Update on Open Banking | Mirage News


OBIE is an independent organization which, following an order from the Competition and Markets Authority (CMA), was created in 2017 by the 9 largest retail banks in Great Britain and Northern Ireland to implement Open Banking.

Open Banking enables consumers and SMEs to securely share their banking and credit card transaction data with trusted third parties who are then able to provide them with applications and services that save them time and money. ‘money. The UK has been a world leader in this area and it is estimated that half of UK small businesses and over 4 million consumers now use services based on open banking technology.

In September 2020, Alison White (a non-executive with corporate governance experience and no prior involvement with relevant organizations) was appointed to conduct an independent investigation, with the support of the Mishcon de Reya law firm, continued upon receipt of a complaint. a number of claims relating to OBIE; to the administrator of the implementation of Open Banking, Imran Gulamhuseinwala (the administrator); and some current and former senior executives of the OBIE.

The survey examined the issues raised under the following five themes: corporate governance; late delivery of accounts; conflict management; questions of supply, optimization of resources and human resources. The findings of the independent investigation were communicated to the AMC in August 2021.

The investigation examined serious allegations of bullying, harassment, discrimination and victimization. He found that the inaction and failures of the OBIE leadership allowed a culture of intimidation and intimidation to prevail. Furthermore, he found that the organization had not properly managed conflicts of interest and although he found no evidence that this had been exploited for private gain, there was an unacceptable risk that it did.

The investigation concluded that the trustee failed to ensure that the OBIE was properly managed in accordance with the 2017 Retail Banking Market Investigation Order (the Order).

The investigation also found that a lack of proper corporate governance had directly contributed to what had happened at OBIE. He noted that the ordinance gave very few details on the governance arrangements of the OBIE; that too much power was vested in the trustee personally with too few checks and balances; that there were deficiencies in the risk management and internal control system and in the management of culture and values ​​and the failure of effective workforce engagement, including when complaints have been filed; and that no steps were taken to improve governance as the Open Banking project expanded in time and scope.

The investigation therefore also concluded that the CMA, and the nine retail banks that contributed to the creation of the OBIE, must accept their share of responsibility for not putting in place strengthened governance mechanisms from the start, due to the lack of attention to governance issues throughout the program and not to improve governance when it became evident that the project was getting more complex and much longer than initially expected.

The CMA is announcing today the following actions taken as a result of the investigation:

  • Imran Gulamhuseinwala handed in his resignation as administrator and chairman of the implementation of Open Banking

  • Charlotte Crosswell has been appointed as Alternate Director and Implementation Chair, to lead the planned transition to future arrangements for Open Banking

  • New non-executive directors will be appointed on a priority basis to the board of directors of the OBIE, in order to provide appropriate independent review and oversight.

  • Kirstin Baker, independent non-executive director of the CMA, has been appointed to lead a review to identify lessons for the CMA in its approach to designing, implementing and monitoring corrective actions in its market investigations. The findings of this review will be published

  • The findings of Alison White’s investigation will be considered as part of future Open Banking governance arrangements, along with responses received to the CMA consultation earlier this year. A new update on this subject will be published as a priority

CMA President Jonathan Scott said:

I would like to thank Alison White for her report. The investigation identified significant deficiencies which require a rapid and substantial response. He found that serious allegations – including bullying, harassment, discrimination and victimization – had not been properly investigated by the OBIE and concluded that this reflected lapses in the law. both in the management and governance of the OBIE. This is simply unacceptable and we agree with Alison White that everyone involved must accept their share of responsibility and act on the lessons learned.

It is clear that a change is needed. I have accepted the resignation of the Implementation Administrator, Imran Gulamhuseinwala, and I am pleased to announce today the appointment of Charlotte Crosswell as the Implementation Administrator and Chair of the ‘OBIE. Her authority and expertise make her well placed to take on the leadership of the OBIE.

The AMC is responsible for drawing lessons from the weaknesses identified in the governance of the OBIE. I am therefore announcing today a review of the lessons to be drawn from our approach to designing, implementing and monitoring remedies in market surveys.

I would like to thank the complainants who raised these issues for doing so, because without them these serious issues may not have been resolved. The report raises questions about the claimants’ right to compensation and I would expect these issues to be considered carefully and with an open mind by the new OBIE leadership.

Open Banking is a pioneering intervention helping millions of people and small businesses to save time and money. The UK is recognized as an international leader in this field. All those who have contributed to its realization in recent years, including the trustee and all those currently working at OBIE, have played an important role in this achievement.

Charlotte Crosswell said:

Since joining OBIE in my initial role as Transition Leader earlier this year, I have already been impressed by the professionalism, dedication and innovation of the open banking team and believe that the organization is in a strong position to successfully adopt open banking. Given my experience as an industry advisor on FinTech and Innovation, I am delighted to bring my experience to the role of OBIE’s Trustee. The success of open banking, and what the OBIE team has already achieved with industry and policy makers, has played a vital role for consumers and SMEs across the UK. We must seek to capitalize on this by providing openness and competition in financial services and be ambitious in our journey towards open finance and smart data.

I look forward to the announcement of the AMC consultation on the future governance of OBIE and hope this will give us more clarity and allow us to fully implement the kind of leadership, governance, structure and culture which is important for a progressive and permanent organization.

Charlotte Crosswell OBE was appointed Transition Lead at Open Banking Ltd earlier this year. Charlotte has been involved in capital markets and technology throughout her career – as CEO, advisor and non-executive director. She is the former CEO of Innovate Finance, where she worked closely with Fintech entrepreneurs, government and regulators in addition to working on the UK Fintech Independent Strategic Review which was published in February 2021. Charlotte also represents UK Fintech in the Department of International Trade. Consultative Group on Trade in Financial Services.


  1. You can view Alison White’s report on the CMA website.

  2. Open Banking was part of a package of corrective measures adopted by an independent CMA investigative group in 2017 aimed at increasing rivalry in the provision of banking services. It requires the 9 largest banks and building societies in Great Britain and Northern Ireland (the “CMA9”) to make transaction data available through a common set of routines, protocols and tools. for creating software applications.

  3. To implement Open Banking, the CMA issued an ordinance which went into effect in February 2017 and asked the CMA9 to create and pay for an implementing entity – now known as Open Banking Implementation Entity (“OBIE”) – and appoint an implementation trustee. , approved by the AMC, to oversee the process.

  4. OBIE was created by CMA9 as a public limited company, Open Banking Limited (“OBL”).

  5. The CMA9s are: AIBG, Bank of Ireland, Barclays, Danske, HSBC, Lloyds Banking Group, Nationwide Building Society, NatWest Group and Santander.

  6. The implementation phase of Open Banking will end in 2022. In 2021, the CMA consulted on the arrangements to be put in place for its governance in the next phase of its development. The responses received to this consultation have been published and CMA is reviewing them.

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