Vida FatemiThe Practitioner Panel has responded to the FCA’s access to cash proposals (CP23/29).
The Practitioner Panel believes that:
- the approach is responsive to changes in need which may derive not only from shifts in participation or representation by designated entities, but also consumer behaviour, demographic movements or other socioeconomic developments;
- allowing designated entities flexibility to define a local area will need to be balanced against the need for the rules to be clear, consistent and proportional from the point of view of the consumers who are intended to be the beneficiaries of them – multiple assessments could lead to different perspectives on the appropriate outcomes;
- it is best to designate one central body to both define a local area and undertake cash access assessments within them based on clear criteria linked to the activities of both designated and non-designated entities;
- the responsibility to deliver social policy outcomes should not rest solely on a narrow set of market participants; and
- it is vital for FCA to encourage innovation and competition in service provision both to drive positive consumer outcomes and to ensure there is not reliance on a single provider that could present a ‘single point failure’ resilience risk.