Mr. Colm Kincaid:

One way of looking at it is in the context of wanting to see choice, availability, competition and innovation for consumers. First, we put a very strong onus on the firms we regulate, as do other regulators across the European system, to be really clear and upfront with their customers about what service they are providing and what the features of that service are, so that when the customer is making a choice about a particular service, he or she understands what it is. Second, the onus is on firms to ensure that whatever model they use, they do it well.

Third, there should be special arrangements in place for people who might need some particular special assistance, be that face-to-face or otherwise. That is a broad-brush way of looking at it but that is the lens through which we look at innovation in products. We ask if it will be understood by the people who will use it, if it serves a purpose and if there are supports in place for people who might be quite happy to use it in a certain way in the normal course but who might need particular assistance at a particular point.

In the area of digital provision, we have been clear that there will be times when people will want to have face-to-face interaction with a human being because they have a particular need etc. On the physical location and the bricks and mortar issue, the system is evolving in a digital direction. Those are the lenses through which we look at the issue if that is helpful.