Mr. John Palmer:

The Deputy makes a good point. While head 7 refers to notifying the bank, the definition of local deficiency in head 3 states it is "a situation where a potentially significant gap or deficiency in access to cash is identified in a ... region by the Bank, or notified to the Bank". The aim is that anyone can do it, including any member of the public or civic bodies or community groups, etc. We are addressing that and making sure that this will be the case. We came to the conclusion that this must be something where guidelines and information are given. If the Deputy has been looking at the UK Treasury's cash access policy statement, it is taking a very similar approach. It is because there are so many different scenarios that this is not a case where you can write down specific circumstances in which this qualifies and that does not qualify because you probably will end up disadvantaging a lot of people in the end. I always give the example of how it would be a reasonable scenario to imagine a population of 1,000 has to be affected by the closure of an ATM. The impact is that they will now have a 45-minute round trip. I can guarantee that one of the first cases would be that 995 people now have a 42-minute round trip. That is clearly not correct and as Mr. Gilvarry pointed out, there is a whole heap of other factors to take into account. For example, what if the percentage of those 995 people who are over 70 is higher than the national average? You have to take demographics into account, as well as travel time, geographic matters. The classic example of a local deficiency would be that an ATM closes. What if there is one within 5 km but it is on the other side of a bay and a round trip is a long way or it is on the other side of a river and there is no bridge? A huge number of scenarios can come out of this and we are asking the bank to produce guidance, to explain to people how they will assess what constitute local deficiencies and when it might determine that it warrants a remedy. It is very hard, however, to come up with hard and fast clear criteria to be applied.