ERODG8600 - Notes for claimants on the reimbursement scheme: how soon after being repaid should claimants start refunding consumers
We would normally expect you to have the scheme ready to implement when we receive your signed undertaking. You should start contacting consumers immediately rather than waiting for the 90-day period to begin before doing this.
You may request an extension to the 90-day period but must have valid reasons for wanting to do this. A late start to refunding the money without good cause would not be seen as a valid reason for extending the 90-day limit.