The CMA has written a letter to Starling regarding its breach of the Retail Banking Market Investigation Order (Order) in relation to the Service Quality Indicator (SQI) remedy.
Part 3 of the Order requires Business Current Account (BCA) providers with 20,000 or more SME customers in Great Britain to complete a survey in order to assess how likely the customers are to recommend that provider. Relevant providers must supply the market research company conducting the independent SQI survey with a list of SMEs holding BCAs, who will be invited to take part. Results showing each bank’s score and its BCA provider ranking are then published.
Starling breached the Part 3 requirement by failing to provide its market research company with data on all the required BCA holders. Specifically, the data did not include holders of the Starling Sole Trader Account (although it did contain businesses, which could include sole traders operating through a limited company, who held Starling’s other BCA). The cause of the breach was Starling’s misunderstanding of the requirements of Part 3 of the Order.
The CMA noted that Starling’s breach was self-reported, and that it had taken proactive steps to remedy the breach and prevent recurrence, including:
- Revising its template submission to the market research company to include sole traders.
- Reviewing data requirements for the SQI surveys more widely to ensure there are no further omissions.
- Plans to:
- review existing processes and controls relating to requirements of the Order;
- provide further training and guidance on all relevant parts of the Order; and
- ask its second-line Compliance Monitoring team to review compliance with the Order in Q4 2024.
- Commissioning a small survey of Starling Sole Trader Account customers on discovering that they had been missed from the mandated SQI survey. This survey is similar in terms of the questions asked of SQI survey respondents, but doesn’t mention the CMA.
- Agreeing to pay for a survey ‘boost’ which will involve additional Starling Sole Trader Account customers being surveyed in advance of the next publication of survey results in February 2025.
The CMA is currently of the view that Starling’s results were unlikely to have been an overestimate. Given this and the action being taken by Starling, it does not consider it appropriate to take further formal enforcement action, but will monitor the results of the survey boost and consider whether further action is necessary.