better banking: a public-good banking ......of progressive politics in scotland. common weal also...

BETTER BANKING: A PUBLIC-GOOD BANKING NETWORK FOR SCOTLAND

28.09.19 Common Weal Policy

Common Weal is a Scottish ‘think and do tank’ which promotes thinking, practice and campaigning on social and economic equality, participative democracy, environmental sustainability, wellbeing, quality of life, peace, justice, culture and the arts.

Common Weal is entirely funded by small donations from members of the public and is entirely independent of any political party. It is governed by a Board drawn from across the spectrum of progressive politics in Scotland.

Common Weal also runs a news service called CommonSpace and has a network of autonomous local groups who seek to put Common Weal ideas into practice in their communities.

For more information visit:www.commonweal.scotwww.commonspace.scot

Or contact us at:[email protected]

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Common Weal

KEY POINTS

― The UK has one of the least diverse retail banking systems in Europe with a disproportionately large market share for private banks and very few cooperative, mutual or public options compared with other countries.

― Private banks (which have no public benefit obligations to customers or communities) have been closing branches at a rapid rate, leaving much of Scotland without reliable banking services. They have also engaged in extremely risky behaviour which has put the wider economy at risk.

― Having a reliable public or mutual banking sector would mean branches being returned to communities, helping to support small business development and local economies, balancing the over all risk to the economy and helping to address issues of poverty which relate to lack of banking services.

― There is now an off-the-shelf ‘bank in a box’ model which can enable this to happen quickly. The Community Savings Bank Association has produced a package which enables a mutual bank to be set up very quickly (as little as 18 months from start to launch). A bank created through this model would have the following characteristics:

It would be owned by its customers who would all have an equal say in how the bank was run

It would provide all the banking services a private retail bank would offer – but with no shareholders there would be no profit taken out

It would charge customers a monthly fee of £5 – but this would mean it didn’t have to push products at customers to cross-subsidise core services. A provision could be put in place for people unable to afford the fee.

Current accounts would be interest-bearing – customers would receive interest on every penny they are in credit, removing the need for a separate savings account

AUTHORDr Gemma Bone Dodds is an innovation and systems change specialist who concentrates on economic transformation and is the author of the Common Weal paper Banking for the Common Good: Laying the foundations for safe, sustainable, stakeholder banking in Scotland. She has a PhD in diverse economic thinking and is a director of All In, a research and systems change agency dedicated to transforming the economy to serve the needs of society and the environment. www.allin.agency

Better Banking

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Common Weal

There would be two branch options. For bigger communities a full, traditional branch would be opened while smaller communities would get a ‘BankPod’ – most of the services of a bank in fully automated form with video conferencing support so customers can talk to a staff member, installed in a space as small as a container unit

― The total start-up costs of the bank would be in the order of £20 million; from there scaling and the number of branches would be dependent on the number of customers

― The bank needs to be set up by a team with the expertise and passion to create a truly mutual bank that will work for the people, the communities, the businesses and the environment of Scotland.The initial project team (who should not, as a rule, be predominantly bankers themselves) should commit to a process of meaningful stakeholder engagement and design right across the country to ensure that the bank is created with and for the people of Scotland. Common Weal believes it should be established initially as a public project and the founding team should be supported and work in close alignment with the Scottish National Investment Bank team, who should assist in the delivery and capitalisation of the bank in association with local authorities.

CONTENTS3 Author3 Key points5 Introduction5 Why we need a new local retail banking system in Scotland6 We can do better6 Why the Scottish National Investment Bank isn’t enough8 What does this mean for Scotland? 8 The CSBA model12 What should a Scottish regional community bank look like? 13 Next Steps13 References

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Common Weal Better Banking

INTRODUCTIONThis paper sets out a programme for the creation of local, sustainable stakeholder banks in Scotland. It shows why we need to invest in banks with local branches and proposes the adoption of the Community Savings Bank Association’s model, with some specifics of how this model should be adapted for Scotland.

WHY WE NEED A NEW LOCAL RETAIL BANKING SYSTEM IN SCOTLAND.For far too long we have been hostage to the power and influence of a banking system which does not have the right incentives, values or structures to be able to support society and the wider economy with what it needs.

Nowhere is this clearer than the abandonment of towns across Scotland in the haste to retreat from branch banking. A recent report1 by the RSA shows that branches still play a vital role in local economies by supporting SMEs and promoting financial inclusion. Despite this, the Scottish Parliament’s Inquiry into bank closures2 found that since 2010, over a third of branches have closed in Scotland.

