ATCS 5.2 Overview

The cash access assessment must be a reasonable assessment of the following:

1. (1)

   step 1 – whether there is, or would be after a relevant closure, a local deficiency in provision of cash access services;

2. (2)

   step 2 – if there is or would be such a deficiency, whether its impacts are or would be significant; and

3. (3)

   step 3 – if there is or would be such a deficiency with significant impacts, what additional cash access services it would be reasonable to provide.

The extent and scope of the cash access assessment and the work the designated person must do to undertake it are dependent upon, and proportionate to, the circumstances of each case.

ATCS 5.2.5R contains restrictions on what can be taken into account in a cash access assessment when considering:

1. (1)

   what cash access services are or will be available following a relevant closure, where the requirement for the cash access assessment was triggered under ATCS 4.1.1R(1) (concerning closures of designated firms) or ATCS 4.1.1R(2) (concerning closures of persons other than designated firms); and

2. (2)

   what cash access services are available, where the requirement for the cash access assessment was triggered under ATCS 4.1.1R(3) (concerning cash access requests).

The restrictions referred to in ATCS 5.2.4R are as follows:

1. (1)

   no account is to be taken of the availability of cash access services at a cash access facility in respect of which a full closure is expected;

2. (2)

   account may only be taken of the availability of cash access services at a cash access facility where there is expected to be a material reduction in provision of cash access services, or a material change in the nature of such provision, on the basis of the cash access services the facility will provide after such reduction or change has taken place;

3. (3)

   no account is to be taken of the availability of cash withdrawal services of the type falling within paragraph 2(e) of Schedule 1 to the Payment Services Regulations (cashback with a purchase);

4. (4)

   no account is to be taken of the availability of any cash access service in relation to relevant personal current accounts if it is subject to a charge; and

5. (5)

   where more than one cash access assessment is undertaken as a result of the same trigger event under ATCS 4.1.1R, no account is to be taken in any of those cash access assessments of the availability of additional cash access services that might be provided as a consequence of any of the other cash access assessments.

Where any rules or guidance in ATCS 5 refer to distance to, proximity of, or travel to a cash access facility, or where the context otherwise so requires, a cash access facility does not include a cash delivery or collection service.

1. (1)

   A cash access assessment must be based on sufficient information of which the designated person undertaking it is aware at the time it is undertaken, and obtained where appropriate from other sources, to enable it to be a reasonable assessment.

2. (2)

   The designated person undertaking a cash access assessment must consider:

   1. (a)

      the types of information to use;

   2. (b)

      the content and level of detail of the information to use; and

   3. (c)

      whether and to what extent to obtain information from other sources.