On 16 July 2020, the FCA published Guidance Consultation 20/2: Branch and ATM closures or conversions (GC 20/2).
GC20/2 applies to FCA-regulated firms that operate physical sites like bank branches, building society branches, credit union offices or cashpoints. The proposed guidance sets out the FCA’s expectations that firms should carefully consider the impact of a planned closure or conversion on their customers’ everyday banking and cash access needs, and other relevant branch services. Where firms do close or convert any of these sites, the proposed guidance sets out the FCA’s expectations around alternative access arrangements.
The proposed guidance makes it clear that the FCA expects firms to keep it informed of plans for closures or conversions throughout the process, to enable the regulator to monitor whether customers are being treated fairly. This should start in good time before the firm announces proposals and continue throughout the process. The FCA expects firms to conduct their 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. If the firms decides to progress with its proposals, the FCA would expect firms 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, as well as communicating existing alternative ways to access services or ways the firm proposes to make alternative access available. The FCA would also expect firms to keep their analysis of customer impact and potential alternatives under review during the period between the proposals being announced and implemented, and keep the FCA informed of changes to its plans. If the firm decided to implement some or all of the proposals, the FCA would expect firms to clearly communicate the alternatives that its customers can use, whether these are existing services or new alternatives the firm is making available.
The deadline for comments on GC20/2 is 30 July 2020.