My Decisions

Dalbeattie

12 August 2024*

Complaint not upheld

The customer complained that Dalbeattie’s Banking Hub application had been treated unfairly. A factor was that a nearby town of similar size had a bank hub awarded earlier in the evolution of the assessment process – the customer appreciated that evolution but found the differential result unfair.

The IA assessment looked at the criteria in place when Dalbeattie was assessed and checked that LINK applied those correctly (including adult population, number of relevant retailers, proximity of other banking facilities, local deprivation, digital inclusion and age profiles) against the predetermined thresholds. The conclusion that Dalbeattie was simply too small to meet the criteria for a hub or deposit solution and that there were already sufficient free to use ATMs in the town was validated. The long journey to alternative bank branches, an older population and financial and digital vulnerability scores had led LINK to exercise discretion and also make a site visit and site report.  The IA also visited and concluded LINK’s on site assessment had also been accurate and thorough. Overall, the criteria then in use had been applied accurately and fairly and the IA complaint as such was not upheld.

* The assessment was carried out before the FCA regulatory framework of PS24/8 Access to Cash came into effect.

Tonbridge

27 February 2025

Complaint upheld

The customer complained that Tonbridge did not have a way for businesses to withdraw and deposit both notes and coin conveniently, nor would LINK’s recommendations for an Automated Deposit service for notes only, provide that.

The IA assessment noted that LINK first assessed and visited Tonbridge in 2022 under the voluntary scheme pre-dating the FCA’s regulation of access to cash. The catchment for population and retailers made it a ‘large’ town, and distance/ travel time to the next full-service bank was considered unacceptably long. Tonbridge had no red or amber flags with regard to financial deprivation, digital inclusion, or age profile. There was a temporary Post Office which was considered inadequate for banking transactions. Under the criteria then in place, the LINK recommendation was for a deposit solution.

LINK carried out another review under the FSC24/8 criteria in August 2024, prompted by the planned closure of the Halifax, leaving Santander and Nationwide (only personal banking). By that time a new Post Office had opened. LINK’s desk top review (there was no site visit) used a description of a new Post Office which was considered to meet the requirement for Full-Service Access to Cash (for both business and personal customers).  Neither the vulnerability nor travel information had changed, but the population and retailer assessment distances had changed under FSC24/8 from 1 km to 1 mile, with 148 retailers and adult population of 17,363.  The Post Office and two personal-banking only branches, were the main factors in the recommendation of a notes-only deposit solution.

The IA review raised only two issues with the LINK assessment – there had been no site visit in 2024 and the description of the Post Office relied on didn’t readily match the facility when the IA visited, and Tonbridge was defined as a ‘large’ location, but a ‘very large’ definition would apply with 150+ retailers, and at 148 retailers Tonbridge was very close to this threshold. Considering the town in the round, along with these two specific issues, the IA suggested LINK consider the assessment again.

Leatherhead

27 June 2025

Complaint not upheld

The customer complained that LINK had not explained the data used to underpin their assessment of Leatherhead, specifically in relation to relevant retailers and population.

The IA assessment checked that the figures LINK had used for the population in the ‘local area’ were correct given the customer’s view that the population was actually much larger. LINK source those figures from a single CACI proprietary data set used for all UK assessments, and the figure used was correct.

It was apparent though that the specific use of the term ‘local area’ wasn’t clear to the customer, so that was explained and in turn the reasons why the smaller population figure was in fact correct. In regard to the relevant retailer count, the LINK assessment did not record sufficient detail for the IA to be able to take a view on accuracy or offer explanation.

To address the questions the IA asked, LINK arranged a follow up visit to the town with the customer to count and explain the relevant retailers. The revised retailer figure after that visit was 73.  Taking the population size and retailers into account, along with the current Post Office provision, the Nationwide branch for personal customers and three ATMs in the retail centre (including a Cashzone machine which also takes deposits) I agreed as IA with LINK’s conclusion that no additional cash services were indicated at this point, according to the criteria.

Eyemouth

04 June 2025

Complaint not upheld

The customer complained that Eyemouth’s Banking Hub application had been treated unfairly in comparison to other Borders communities and felt that the existing cash position in the town was not fit for purpose.

The IA assessment checked that LINK applied the criteria in place when Eyemouth was assessed (including adult population, number of relevant retailers, proximity of other banking facilities, local deprivation, digital inclusion and age profiles) against the predetermined thresholds.

The town was visited by LINK as part of their assessment, and the conclusion against the criteria, that Eyemouth had sufficient services with two free to use ATMs and the Post Office, was validated.

The IA also visited Eyemouth and concluded LINK’s assessment had been accurate and thorough; feedback was given to the business that ATM reliability was critical, as whilst the Post Office provided seven days a week personal and banking services, its location at the top of a steep hill (albeit only half a mile from the town centre) meant it did not realistically contribute to cash availability in the town centre, especially to those without a car.

Overall though, the criteria had been applied accurately and fairly and the IA complaint as such was not upheld.

Thame

29 July 2025

Complaint not upheld

The customer complained that LINK had used incorrect population figures and an urban categorisation in their assessment. Amongst the other issues raised were that the retailer numbers and distance to a full-service bank were understated and that the age profile of the area had not been properly recognised.

The IA assessment checked that the population figures LINK had used for the ‘local area’ and retail centre were correct. LINK source those figures from a single CACI proprietary data set used for all UK assessments, and the figures used were as stated there. The assessment population of the local area was much lower than the customer believed due to some local villages being associated in the CACI data with retail centres other than Thame. In regard to the retailer count, the definition of a ‘relevant’ retailer includes only more cash-reliant business types, which along with the 1-mile retail centre area again accounted for a lower total. Overall Thame was correctly assessed by LINK as a ‘large’ location with two red flags for age profile and distance to the next full-service bank. Considering this, along with the Post Office facilities, the Nationwide branch for personal customers and the ATMs in place at the time of the assessment, I agreed as IA with LINK’s recommended addition of the note deposit machine to meet business need, in line with the assessment criteria. I recommended in addition that the Post Office ensure full potential in this location is being delivered and that LINK ensure with ATM providers that high cash withdrawal days such as market day are properly catered for.