In fact, the situation is rapidly deteriorating as the two principal banks in Scotland, RBS and Lloyds (which owns Bank of Scotland) are retreating from branch banking at an alarming rate, stranding many customers and abandoning their ‘last bank in town’ pledge. The retreat of banking services has a disproportionate impact on our rural areas. The House of Lords Rural Economy Committee recently noted that the loss of basic services such as banks and ATMs is a key issue for people and businesses in the countryside3. This is especially damaging in the most remote and rural areas of Scotland where some have to travel over 50 miles to access a branch and in some cases, this involves a ferry crossing4. Highlands and Islands Enterprise have shown that since 2015 there have been 28 bank closures in the Highlands and Islands area, with 14 further closures planned in 2018. The total closures comprise 22 in Highland, 10 in Moray, seven in Argyll and Bute and one each in Eilean Siar, Orkney and Shetland. Seven of these closures are in areas designated by HIE as fragile5.

Bank closures per 100,000 residents

1.5 or more

None

Source: Big Six banks, ONS, BBC (2016)

0

5000

10000

15000

20000

Bank branches in Scotland, 1989

Bank branches in Scotland, 1989

Number of bank branches in Scotland, 1989 - 2018

Source: Which?

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Although banks argue that the rise of online banking has made branches untenable, many small businesses rely on cash and need to deposit their takings every day. It is likely that access to cash will worsen in the future as ATM providers consolidate the number of cash machines and start charging for their services. In 2018 free-to-use ATMs in the Link Network declined by 5% or 2,600 machines6. Many now rely on Post Offices for some basic banking services; however a recent survey by the National Federation of SubPostmasters warns that 22% of post office workers are planning to close, hand on their business or downsize over the next year7. Hopefully separate solutions will be found to ensure the sustainability of the Post Office, however we cannot solely rely on them for banking needs.

Even where mainstream branches remain, businesses are not getting the support they need from banks, and too many people are denied access to basic bank accounts and facilities, pushing them into the arms of high cost credit, often worsening already difficult situations. The most vulnerable in our communities are those most affected by these closures. This is not acceptable.

WE CAN DO BETTER. We need a banking system that enables:

― Simple, everyday banking for all – the vast majority of people want a stable and safe place to store their money, grow modest savings, and have access to fair credit as necessary, especially the most vulnerable.

― Inclusive growth – growth is no good if it is one type of growth (e.g. sector, region, race, class or gender) at the expense of the others. Inclusive growth will not happen by accident, we need to design for it. Only if we pay attention to the sentiment of Emmas Lazarus when she said: ‘none of us is free until we are all free’, will we unlock the true potential of Scotland in all its diversity and wealth.

― Sustainable investment – the need has never been greater to transform our economy to become sustainable, low-carbon and fairer to workers. We need to support the growth of SMEs, entrepreneurs, social enterprises, and community groups seeking to help us tackle our pressing problems.

― A more stable, diverse financial system – adding in a new layer of local, co-operative banks will make the overall economy more robust and better able to withstand shocks and stop the retreat of branch banking, which is so important, particularly to our rural communities.

In March 2016, Common Weal, Friends of the Earth Scotland, the New Economics Foundation and Move Your Money published a report ‘Banking for the Common Good’8 which set out an ambitious programme for reform to create a model banking system made up of local, democratic banks underpinned by publicly owned infrastructure and a national investment bank generating wealth. As a first step, it called upon the Scottish Government to consult on the creation of a Scottish National Investment Bank (SNIB) and a follow up report ‘Blueprint for a Scottish National Investment Bank’9 in October 2016 provided a greater level of detail on how exactly this could be done.

This call was heard. In September 2017, the First Minister Nicola Sturgeon announced the creation of the SNIB. Following consultation, this part of the process is well underway, however the SNIB was only ever half of the story.

WHY THE SCOTTISH NATIONAL INVESTMENT BANK ISN’T ENOUGHWhilst National Investment Banks can play a key role in financing investment in infrastructure and supporting the economy at large, successful national investment banks tend to rely on a vibrant local, regional or municipal banking

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sector to distribute loans. This is particularly important in ensuring that capital is spread evenly throughout the country, or able to be targeted at regions that suffer from under-investment or deprivation.

Local, regional and municipal ‘stakeholder banks’ in other developed countries add economic value by filling the gaps where commercial banks are unwilling to go – maintaining a presence in rural areas, providing patient capital, relationships with small businesses, and serving the financially excluded. They also appear to have a positive

impact on financial stability. This should be a key aim of any new banking system in Scotland.

