This requires banks and building societies to specify, for each Personal Current Account (PCA) product that they offer, the maximum Relevant Charges that could accrue in relation to that PCA in any month, as a result of exceeding or attempting to exceed a Pre-agreed credit limit on the PCA. This is known as the Monthly Maximum Charge (MMC).

Monzo Bank breached Article 29.1 of the Order, which requires the MMC to be disclosed each time information relating to the Relevant Charges is disclosed, and no less prominently than the presentation of that information.

Monzo Bank failed to disclose the MMC next to the Relevant Charges in its Fee Information document.

The breach occurred between 25 October 2018 and 19 November 2021.

The CMA is also concerned that Monzo Bank’s Internal Audit Report failed to identify that Monzo Bank’s Fee Information document was non-compliant with the Order.

The CMA revealed that Monzo had taken action to end the breach and prevent a recurrence having updated its fee information document to be compliant with the order since November 2021.

Monzo has also implemented a new procedure whereby its Terms and Conditions are subject to an internal annual audit legal review to confirm compliance with the order.  Furthermore, the bank has strengthened its product governance to improve awareness of all regulatory obligations.

The CMA also noted that Monzo has expanded its risk management and compliance teams to provide greater support to the business in these areas and ensured that the terms and conditions including the fee information document are changed in line with Monzo Bank’s full governance process.

The watchdog said that in light of the actions taken by Monzo, it does not consider it appropriate to take further formal enforcement action in relation to this breach at present. The CMA revealed that it will monitor Monzo Bank’s future compliance closely.