Following our meeting with Barclays Bank on Friday 15 December to express our strong opposition to their plans to close their Crouch End branch, your Crouch End Labour Councillors and I have written to Barclays bosses to ask a number of questions about the work they have done to assess the impact.

You can read our letter in full below – and we will share a copy of the response we receive:

Dear Barclays,

Thank you for your follow up note, and for meeting with us last Friday.  We appreciate the information you have provided but are writing with some follow-up queries and concerns we have regarding the recently announced closure of your Crouch End Branch.

As we have previously outlined, we strongly oppose this closure and believe it will be of detriment to the local community, and risk harm to retail banking consumers in the area, especially to vulnerable customers who rely on branch banking services.

As noted during our meeting, we will engage with the FCA in parallel to voice our concerns, specifically with how this branch closure impacts adherence to FCA’s PRIN 6 as well as adherence to Consumer Duty and Access to Cash guidance. Further to our engagement with the FCA, there are some outstanding questions we would appreciate a response to in order to fully understand the impact this branch closure would have on the community it serves. We would appreciate a response to the below by Friday 12 January.

• In your literature, you note that the branch only has 26 regular customers. We would request a definition of “regular customer”.

• Following the closures of the Muswell Hill and Highgate branches, please advise how many customers who formerly used those branches now utilise services at the Crouch End branch? Please provide the number of individual customers previously using the aforementioned branches who have used the Crouch End Branch at least once in the past six months.

• Please provide numbers of customer queries as well as customer complaints related to the announced branch closure.
  • Please provide these figures in relation to the recent closure of branches in Muswell Hill and Highgate as well, as we believe these are important data points in assessing the broader impact of the trend in increasing branch closures.
• To what extent have you engaged with the FCA on the Crouch End branch closure?
  • We thank you for your follow-up note where you reference LINK. While we are aware they may trigger a review, we are keen to understand Barclay’s own review off access to cash (whether this is done through LINK or not, we would expect that a review or assessment has been made by Barclays given the announced closure).
    • A recent Consultation has been issued by the FCA related to Access to Cash (CP23/29). While we understand this paper is still in consultation, we note that section 2.23 involves firms notifying LINK of planned branch closures. We would request confirmation if they have been notified, and to what extent you have engaged with LINK.
    • Beyond any assessment LINK has conducted, what assessment or review has Barclays conducted to assess local access to cash?
    • Capacity of local Post Office services is already stretched and should not be left out of any analysis on access to cash. Has analysis (either through LINK or otherwise) included an assessment of capacity of local Post Office service? We do not believe it is fair for additional traffic to be expected to be absorbed by the Post Office, where there are already frequent queues.
    • Noting that Consumer Duty and FCA Guidance on Access to Cash includes small businesses and given the importance of small businesses to Crouch End, what consideration has been made to business banking customers. How many business banking customers use the local branch as a deposit point and what consideration has been made to potential harms of requiring these customers to attend branches minimum of two miles away to deposit large sums of cash?
    • Closure of this branch places further strain on existing local cashpoints which are already frequently empty, restricting consumers’ access to cash. Post Office capacity is increasingly stretched, with regular long queues to access the various services they provide.
    • Recent theft at outside cashpoints has understandably highlighted the importance of indoor access to cash services. The closure of this branch significantly reduces local access to safe and secure access to cash and heightens the risk of harm to the consumer.
• Please provide the number of Potentially Vulnerable Customers (PVCs) who use the Crouch End Branch (please provide any PVC who has used the Crouch End Branch at least once in the past 6 months. Should you not have data on PVCs, please provide a list of all customers over age 70 who have used the branch at least once in the past six months). In their OCT22 Guidance (FG22/6), the FCA noted that c. 21% of adults with day-to-day accounts regularly use a branch. Further, they note that Adults who most regularly use a branch include those with one or more characteristics of vulnerability.
• In your literature, you noted that 94% of customers who use the Crouch End branch do use app, online, and or telephone banking.
  • These services do not allow access to cash, and there is no indication of customer preference, which is increasingly important for PVCs. How many customers does the 6% of branch users who do not use these alternate banking channels represent?
  • We would also like to better understand your strategy for ensuring this 6% of customers still have access to banking services despite the closure of the Crouch End branch (noting the nearest alternative is now 2 miles away, and this follows the closures of Highgate and Muswell Hill branches). What strategy is in place to ensure these customers are still best served, and what consideration has been made to any increase in traffic expected at the few branches which will remain open in the region?
  • What advice has been provided to any customers with limited mobility in accessing branch services?
  • A trend of increasing isolation for PVCs and customers not suitable or amiable to alternate banking channels is concerning. We would also be eager to ensure that any strategy pursued by Barclays which would put further emphasis on customers utilizing alternate banking channels (especially PVCs) takes due consideration of anti-fraud measures. PVCs and elderly customers are at increased risk and vulnerability to fraudsters (the PSR has noted APP Fraud as a concern), as well as an increase in vishing and phishing scams. More recently, the PSR has issued a consultation on 29/09/2022 on proposals to give consumers greater protection against APP scams. What work is being done to inform PVCs about their rights should they fall victim, and what work has been done to ensure customers who are not comfortable with alternate banking channels feel secure accessing services?

Suitability and treatment, access, and confidence are three principles which underscore the FCA’s Consumer Duty. We are concerned that the closure of the Crouch End branch erodes these principles by diminishing access to cash and branch services, and especially by increasing the risk of harm to Potentially Vulnerable Customers. Closure of the Crouch End branch must not be considered in isolation and must be viewed in the broader context of recent branch closures and the diminishing physical presence of financial service providers to retail customers. Under Consumer Duty, the FCA also notes that “firms should continuously learn from their growing focus and awareness of real customer outcomes.” Our concern is that this branch closure is made without due regard for real customer outcomes and highlights our concern on this trend in closures.

We once again thank you for your time in our recent meeting, and in advance for your prompt reply to our questions and concerns.

Wishing you a happy festive season.

Kind regards,

Catherine West MP

Cllr Lester Buxton

Cllr Cressida Johnson