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Ron Delnevo, Europe Executive Director
T: +44 (0) 7973 210 154
Meeting of the Month - March 2019.
There are no meetings in March. The next meeting of the European Advisory Board is on 9 May at 15.00 CET.
This is ATMIA Europes most important Committee. If you want to be part of it, please contact Ron Delnevo at firstname.lastname@example.org.
The UK Government has rightly made clear that it wants the UK Public to be able to deposit their cash at any ATM that has a deposit facility. In these days when the number of bank branches is fast declining, it is unrealistic - and very inconvenient - to expect those wishing to deposit cash to search out one of their own bank's ATMs to do so.
However, universal cash deposit at ATMs is only really a first step. What is truly needed is a network of Smart ATMs, strategically located around the UK and providing 99% of the services available at a staffed bank branch.
Every local community in Europe needs at least two Smart ATMs. ATMS are elrctro-mechanical devices which suffer faults and outages, including cash-outs. Two ATMs is therefore the minimum requirememt for any Community with no bank branch to provide local access to financial services.
Smart ATMs will provide many transactions and one of the most important is cash recycling. This is a progression from simply accepting cash deposits. A cash recycling ATM processes deposited notes, removing those that are damaged or dubious and makes available for withdrawal those notes which are fit for recycling to the public.
Cash recycling is convenient for ATM users and is also ultimately a cost-reduction measure. It cuts down the number of cash deliveries needed to ATMs and ensures that communities have some access to cash, even where for any reason a cash delivery fails to happen.
Any local recycling is good for the environment. Cash recycling can therefore be seen as helping the ATM Industry contribute to making our world a better place in which to live.
In some countries, all new ATMs which are being installed are capable of cash recycling. We urgently need to see this trend accelerate to include the UK and the whole of Europe.
The good news in the UK is that the LINK Network now has a Universal Cash Deposit transaction available to be used. All that is needed now is for all Issuers to adopt the transaction. After that, any ATM Operator can install machines anywhere to accept cash deposits from the customers of any Card Issuer.
It is clear that the UK Treasury is genuinely strongly interested in innovations, such as Cash Recyling at ATMS. This should provide impetus to the adoption of some exciting innovations in the ATM sector.
Ron Delnevo has written to Hannah Nixon, CEO of the UK Payments Regulator(PSR) ( she is leaving this post in April 2019) on a number of occassions, asking for an urgent update on the adoption of Universal Cash Deposit in the UK and asking what Ms Nixon is doing to facilitate adoption. This LINK transaction is vital to the smooth circulation of cash in the UK. It needs to be adopted by all issuers so that ATMs will the requisite functionality can be installed in Communities around the UK.
Despite several written requests for the Payment Systems Regulator to act, Hannah Nixon has so far failed to do so
Ron met with the UK Treasury in early September 2017 and again in January, June and November 2018, at which meetings he. asked the Treasury to intervene to ensure this vital transaction is implemented as soon as possible on UK ATMs. He has also continued to apply pressure to the Payments Systems Regulator (PSR) - whom he met again in November 2018 - and, of course, LINK, to get this transaction implemented.
There will be considerable media coverage of this hugely important issue in early 2019, so the first Card Issuer to implement this transaction will attract massive positive publicity.
Another transaction that needs to be available throughout the LINK Network is contactless cash withdrawals. At the moment, some ATMs offer this sevice to some cardholders. This is very confusing as fas as the public is concerned.
Contactless cash withdrawals at ATMs improve security and reduce average transaction times by 30%, which increases the capacity of busy ATMs and reduces queuing times.
Which bank will be the "First Mover" for these transactions in 2019?
WATCH THIS SPACE!
Payment Choice 2020: Maintaining Payment Choice in Europe
The ATMIA has been heavily involved in the Nordic Region in recent years, trying to help ensure that both ATMs and cash have a good future
Ron Delnevo appeared at the Nordic Finance Forum in Stockholm on 9 November 2017. His presentation focused on how SmartATMs can replace lost bank branches.
The ATMIA has also been fully involved in Finland, trying to stop the imposition of Disloyalty Fees on bank customers who choose to use non-bank ATMs.
