We are of the opinion that the current rapid rate of bank branch closures may have come about as a result of banks rushing to close branches before legislation to protect access to cash and banking services can take effect. We are concerned that the existing mechanisms to analyse the needs of customers and ensure services are available are inadequate to prevent unnecessary closures. We expect the Financial Conduct Authority to carefully monitor the quality of the analysis used by banks to justify branch closures. Furthermore, while we do not expect the Government to 28 Access to cash in Scotland intervene in genuine commercial decisions, we believe there is a case for action if banks are closing branches purely to pre-empt the legislative intent established in the Queen’s Speech. (Paragraph 47) ATM network