Posted by Michael McKee, Chris Whittaker and Erna Soljanin on 29 July 2020
Tagged to Brexit, Consultation, COVID-19, FCA

On 16 July 2020, the Financial Conduct Authority (FCA) published draft guidance setting out its expectations for banks, building societies and credit unions when considering closing branches or ATMs, or converting a free to use ATM to pay to use.


As cash use continues to decline due to the COVID-19 pandemic, the draft guidance sets out the FCA’s expectation that firms should carefully consider the impact of a planned closure or conversion on their customers’ everyday banking and cash access needs (this includes withdrawals, deposits and other cash-related branch services such as cheque cashing). This draft guidance also sets out the FCA’s expectation that firms put in place alternative access arrangements.

The proposal

In the draft guidance, the FCA expects firms to conduct analysis of the needs of customers currently using the sites, the impact of the proposals, and alternatives that could be put in place if they implement the proposals. The FCA expects to be provided with a clear summary of the results of this analysis.

Additionally, if a firm decides to progress the proposals, they would be expected to clearly communicate information about proposed closures or conversions to their customers no less than 12 weeks before a proposed closure or conversion would be implemented.

The guidance also sets out the FCA’s expectation that firms consider putting in place alternative access arrangements where it is reasonable to do so, for example:

  • sharing services with other providers;
  • providing mobile banking hubs or cash delivery services;
  • commissioning a free-to-use ATM;
  • supporting customers to use digital channels. 

Next steps

The FCA welcomes comments from stakeholders on the draft guidance by 5pm on Thursday 30 July.

The authors

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