The good news at the end of January 2018 is that the Finnish Financial Services Regulator has ruled out the imposition of Disloyalty Fees. THIS IS A BIG WIN FOR THE PUBLIC, INDEPENDENT ATM OPERATORS - AND CASH!
It means that it will remain economic for new ATMS to be installed to meet the cash needs of the Finnish public and businesses.
Government intervention looked unlikely, until very recently. However the following article from Bloomberg, published on 18 February 2018, holds out some hope of government action
““No cash accepted” signs are becoming an increasingly common sight in shops and eateries across Sweden as payments go digital and mobile.
But the pace at which cash is vanishing has authorities worried. A broad review of central bank legislation that’s under way is now taking a special look at the situation, with an interim report due as early as this Summer .
“If this development with cash disappearing happens too fast, it can be difficult to maintain the infrastructure” for handling cash, said Mats Dillen, the head of the parliamentary review. He declined to give more details on the types of proposals that could be included in the report.
Sweden is widely regarded as the most cashless society on the planet. Most of the country’s bank branches have stopped handling cash; many shops, museums and restaurants now only accept plastic or mobile payments. But there’s a downside, since many people, in particular the elderly, don’t have access to the digital society.
Riksbank Governor Stefan Ingves has said Sweden should consider forcing banks to provide cash to customers. In its annual report on Monday, the Riksbank said the question is what role it should play in a future with even fewer cash payments.
“The Riksbank is carefully analyzing this development,” Ingves said. “Overall, I think we are facing structural changes in areas that have previously been stable. This is a development which will affect all the Riksbank’s departments and we will need to make strategic decisions regarding the way forward.””
“One may get into a negative spiral which can threaten the cash infrastructure,” Dillen said. “It’s those types of issues we are looking more closely at.”
Since this article appeared a Parliamentary Committee has recommended that bank branches be compelled to offer cash services. This is getting some pushback from the Swedish Banking Association - but it looks likely the politicians will have their way, acting in the Public Interest.
DURING OCTOBER, THE RIKSBANK HAS ANNOUNCED IT IS MINDED TO FORCE ALL BANK BRANCHES TO ACCEPT DEPOSITS OF CASH AND DISPENSE CASH OVER THE COUNTER.
THIS WOULD BE A HUGE VICTORY FOR THOSE FIGHTING ON BEHALF OF THE SWEDISH PUBLIC TO ENSURE CASH REMAINS A CONVENIENT PAYMENT CHOICE IN SWEDEN.
WATCH THIS SPACE FOR UPDATES!
Limitations on Cash Use in the European Union
A study carried out on behalf of the European Commission and finalised in early 2018, has confirmed that restrictions on payments in cash would not significantly prevent terrorism financing, although the same study indicated that such restrictions could be useful in combatting money laundering.
As a result of the finding in relation to terrorism, the Commission has decided not to pursue Europe-wide limitations on cash use at this stage.
You can read more here
So good news, but we will need to be alert that this issue may well come up again, given the comment on money laundering. We are in discussion with other interested parties in relation to further potential responses to the Commission.
Also, there has been no indication from the Commission that they will be asking national governments to desist in imposing their own limitatons on cash use. This will need to be discussed with the Commission in due course.
There are on-going discussions within LINK as to the appropriate level of scheme interchange that should apply to cash withdrawals and balance enquiries.
At least one Financial Institution that is a member of LINK is rumoured to want an average 20% reduction of interchange payable, to reduce their own outgoings.
Other members of LINK maintain that there is an established formula for the calculation of interchange and that a 20% reduction in the levels established by using this formula would result in many Free To Use ( non-surcharge) ATMs becoming uneconomic to operate.
Industry estimates are that as many as 8500 Independent Deployers ATMs may be deinstalled in the next 24 months should interchange be reduced by 20%. This amounts to about 1/3rd of the free Independent Deployers ATMs currently operated on the LINK network. In addition, there may well be many bank operated off-branch ATMs that will become uneconomic and need to be removed.
