The cash access assessment must be a reasonable assessment of the following:
step 1 – whether there is, or would be after a relevant closure, a local deficiency in provision of cash access services;
step 2 – if there is or would be such a deficiency, whether its impacts are or would be significant; and
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.
ATCS 5.3 to ATCS 5.5 contain detailed rules and guidance about the steps referred to in ATCS 5.2.1R.
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:
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
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:
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;
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;
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);
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
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.
ATCS 5.2.6R applies where rules and guidance in ATCS 5 are only relevant to cash access facilities which users of cash access services can visit, as opposed to, for example, a service which delivers cash to or collects cash from people’s homes.
In considering the availability of cash access services (as described in ATCS 5.2.4R(1) or ATCS 5.2.4R(2)), significant weight should be given to whether it can be demonstrated that cash access services provided at any cash access facility under consideration are provided with consistency during stated opening hours. See ATCS 8.1.6G for guidance in this context on cashback without a purchase.
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.
The designated person undertaking a cash access assessment must consider:
the types of information to use;
the content and level of detail of the information to use; and
whether and to what extent to obtain information from other sources.
Other sources from whom designated persons should consider obtaining relevant information include those that might help them to understand the demographic characteristics of the local area and the need for cash access services, as well the range of local matters that could impact this understanding such as transportation issues and planned housing developments. Examples of such sources could be:
local community groups;
local authority departments with responsibility for planning or for cohorts who may be particularly reliant on cash;
consumer groups;
the local office of persons listed in ATCS 3.2.1R(1);
groups or charities who help local cash users in vulnerable circumstances, such as local carers or mental health support groups or charities;
staff of designated firms; and
customers of designated firms (for example, through surveys).
The list of possible sources of information in (1) is not exhaustive.
