“Rolling out confirmation-of-payee is not as simple as flicking a switch. Broadly speaking there are two main phases involved. First, we need to build a solution and ensure it works technically with our current payments system and complies with banks’ privacy and confidentiality obligations. Once we have that, banks then individually need to implement changes to their own systems to make the solution available to their customers, and that includes designing, building, and rolling out updates to their apps and online banking platforms.“