Removals of ATMs on the scale envisaged would severely damage the publics convenient access to cash and threaten financial inclusion. Almost everyone in the UK could be adversely effected but the impact would be particular keenly felt by those on lower incomes or state benefits, who use cash for almost all purchases and find that use a vital tool in their budgeting to live their lives from day-to-day.
The ATMIA is in discussion with a number of Association Members, the UK Government and Financial Services Regulators. The objective is to ensure that the LINK scheme continues on a basis that guarantees, at a minimum, maintenance of current levels of public access to cash and that the level of LINK interchange is set at levels which make the scheme sustainable on a long-term basis.
The ATMIA is working hard to ensure an outcome in the public interest and one that enhances the future role of ATMs and cash in the UK. Ron Delnevo was interviewed by Eddie Mair on BBC radio on 7 April. You can hear this here.
In November 2017 this threat re-emerged, with proposals that LINK interchange be reduced by 20%. This would put 20,000 + free UK ATMs at risk. The ATMIA judges this proposal to be as against the Public Interest.
The powerful Treasury Select Committee, the most important Back-Bench Committee of the UK Parliament, has asked for an Independent Inquiry into LINK issiues. Which?, the Association of Convenience Stores,the Federation of Small Businesses and ATMIA have all supported this request.
Though LINK at the end of January 2018 announced a 5% cut in interchange on 1 July 2018, the ATMIA continued to work to ensure a clear vision for the future of the LINK ATM NETWORK is put in place.
You can read more here, in an article by Ron Delnevo, ATMIA Executive Director Europe.
As things stand in March 2019, the good news is that LINK has decided to limit the definite reduction in interchange to 10%, rather than 20%.This was a vital move by LINK, since industry estimates indicate there were only around 64,000 ATMs in the UK at the end of 2018, down from a high of 70,000. There has also been a small but significant switching of ATMs from free to pay-to-use, with a further significant switch in this direction thought likely in H1 this year..
Neither situation is good for the UK public, given that cash access at bank branches has declined so dramatically in recent years. Branch numbers have fallen by around 2/3rds in the last decade.
The UK can afford to lose no more ATMs - and the ones in situ need to get "smarter", so that they can fully replace lost bank branches.
Last month, LINK announced that it has created a £2.75 “super premium” interchange, to be paid where a free-to-use ATM achieves less than 200 cash withdrawals per month on average. Industry sources indicate that there are almost no (50 or less) free-to-use ATMs in the UK achieving this extremely low level of cash withdrawals. It is difficult to understand, therefore, how this premium can have any meaningful impact on the provision of ATM services in the UK.
There are certain to be further developments throughout 2019 - you can be certain to be well informed if you visit these pages regularly.
Business Rates on UK ATMs
An appeal to the UK Courts to stop the Valuation Office imposing Business Rates - a property tax - on off-branch ATMs has now been won!
The Court of Appeal found in favour of the ATM industry and its supporters.
Around £300 Million of business ratepayments are due to be refunded, with the repayments backdated to 2010.
However, ill-advisedly, the Valuation Office Agency has appealed the court ruling.
They certainly should NOT have done so. They were wrong to impose businss rates on ANY ATM in the first place!
We will know by end Q1 2019 whether this wrong-headed appeal succeeds - WATCH THIS SPACE!
Dynamic Currency Conversion
Debbie Smyth and Ron Delnevo, representing the ATMIA, met with the European Commission early in June 2018 to discuss Dynamic Currency Conversion (DCC).
The ATMIA team were delighted to report that, whatever happens in relation to transparency, the Commission has decided not to ask for an interim cap on DCC.
The ATMIA will continue to work with the Commission on every aspect of DCC, with the objective of ensuring this service can continue to be offered at ATMs without the imposition of onerous regulations.
ATM DCC is already significantly more transparent than that offered at POS. The ATMIA believes that if the Commission feels it appropriate to review the workings of DCC at all, the review should focus on the POS situation.
As of February 2019, the regulation has been published, with implementation in December 2019. We will continue to work to minimise any negative impact for the industry of the new requirements.
The ATMIA Europe Member of the Month for March 2019 is.....Auriga!
Working to protect the health & vitality of the European ATM Industry. Find out how you can contribute.