ATCS 5.5 Step 3: Assessing reasonable additional provision

1. (1)

   ATCS 5.5.1R does not require the cash access assessment to identify the cash access facilities from which the additional cash access services are to be provided. The rules are accordingly channel-neutral in this respect, subject to the matters set out in ATCS 5.5.2R.

2. (2)

   The definition of assisted cash access service is channel-neutral in terms of how the assistance should be provided, so this could involve the physical presence of the appropriately trained individual or the provision of assistance by them via, for example, video link. The exact nature of any assistance needed in the circumstances must be identified in accordance with ATCS 5.5.2R(4).

3. (3)

   In delivering any cash access services, designated firms should be mindful of the duty to make reasonable adjustments for people with disabilities under the Equality Act 2010 in Great Britain and the need to comply with equivalent legislation in Northern Ireland. While cash access assessments are not expected to make judgments about compliance with such legislation, they should explain their findings on the impact on those who have particular difficulties with accessing cash access services due to disabilities. Those findings may assist designated firms in ensuring they meet any obligations under the relevant legislation.

4. (4)

   ATCS 5.2.5R excludes consideration of the availability of certain cash access services at step 3.

1. (1)

   The question of reasonableness in terms of the identification required under ATCS 5.5.1R and ATCS 5.5.2R is likely to depend on matters specific to the local area, which could include:

   1. (a)

      whether any cash access services have been provided in the local area in the past and, if so, their nature and extent;

   2. (b)

      the reasons, if known, for any relevant closures in the local area in the past;

   3. (c)

      the likely cost of additional provision of a particular service;

   4. (d)

      whether any additional cash access services which would wholly or partly address the significant impacts of the local deficiency identified by the cash access assessment are due to be provided by anyone independently of the assessment and any other cash access assessment undertaken as a result of the same trigger event, and the timeline for such additional provision;

   5. (e)

      in terms of the identification of the location of any cash access facilities under ATCS 5.5.2R(5), proximity to areas where cash is most likely to be used, such as retail areas; and

   6. (f)

      in terms of the identification of capacity needs and opening hours of any cash access facilities under ATCS 5.5.2R(6), any predictable changes in demand for cash access services.

2. (2)

   The list of matters in (1) is not exhaustive.

Given the number of different solutions available, it should only be concluded at step 3 in very exceptional cases that it is not reasonable for any additional cash access services to be provided.

It may be appropriate in some cases for additional cash access services to be provided for a trial period. In such cases, ATCS 6.1.2R(10), ATCS 6.1.5R, ATCS 6.1.6G, and ATCS 8.1.12R to ATCS 8.1.15G apply.