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Liability to refund the customer/fraud victim is covered by existing Payment Services Regulations.  This means the bank in most cases is required to refund the customer/victim in the first instance. 

UK Open Banking rules indicate fraud liability should sit with ‘the party that hasn't properly authenticated the customer’.  So the bank can seek recompense from the fintech/TPP, but the rules and mechanism to achieve this are unclear at best. 

There is a dispute management mechanism through the OBIE and the Financial Ombudsman, but again in reality the bank would only have basis for dispute based on information provided by the fintech/TPP.

£400m in fraud savings is a huge number and helps to show the value and the benefit of voice biometrics.  Consumers seem increasingly comfortable using biometrics to access banking services and PSD2 SCA changes will no-doubt accelerate this further.  It's also interesting to hear that HSBC have seen a big increase in fraud attempts through the telephone channel in 2019, maybe this is a response to PSD2 changes and migration due to increased security measures online and in e-commerce. 

Voice biometrics also seems to offer the flexibility to use across multiple channels, F2F, and via mobile App in addition to telephone channel.  So getting millions of customers registered may open up additional service options, though with the proliferation of additional customer authentication options it increases the need for banks to have a sophisticated decisioning platform combining risk-based authentication and fraud decisioning to minimise customer friction.