On 14 September 2020, the FCA published Finalised Guidance 20/3: Branch and ATM closures or conversions (FG20/3). FG20/3 applies to regulated firms that operate (or have agents operate) branches, or ATMs (cash machine or cashpoint), and who are subject to Principles 6, 7 and 11 of the Principles for Businesses. It applies when such a firm proposes or takes a decision to close such sites, or to convert a free-to-use ATM to pay-to-use, with some exceptions.

In FG20/3 the FCA sets out its expectation that firms should carefully consider the impact of a planned closure of a branch or ATM, or conversion of a free-to-use ATM to pay-to-use, on their customers’ everyday banking and cash needs, and other relevant branch services. Where firms do close or convert any of these sites, the guidance sets out the FCA’s expectations around alternative access arrangements.

The FCA also makes clear in FG20/3 that it expects firms to keep it informed, via their usual supervisory contact, of plans for closures or conversions throughout the process, to enable the regulator to monitor whether customers are being treated fairly.

FG20/3 applies from 21 September 2020.

In FG20/3, a ‘site closure’ means the permanent closure of a branch or all ATMs operated by a firm at a particular location, or a mobile bank facility no longer operating. A ‘conversion’ means the conversion of a free-to-use ATM to a pay-to-use ATM. The guidance applies to decisions to make a closure or conversion taken by firms after the date it takes effect. Where a decision has been made before the guidance takes effect, the FCA expects firms to take account of it to the extent it is reasonable to do so. For example, if a firm decided before the guidance was issued to close branches in more than 12 weeks’ time, it may still be reasonable for it to provide 12 weeks’ notice to customers.