What we know of national investment banks elsewhere, particularly in best practice examples such as the KfW in Germany, is that they have a banking structure where their national investment bank reaches down into the corners of the country through a blend of regional and local, co-operative and mutual banking networks. The KfW would be nothing without a vibrant local banking network, made up of the Sparkassen, or savings banks, and co-operative banks.

COOPERATION FROM NATIONAL TO LOCAL: THE GERMAN EXAMPLEMore than any other banking system, the German example illustrates the potentially powerful symbiotic relationship between a national investment bank and a municipal or local banking system. It also illustrates the diverse range of ownership and governance models that public banks can adopt, and the way public institutions can add value to the economy rather than ‘crowding out’ private investment.

In Germany the KfW lends mostly through secondary financiers and in doing so works with nearly every German bank in a three-pillar system – private retail banks, savings banks, and co-operative banks. The Sparkassen and local co-operatives perform most strongly at SME lending due to their local focus, and as such are key partners for the onward distribution of National Investment Bank loans.

Market Shares of Deposits in Germany, France and the UK Source: Greenham, T. Prieg, L. ‘Stakeholder Banks: Benefits of Banking Diversity’, New Economics Foundation, (2013) p.3

The co-operative and savings banks are a key part of the success story of the German economy, outperforming private commercial banks in terms of real economy lending and small business lending, as well as spreading both public and private investment more evenly across geographic regions. The local banks are also important institutions within their local communities, providing financial support for local cultural, social and sporting activities.

Germany France UK

24%36%

40% 82%

18%45%

55%

Commercial bank

State financial institutions

Cooperatives, credit unions and mutuals

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WHAT DOES THIS MEAN FOR SCOTLAND? Scotland does not currently have anything that could be described as a vibrant, diverse, and local banking system. It is time to create something better.

At the time of writing the original report in 2016, it was thought that creating a new local banking system would require significant changes at national, regional and local level. This is no longer the case for two reasons.

Firstly, the UK regulatory landscape has changed, partially in recognition that the barriers to creating a bank were too high. The main regulatory bodies, the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) set up the ‘New Bank Start Up Unit’ to make the processes easier and fairer to smaller and inherently less-risky types of banks.

Secondly, in ‘Banking for the Common Good’, we envisaged the Scottish National Investment Bank having to create the banking infrastructure necessary for local regions of Scotland to set up their own local banks. This would be a big endeavor for an emerging/new bank with many other priorities, however we did not see any

other feasible option. There is now a much quicker and more efficient option.

THE CSBA MODEL An organisation called the Community Savings Bank Association (CSBA) has laid the groundwork to enable the creation of a UK-wide network of 18 mutually-owned, regional savings and loans banks to serve the financial needs of people of ordinary means, local community groups, small and medium sized companies.

The CSBA has carried out extensive research supported by the Royal Society for the Encouragement of Arts, Manufactures and Commerce (RSA), led by Fellow James Moore and a team with over 150 years of banking experience between them10. This research has led them to develop a concept of a ‘community bank in a box’. This network of independent, customer-owned regional banks take the best of past banking practice and the latest technological innovation to ensure that the costs of operating the bank are minimised for a sustainable and profitable model.

Four cooperatives following this model are in the process of being set up, in London, the South West and West of England, with other regions

CAPITAL INVESTMENT PHASING FOR A CSBA BANKThere are a number of stages to building a regional co-operative bank, which are outlined below alongside the targets for funding. Initially, the start-up phase where the initial research and development of the specific model needed for the region is developed, needs a relatively modest amount of seed-funding. We believe that amount should be secured by the Scottish Government, who have agreed on the urgent need for a systematic study of the banking landscape in Scotland.

Once the market research has been completed, stakeholders identified and founding members and the core team in place, authorisation by the Bank of England takes 12 months, during which time the full required capital of £20 million needs to have been secured. It is expected that to succeed, soft commitments to the full value of the capitalisation should be in place before the banking license is applied for.

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investigating these proposals. Each bank is legally and operationally separate, with decision-making made by its members – the customers. By collaborating on the infrastructure with other banks in other regions, the risks, costs and timescales of creating each new bank is reduced through the use of proven banking systems, standard product ranges and common operating structures.

Each bank has as its starting point a complete business model, legal structure, IT system, product line, branding and corporate governance framework – which is simpler, cheaper, faster, and less risky. Certain core functions are co-owned, cost shared and developed with others in the network, enabling economies of scale. The products offered by each bank will include

Stage Target What funding will be used for Key target investors

Stage 1: Start-up £150k -

£300kMarket research and tailoring of model to local circumstances. Recruit Board. Start application process to gain feedback from regulators.

