PSR Call for views: First review of Specific Direction 12 (LINK) - Which? response

Free access to cash remains extremely important for many people, particularly those on lower incomes, older people, and people with physical or mental health difficulties

The PSR’s Specific Direction continues to serve an important purpose in maintaining free access to cash. It should therefore be retained.

There may be some overlap between the cash provisions contained in the Financial Services and Markets Bill and SD12, but the legislation has not yet received Royal Assent and remains subject to change, while the FCA will also need to consult on how it proposes to interpret its new responsibilities. Most importantly, the Bill does not set out whether the proposed framework will guarantee minimum levels of free access to cash withdrawals and deposits.

Specific Direction 12 should remain in place until legislation to protect access to cash has been passed, the associated HM Treasury Policy Statement has been published, a regulatory framework ensuring appropriate oversight of access to cash issues has been introduced by the FCA (including its approach to free-to-use facilities such as ATMs), and a thorough assessment can be made of the impact and effectiveness of the new arrangements.