ATCS 2.3 Guidance relating to both types of closure

1The Glossary definition of relevant closure excludes events relating to a cashback facility or a cash delivery or collection service. A retail store where cash access services are provided by or under arrangements with the Post Office would not be regarded as a cashback facility.

The definition of relevant closure also excludes events insofar as they relate to cash access services which are not provided free of charge in relation to relevant personal current accounts. The effect is that:

1. (a)

   if cash access services provided at a cash access facility in relation to relevant personal current accounts are subject to a charge, and other cash access services in relation to relevant personal current accounts are provided free of charge or cash access services are also provided for businesses, the facility is not excluded; and

2. (b)

   if the only cash access services provided at a cash access facility relate to relevant personal current accounts and these services are all subject to a charge, the facility is excluded.

By way of example, the full closure of an automatic teller machine which charges for use would be a relevant closure if businesses can use it to withdraw cash.

ATCS 2.1.1R applies to cash access facilities of designated firms so it does not apply where, for example, the relevant closure is a full closure of a Post Office branch. This would fall within scope of ATCS 2.2.1R.

1A relevant closure includes a reduction in cash access services provided at a cash access facility, or a change in the nature of such provision, where the reduction or change is material. Materiality relates to the nature and extent of the reduction or change rather than involving an assessment at this stage of the impact on users of cash access services. For example, a nominal reduction in opening hours from 40 to 39 hours a week should not be treated as material.

Reductions or changes which should be regarded as material include:

1. (a)

   conversion of a free-to-use cash access service provided in relation to relevant personal current accounts to pay-to-use;

2. (b)

   removal of a counter or a significant reduction in opening hours;

3. (c)

   removal of the functionality for a reasonable mix of both coins and banknotes to be deposited or withdrawn;

4. (d)

   loss of or a significant reduction in an assisted cash access service; or

5. (e)

   withdrawal of a cash access service by a designated firm from a cash access facility through which it provides cash access services alongside other providers.

The list in (2) is not exhaustive.