― Social investors ― Charitable Foundations ― Social impact funds

Stage 2: Authorisation £1m to £2m Recruit executive team. Conclude

supplier contracts, build back office, It and operational infrastructure. Obtain provisional banking licence.

― Social investors ― Charitable Foundations ― Social impact funds

Stage 3 - Mobilisation £4m - £5m Open branches and online channels, recruit

branch managers and staff, training, as well as designing policies, procedures and products

― Social investors ― Charitable foundations ― Social impact funds ― Local authorities ― Pension funds ― Investment funds ― CSR funds ― Angel investors

Stage 4 – launch £13 - £14m Full caplitalisation can take place once an

unrestricted banking licence is obtained, but investor commitments must already be in place to achieve the licence. This provides regulatory capital requirements for the bank to begin to build its balance sheet.

― Social investors ― Charitable foundations ― Social impact funds ― Local authorities ― Pension funds ― Investment funds ― CSR funds ― Angel investors

Stage 5 – Crowdfund £1m To take place at the same time as the

launch fund raise, the crowdfund helps to build a customer base whilst also providing a marketing opportunity for the new bank

― Members ― The public

Source: Travers-Smith, F., Van Lerven, F. ‘The Local Banking Toolkit: a practical guide to starting a regional community bank’, The New Economics Foundation (2018) [Available at: https://neweconomics.org/uploads/files/NEF_LOCAL-BANKING-TOOLKIT.pdf]

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a competitive range of current, savings and loan accounts, together with online capability.

Regulation has been primed by the CSBA, making the process easier and less risky. Mutual societies are regulated by the FCA, which has registered the CSBA and approved its constitutional documents as “model rules” that can be used, with its permission, by the individual regional community banks for quicker and cheaper registration. These model rules are the core constitutional documents, which encapsulate all the principals, powers, and obligations that a new co-operative bank will need.

Crucially, these documents are open enough that each regional bank can put its own stamp on the organisation, adapting it to fit the particular needs of their area. At the heart of the model sits local democratic decision-making and ownership by the members in a truly mutual bank.

Mutuality

A mutual bank is a financial organisation which is owned by its members rather than shareholders, and allows members to have a share of the profits and democratic control on a one-member-one-vote basis.

Customer-owned banks only became legally possible in the UK in 2014. Mutuality is embedded in the structure of the CSBA model bank and it would be the UK’s first genuinely co-operative regional bank. This is important for two crucial reasons. First, the bank will bring some much-needed trust into the banking system by putting customers at the heart of the organisation. Being owned by, and therefore in service to, its members creates the right incentives for the bank to do what is right for the communities of which it is part, and if something was to go wrong, its members have real power to hold the bank to account.

Second, because it is member owned, this enables the bank to operate with a more sustainable and just idea of value - it would be a stakeholder bank able to account for social and environmental, as well as economic goods. Where shareholder banks can destroy that which is dear to us in

search of the highest profit margins, stakeholder banks can create sustainable returns whilst also serving social needs11.

Inclusive and Fair

The CSBA model has inclusivity embedded. Every single person who lives in the regions that the bank covers is entitled to a basic bank account. This should impact on the poverty premium which is the average £490 per year which poor people pay for access to basic goods and services, of which around £92 is driven by financial exclusion12. No longer should someone be forced to pay more because they are excluded from direct debits or cheque cashing services.

Because the bank is controlled by its members the members are free to make decisions to use some of the profits to achieve certain social or community goals, of which some services might want to be subsidised to make it fairer or more inclusive for certain activities.

Simple

The CSBA model will be transparent and upfront about fees, current accounts will be open to all, but it will not be free. Currently retail banks in the UK run on the profits from high fees charged for overdrafts or other facilities and through the bank cross-selling you products you don’t need (hence the PPI scandal). The CSBA model is much simpler.

There is a £5 per month fee for individual customers, which rises to £10 per month for SMEs. Clearly, for the poorest in society, the fee might be prohibitive, but we argue that there could be ways to subsidise this by other means. However, unlike regular bank accounts, you will accrue interest on your current account balance. So, if you have money in your account, you will get paid interest by the bank. If however you have an overdraft and you owe money, you will pay interest on the amount overdrawn, with no need for separate savings accounts.

This will benefit those who are unable to save but have income going through their account every month, even if it then goes out to pay the bills.

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Similarly, SMEs are net savers, but most of their savings sit in their current accounts waiting to go out. The simplicity of the CSBA model is that SMEs will also be rewarded for providing this liquidity to the bank.

