OBIE Chair commits to focus on workplace culture and improving corporate governance as immediate priorities


The newly appointed Chair of the Open Banking Implementation Entity (OBIE), Charlotte Crosswell pledged to acknowledge and learn from past mistakes to help open banking deliver on its mission as a public good by increasing competition and innovation and ultimately securing better outcomes for consumers and SMEs.

Charlotte Crosswell, Chair of the Open Banking Implementation Entity (OBIE)

Crosswell’s appointment comes after Imran Gulamhuseinwala resigned as OBIE Trustee and Chair following an independent investigation commissioned by the CMA (Competition and Markets Authority). Having considered the findings, the CMA last week published the report and set out the next steps to be taken.

Crosswell is charged with leading the planned transition to the future arrangements for open banking. Further priority hires will be the appointment of new Non-Executive Directors to the OBIE board to give appropriate independent scrutiny and oversight. The OBIE will work with the CMA and CMA9 to put the appropriate measures in place surrounding their appointments.

Charlotte Crosswell, OBIE’s Chair said: “Firstly I want to thank everyone who contributed to the review and acknowledge that those must have been difficult conversations to have. On behalf of OBIE, I want to take this opportunity to sincerely apologise to anyone who feels negatively affected or let down by the issues identified in Ms White’s report. In my new role at OBIE, I am committed to turning these learnings into effective and meaningful change both in terms of stronger governance as well as a continued focus on employee values and wellbeing.

 As part of a transition from a contractor to employee model, the OBIE has already made some progress on overhauling its employment infrastructure; the implementation of employment policies and procedures, the establishment of a dedicated HR function and a Culture and Values Working Group. The sentiment conveyed to me by an overwhelming number of existing staff is that the OBIE of today is unrecognisable from the negative culture previously described. However, the observations and findings of Ms White mean that there is absolutely no scope for complacency. Under my leadership we will commit to working to ensure that there is no repetition of any failings and inadequacies, historical or otherwise. Simply put, what happened was unacceptable and can’t happen again. We intend to act swiftly and decisively. Non-Executive Directors will be appointed to the OBIE board as a priority, to provide appropriate independent scrutiny and oversight.

Ms Crosswell went on to explain that since joining the OBIE initially as Transition Lead earlier this year she has been hugely impressed with the professionalism, dedication and innovation of the OBIE team and the wider support of the open banking ecosystem.

 “OBIE personnel past and present have helped to establish the UK as a recognised world leader in open banking. 4 million consumers and small businesses in the UK now use services powered by open banking technology. Everyone that works for the OBIE believes in the mission and that has been powerful and inspiring to witness.

 With the CMA soon to announce next steps towards the model for the future governance of open banking we are at a key inflection point, and I hope this will give us greater clarity and enable us to implement fully the kind of leadership, governance and structure, alongside a supportive, diverse and inclusive culture, that is vital for a progressive and permanent organisation.” 

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Notes to Editors:

  1. Open banking enables consumers and SMEs to share their bank and credit card transaction data securely with trusted third parties who are then able to provide them with applications and services which save them time and money.
  1. Charlotte Crosswell OBE was appointed as Transition Lead at Open Banking Ltd earlier this year. Charlotte has been involved in capital markets and technology throughout her career – as CEO, Board 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 Independent Strategic Review into UK Fintech that was published in February 2021. Charlotte also represents UK Fintech on the Department for International Trade’s Financial Services Trade Advisory Group.
  1. You can view Alison White’s report on the CMA’s website.
  1. The CMA announced the following steps that are being taken following the investigation:
  • Imran Gulamhuseinwala has tendered his resignation as Open Banking Implementation Trustee and Chair.
  • Charlotte Crosswell has been nominated as the replacement Implementation Trustee and Chair, to lead the planned transition to the future arrangements for Open Banking.
  • New Non-Executive Directors will be appointed to the OBIE board as a priority, to provide appropriate independent scrutiny and oversight.
  • Kirstin Baker, an independent Non-Executive Director of the CMA, has been appointed to lead a review to identify the lessons for the CMA in its approach to designing, implementing and monitoring remedies in its market investigations. The findings of this review will be published.
  1. The open banking implementation phase will complete in 2022. The findings of the Alison White investigation will also be taken into consideration in relation to the future governance arrangements for OBIE, alongside responses received to the CMA consultation earlier this year. A further update on this will be published as a priority.

About Us

The Open Banking Implementation Entity (OBIE) is the entity set up by the CMA in 2016 to deliver open banking. Its trading name is Open Banking Limited.

The OBIE is governed by the CMA and funded by the CMA9 (Allied Irish Bank, Bank of Ireland, Barclays, Danske, HSBC, Lloyds Banking Group, Nationwide, Natwest Group and Santander). Its works with the CMA 9, as well as challenger banks, financial technology companies, third party providers and consumer groups.

The OBIE’s role is to:

  • Enforce the obligations on the CMA9 under the CMA Order
  • Design the specifications for the Application Programme Interfaces (APIs) that banks and building societies use to securely provide open banking
  • Support regulated third party providers and banks and building societies to use the OBIE’s open banking standards
  • Create security and messaging standards
  • Manage the OBIE’s open banking Directory which allows regulated participants like banks, building societies and third-party providers to enrol in open banking
  • Produce guidelines for participants in the open banking ecosystem
  • Set out the process for managing disputes and complaints.