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CP19/5 - Call for views: Review of the structure of LINK interchange fees

Published 06 06 2019
Closes 05 07 2019
Making sure we all have a choice about how we pay for things, in the way we want to, is important.  Cash remains, and will continue to remain, one of those central choices. 
 
Most of us currently use ATMs to access our cash. Each time we use our debit card at an ATM that does not belong to the banks that issued the card, a fee is paid to the ATM operator. This is called the interchange fee. In this paper, we examine how the structure of those interchange fees works now, what other options there could be and how the interchange fee structure could work to provide better outcomes. 

Why are we publishing this document?

We are working to protect the current geographic spread of free-to-use ATMs. 
 
We are looking at why ATMs are placed where they are in different areas of the UK and what factors might affect where they are placed. Our wider work is also considering ways to improve access to cash through other means. 
 
This is just one element of our wider work on access to cash services and will feed into our broader regulatory approach in this area. We invite views on the issues raised in this paper from all interested parties, including relevant evidence. 
 
We want to hear and consider all views raised in this paper from anyone who is interested, with relevant evidence. We will engage widely with the industry during the course of our work plan.

What will we be looking at?

This paper is specifically focussed on the structure of interchange fees, rather than the level of those fees. We’re interested in hearing views and evidence on:
  • The description and framework for considering the costs of providing ATMs and the value they provide, including the objectives we set out in this paper 
  • Whether there are any other factors we should take into account when analysing the incentives to provide ATMs.
  • What incentives and impacts the existing LINK interchange fee arrangements, as described in this paper, have
  • What structure of interchange fees would have appropriate incentive effects going forward

Next steps

Reflecting the exploratory nature of this paper, we want this to be the start of an ongoing discussion of this issue. At this stage, we welcome views and evidence by 5pm on 5 July 2019. Any responses do not need to cover all of the issues covered in the paper, and we would welcome short contributions, observations and other ideas for reform. We are also planning a roundtable in the summer to discuss the work we are doing in this area. Please contact us by 21 June if you would like to attend.
 
You can email us at PSRcashaccess@psr.org.uk or write to us at the following address:
 
PSR Access to Cash project team
Payment Systems Regulator
12 Endeavour Square
London 
E20 1JN