On 24 February 2022, the FCA published a new webpage setting out examples of good practice and areas for improvement in relation to branch and ATM closures or conversions. The examples, although not exhaustive, set out the good practice that the FCA has seen since issuing guidance in September 2020 outlining its expectations of how firms should conduct their closure processes.
The good practice and areas of improvement are set out under the following headings:
- Alternative services.
- Notification and communication to customers.
- Consumers in vulnerable circumstances.
- Senior management engagement.
For senior management engagement, the FCA expects accountable senior managers to engage to achieve good practice when overseeing branch closure initiatives. Examples of the good practice that the FCA has observed include:
- Firms proactively completing suitably detailed analysis for all branch closures.
- Senior managers asking for and receiving regular assurance via effective management information that branch closure plans were adhering to the FCA’s principles.
- Leadership taking decisions with consumer feedback in mind, such as requiring firms to consider alternative sites from those proposed or by pausing branch closure initiatives while collecting further data where needed.
Examples of practices where the FCA wants to see improvements:
- Senior managers not receiving regular management information pre-closure and lacking insight into branch closure proposals.
- Firms not completing a detailed analysis of the impact of a proposed closure or conversion on their customers for all branch closures.
- Firms not giving the FCA a clear summary of that analysis.
- Firms not engaging in lessons learnt exercises post closure.
- Branch closure plans not given sufficient scrutiny or importance at senior manager level.
