSP? I couldn't tell by looking at the demo if any such functionality is available?
Information on this will be available via the training materials and a demo to show how multiple payments are added will be scheduled in due course. Each payment will need to be added one by one. Please register to receive the first release of training materials.
Where can we find the API docs?
Information on this will be available via Datasite once you have registered and passed ID&V.
Are the claims data only available for the firms included on the claim or there will be fraud information available for all the firms using the system?
Information is only visible between the parties involved in the claim.
If the receiving PSP can recover the funds, how does this work? Do they still only send back 50%?
Please consult the APP Reimbursement Rules available on the Pay.UK website and the RCMS training guide. The repartriation journey in the RCMS can be triggered mid-workflow or after the claim has been closed.
Is there any technical integration requirements to be able to participate?
Once registered and contracted for RCMS, PSPs will have access via DataSite to training material and helpful guides on using the system.
How will we know who is registered on the RCMS platform? if we load a case we will need responses ASAP
The directory search results will indicate whether a PSP is a full RCMS claims+ user or just using the core functionality in which case the claim will need to be manually worked through. Contact details of the Receiving PSP (if registered) will be available on the directory.
What will the escalation route look like to identify claims that are received by the sponsor bank but are for indirect clients? An exception process was discussed, but what that looks like, none of us are aware.
If the Indirect PSP has not registered and claimed the sort codes and account numbers for which it is responsible, claims for these accounts will be routed by default to the Sponsor. For this reason, we are encouraging Sponsors to work with their PSP clients to ensure they have registered and claimed the accounts that are theirs.
I would like to confirm if there are any tech integration requirements or access is solely upon successful registration to achieve full access?
Once registered and contracted for RCMS, PSPs will have access via DataSite to training material and helpful guides on using the system.
How easy is it to change the PSP details if they're incorrect?
Changes can be made after registration within the RCMS platform. Only major changes may require assistance from Pay.UK help desk otherwise the process is simple.
What is the link, if any, from RCMS to the details supplied in the Pay.UK Registration Form, i.e., we have more than one reimbursement account so if we add all 3 accounts to the Pay.UK Form does this link to RCMS or do we have to re-enter these in the RCMS solution?
It is only possible to supply one reimbursement account. If you use multiple accounts, due to multiple brands, we suggest you register separate brands as separate entities and have a separate instance of the RCMS for each of these.
We need to know what all the possible data field values for claims will be and when this information will be provided?
This is included in the data model published 30 July, along with V1 of the solution architecture
What happens if the sort code/account number isn't found, not registered or is deemed out of scope?
When users search the PSP directory, the directory will identify ‘no results’ have been found if the sort code is not found in the directory. The user will then need to raise a ticket through our help desk. If the sort code/account is found but has specifically been marked as out of scope by a PSP, then the ‘In scope?’ field will state ‘N’.
For claims raised where the Sending Firm is signed up to RCMS Core + Claims but the Receiving Firm is not signed up to RCMS Core + Claims, these will be managed outside of RCMS. Conscious that the Liability and Excess calculations can be complex. How will this be managed? Has the process to be followed to manage these 'manual' claims clearly been captured in the Practitioner's Guide?
Yes, the process to be used by PSPs where one of the PSPs is not using Core+Claims is detailed under the ‘Operational Readiness’ chapter within the Best Practice Guide. For clarity, if either PSP is not using RCMS Core+Claims, the claim will need to be managed offline and there is no functionality in the RCMS to be able to store responses for claims being managed offline. PSPs will need to do this on their internal systems. We will be providing templates to PSPs so that the offline communication between PSPs can be streamlined.
Demo showed adding one payment as part of claim - how are multiple payments over various dates added? One by one?
Information on this will be available via the training materials and a demo to show how multiple payments are added will be scheduled in due course. Each payment will need to be added one by one. Please register to receive the first release of training materials.
We are an indirect PSP and only offer Chaps - should we still register 20/08 ready for the chaps RCMS process?
If you do not send or receive via FPS at all, then please wait for the CHAPS rules to be published. However, all PSPs that send or receive payments via FPS should assess whether they are in scope of SD20. The RCMS does not yet cover CHAPs workflows, but these are intended to be implemented soon.
