ACCA welcomes the opportunity to respond to the Access to Banking Services Review, which has been commissioned by the government to enable the chair to understand whether there should be protections for in-person banking services. While the Review scope reflects that, it could better connect to the insights already gathered by different departments. This includes work undertaken by the Financial Conduct Authority (FCA), HM Treasury, and the Department for Business and Trade.  While outside the scope, their work should be called upon in assessing which in-person banking services are essential, relevant customer groups, and the materiality of the detriment caused.

ACCA recognise the positive intent behind the government’s broader Financial Inclusion Strategy, likewise the roll out of banking hubs across the UK. We also acknowledge broader efforts to unlock finance for small business, an issue that ACCA has consistently drawn attention to. This includes the recent expansion of the British Business Bank’s Growth Guarantee Scheme. Taken together, we view such initiatives as promoting the concept of ensuring financial services work for everyone. Alongside responses to specific questions, ACCA supplies the following recommendations.

• Clearer expectations on in-person service provisions: Given the FCA has established guidance on branch and ATM closures or conversions, we support consideration of extending these to in-person banking services.
• Improving customer information: We call on the government to encourage financial institutions to enhance their SME focused support and education. This is particularly relevant to the wide range of financing opportunities; likewise, the importance of business credit scores.
• Inclusive access for all customers: With digital exclusion still a problem in parts of the UK, ACCA has reservations about a digital only approach. We support the overarching principle of ensuring that non-digital alternatives remain.
• Utilise evidence collected across government: To avoid unnecessary duplication, ACCA encourages the government to utilise evidence already gathered and focus on tangible measures that promote inclusive access.
• Transparency-focused measures: With banks already providing the FCA with substantial information on branch closures and treatment of vulnerable customers, ACCA sees value in exploring the efficacy of assessments that underpin closure decisions. We also see merit in elevating the transparency of those.

To read the response in full, please download the consultation document found on this page.