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ATCS 5.4 Step 2: Assessing significance of impacts of local deficiency

Scope

ATCS 5.4.1R
  1. (1)

    Under ATCS 5.2.1R(2), an assessment must be made of the significance of the impacts of the local deficiency found in the provision of any of the specified cash access services that were assessed at step 1.

  2. (2)

    The assessment must consider the significance of the impacts on users of cash access services in general in the local area, not just customers of designated firms.

Factors

ATCS 5.4.2R

Subject to ATCS 5.4.1R, the factors a cash access assessment must have regard to when considering whether the impacts of a local deficiency are or would be significant include the following:

  1. (1)

    the number of persons in the local area likely to be affected, including:

    1. (a)

      the number of holders of relevant personal current accounts likely to be affected; and

    2. (b)

      the number of businesses which accept cash payments likely to be affected;

  2. (2)

    the likely impact on those in the local area likely to be affected, bearing in mind in particular:

    1. (a)

      their characteristics;

    2. (b)

      the impact on those in vulnerable circumstances;

    3. (c)

      the extent of the need for assisted cash access services;

    4. (d)

      the extent of the need for businesses which accept cash payments to use cash access services for both coins and banknotes;

    5. (e)

      the extent to which those likely to be affected may be outside the relevant distance when considering proximity to the nearest suitable cash access facilities with (between them) sufficient capacity to accommodate users of cash access services from the local area;

    6. (f)

      whether the additional travel time for those likely to be affected to get to the cash access facilities referred to in (e) over and above the travel time to their nearest retail areas is unreasonable;

    7. (g)

      whether those likely to be affected have to incur unreasonable costs in travelling to the cash access facilities referred to in (e) over and above the costs of travel to their nearest retail areas; and

    8. (h)

      the impact of any predictable fluctuations in demand for cash access services.

  3. (3)

    The list of factors in (1) and (2) is not exhaustive.

Guidance on factors

ATCS 5.4.3G
  1. (1)

    An assessment under ATCS 5.2.1R(2) is only required where it has been identified that there is or would be a local deficiency under ATCS 5.2.1R(1).

  2. (2)

    Subject to ATCS 5.4.1R, an assessment will need to be made of the degree to which users of cash access services in the local area (both people and businesses) are impacted.

  3. (3)

    ATCS 5.2.5R excludes consideration of the availability of certain cash access services at step 2.

  4. (4)

    The degree to which the nearest suitable cash access facilities with (between them) sufficient capacity may be outside the relevant distance is a factor. For example, if they are only just outside the relevant distance, that may indicate (leaving aside other factors) that the deficiency does not or would not have significant impacts. This factor should involve looking at issues such as:

    1. (a)

      the cash access services available at, the features of and the capacity of the nearest cash access facilities;

    2. (b)

      the distance to the nearest cash access facilities needed to reasonably meet the cumulative demand of users of cash access services from the local area; and

    3. (c)

      how far outside the relevant distance these cash access facilities might be – in particular, the furthest such facility.

  5. (5)

    Opening hours may be relevant to a cash access facility’s capacity. For example, the facility may be open for so few hours each week that this leads to unacceptable delays in service or queues.

  6. (6)

    The other factors set out in ATCS 5.4.2R also involve the question of degree. For example, where a substantial number of people in the local area are likely to be affected, that would suggest significant impacts.

  7. (7)

    In having regard to the number of businesses likely to be affected and the impacts on them, consideration should, in particular, be given to types of businesses that might be expected to be heavily dependent on cash.

  8. (8)

    The impact on those with characteristics of vulnerability is a factor. This should involve identifying when users of cash access services with characteristics of vulnerability, including those who may have particular difficulties with accessing cash access services due to disabilities, are or would be significantly impacted. Designated persons should refer to Finalised Guidance (FG) 21/1 (Guidance for firms on the fair treatment of vulnerable customers) for more information on our approach to characteristics of vulnerability.

  9. (9)

    An example of predictable fluctuations in demand for cash access services and their impact is where a local area receives a significant influx of visitors during the holiday season or on market days, which puts pressure on the cash access facilities in the area.

  10. (10)

    Regard should be had to any concerns raised by local community representatives and organisations about the adequacy of cash access facilities.