It looks like a max of 2000 characters for the scam text and no option for attachments - is that correct?
Yes, that is correct. There is no attachment facility due to security reasons. There are other free text fields as we progress the claim where further text can be sent between Sending and Receiving PSPs
On Advanced Reimbursement, why is the Max Cap and Excess not reflected?
Advanced reimbursement is a decision made by the sending PSP to refund their consumer before the Opportunity to Respond window closes for the receiving PSP. This means the Sending bank is reimbursing at risk and does not have to take into consideration excess or max cap.
Is there an option for email notification or is it just in system notification?
The RCMS offers notifications via the UI. Email notifications will be included in Release 2. Further detail on this will be available via the training materials. Please register to receive the first release of training materials.
How much of the "create new claim" process can be automated via API at launch?
Please see the API folder in the SharePoint folder marked “RCMS API specifications”. If you do not have access to SharePoint, but intend to implement via API, please email CBDO@wearepay.uk to tell us this so we can help you.
Are there any dashboards or MI to have effective oversight of all claims? Or just use the notifications tab?
Dashboards are being developed in Release 2 so users can have an aggregated view of the status of claims.
Is there a status to indicate that the opportunity to respond has ended?
Status notifications are under consideration for Release 2.
For banks not applying the excess, would the excess field need to be manually changed per payment?
Yes, the RCMS uses £100 excess by default. If the PSP user wishes to change this, they will be able to do so at claim level.
What is the claim reference to be provided in the Faster Payment sent by PSP? The Payment id in demo is longer than 18 characters which is the limit for Faster Payment reference.
The RCMS Payment ID will be 18 characters in Release 2 so that this can be added to the Faster Payment as a reference. More detail on this will be included in the training guide.
How does the Receiving PSP know what reference to use when returning money to the SF?
Each case created has a unique claim ID so PSPs can use this by default, but the directory provides an option for all PSPs to add a format for references if they want PSPs to use a specific reference format.
Regarding the search PSP contact details in the registry shown earlier, I noticed there is a column for "Reimbursement Account Reference". Does this mean that we expect PSPs to send with the same reference for every payment for a given PSP? I was hoping we would have a separate reference for each claim?
Sending PSPs can use this field to notify Receiving PSPs of the ‘format’ they wish Receiving PSPs to use when sending the reimbursable contribution.
I work in the FPS team and not the Fraud team so when this is live I don't need to see the details of individual claims but I will require access to the Dashboard & anything relating to compliance monitoring. What user role would I need access to - does Compliance User cover this requirement?
Correct, you will need the compliance user role. Please register by 20 August and once the RCMS contract has been signed, you will receive an email detailing the activation steps where the Service Administrator role can be set up. The Service Administrator can then set up the compliance user role, along with the other role types offered within the RCMS.
How will Indirect be covered here? How does one search Indirect PSPs?
All registered PSPs whether direct or indirect will be listed on the Directory. There is a reliance on all in scope PSPs registering, contracting, and activating themselves on the RCMS platform to populate the directory and validating the data effectively.
Good to see the Happy Path, would be good to see even a slightly more complex, multi beneficiary claim, to see how each individual claim is resolved.
“We will be hosting multiple demonstrations to showcase the capabilities of the RCMS Core+Claims including stop the clock, please register your interest using this link: www.wearepay.uk/rcms/.
Alternatively, screenshots of the RCMS will be included in the training materials. Please register to access the training materials.”
If managing offline, do we still have the stop the clock facility?
The Stop the clock function can still be used by the Sending PSP and managed offline. The FPS Reimbursement Rules are system agnostic, so they apply irrespective of a solution being used.
We do need stop the clock provisions covered. Are they timestamps within the system?
Yes, time stamps against stop the clock will be shown in ‘case history’ within the RCMS.
Is the SLA business hours or 24/7?
Please refer to the FPS Reimbursement Rules (on the Pay.UK website) for details on timings. Further details and examples are included in the Best Practice Guide which can be accessed once a PSP has registered.
Where/when is the secondary reference data provided or is this taken from existing FPS?
The EISCD contains within it secondary reference data which will be populated in the directory for registered PSPs. It is vital that all registered PSPs review and validate this data to ensure the PSP directory is kept updated and the data within it is valid.