FCA Guidance Consultation: Branch and ATM Closure - Which? response

Summary:

• Which? welcomes the opportunity to respond to the FCA’s proposals on branch and ATM closures or conversions.
• Bank branches and ATMs are closing at an alarming rate. Which? research shows that consumers, particularly older consumers and those in rural areas, rely on the services that branches offer. While closures are a commercial decision, it is vital that communities and vulnerable consumers are not cut off from cash and access to essential banking services.
• The Access to Banking Standard is failing communities as banks rarely reverse a decision to close a branch. HSBC, Lloyds Banking Group, Santander, the Co-operativeBank, TSB and Virgin Money have never reversed a decision.
• Which recommends that the FCA:
  • Implements the final guidance as soon as possible to prevent a rush of closures before proposed legislation to protect access to cash is introduced and to help mitigate the impact of the coronavirus pandemic on the already fragile branch and ATM networks.
  • Clarifies how their role and the proposed guidance interacts with the existing regulation and industry agreements of ATMs and branches. The FCA should also set out how they will work with stakeholders to ensure that ATM closures not covered by the guidance are undertaken in a fair way.
  • Uses the full range of enforcement tools available to them in cases where firms have not treated customers fairly.
  • Also focuses on supervision to prevent harm, intervening to ensure that adequate banking services remain in place they find that alternative provisions are insufficient.
  • Conducts an assessment of the viability of alternative provisions firms could provide after a branch or ATM closure.
  • Should carefully consider the suitability of Post Office as a viable alternative in place of a branch or an ATM.
  • Sets out what impact they expect the proposed guidance to have and what outcomes they will measure to evaluate whether the guidance is effective.