Profit-sharing

The profits the bank makes is able to be shared with its members – through giving higher interest for savers, lower rates for borrowers, and a dividend for members.

Bringing Back Branches

The CSBA research has carried out extensive analysis of the numbers and turned this research into a business plan which enables a profitable bank with a good network of branches. Branches are of two kinds; full branches (as we currently see on the high street), and specially designed, fully automated ‘BankPods™’ which provide the majority of banking functions with video-conferencing support.

CSBA research found that bank branching is still a profitable endeavour, even in more remote and rural locations, and challenges the banking industries retreat from branch banking. The open 24/7 BankPods™ are particularly important for rural areas as they should cut down the distances that local people and businesses have to travel to do their everyday banking such as paying in cash or cheques, saving them a lot of time and money.

A BankPod™ has been built in a warehouse to test out the viability and usability of the new technology. Each regional bank would decide with its members the distribution of the two branch types, and it could be that a BankPod™ could be supported with branch staff on some days of the week, to facilitate the transition to this new technology to ensure fair access for all, or to link branch managers with businesses based in rural areas.

Bringing Back Branch Managers

A new bank should be rooted in the communities in which it is based. Over the years the role of

branch managers has been stripped back in favour of automated systems which centralise decision-making. Whilst this may increase short-term profits, the loss of local decision-making leads to poorer expertise, as knowledge is the key to making good investments and fair decisions. Branches would have managers with real power to make decisions, and they will be rooted in the communities that they serve.

It is important that we capture the expertise of bank managers who have been made redundant or changed jobs due to recent branch closures, and harness them to train up the next generation of managers and staff so that we are not left with a skills shortage in the years to come. Branch managers should reflect the populations that they were set up to serve and embody the values and principals of the bank.

The CSBA model is ‘shovel ready’

The ‘community bank in a box’ model means that a local banking system is within our reach in reasonable timescales. What is needed is:

― A credible group of people willing and able to found the bank. They need collectively to have expertise, experience and connections to the local area. They need to adapt the CSBA model to fit their region, find key people to run the bank once operational (the founding group are not the same as those who will run it once open), and find the funding.

― £20 million investment – this is to satisfy the regulatory requirements (and indeed goes beyond the minimum), and to provide capital to begin the process of applying for the banking licence and initial capital expenditure.

Once these ‘assets’ have been secured, it is estimated that to secure the banking licence and be ready to start trading would take around 18 months. To reach maturity and have the full branch network set up it has been estimated by the CSBA to take nine years.

The New Economics Foundation has produced the ‘Local Banking Toolkit’13 which outlines the

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practical details of setting up the CSBA model, and was co-written by one of the founders of Greater London Mutual. As each bank needs to be set up to work for the communities it serves, we have outlined below some of the principles and values that a Scottish bank should create.

WHAT SHOULD A SCOTTISH REGIONAL COMMUNITY BANK LOOK LIKE?In addition to the mutuality and democracy that is already embedded in the CSBA model, here we set out some of the elements we think are crucial in creating a local banking system that works for the common good in Scotland.

One bank or two?

For Scotland, the CSBA propose that there needs to be two regional banks – East and West – to ensure the critical mass of people needed to grow and sustain a bank whilst keeping the bank at a small enough level, with a good blend of urban and rural, to ensure that the ‘local’ element is not lost. We would suggest that the initial research should be done using participatory consultation methods to really understand the needs, test the market, and ensure that communities across Scotland would be happy with any approach taken.

Vibrant branch network

The initial research stage should identify a comprehensive picture of the banking landscape in Scotland, taking care to identify gaps in provision and use participatory processes to engage SMEs and vulnerable citizens in particular to find out what a new bank needs to do to serve Scottish society and ensure universal banking provision. This will lead to a deeper understanding of the network of branches needed in Scotland, taking into account the likely future of further branch closures.

Supportive of social finance

A Scottish Peoples’ Bank should exist not to compete with other institutions that already exist to provide socially useful finance, such as credit unions and community development finance, but they should be partially owned by and supportive of them. Credit unions need to access banks in order to operate, and are in some cases as liable to damage from unstable banking practices as any banking customer. A Scottish Peoples’ Bank should be set up in full consultation with existing social finance organisations in Scotland and this should be reflected in its constitution.

Reflect modern, diverse Scotland

From the highlands to the islands, West to East, North to South, urban and rural, the bank(s) should ensure that the areas they cover are adequately reflected in branch locations, but also in the decision-making, operational and governance structures of the bank. The Scottish Peoples’ Bank should be gender diverse and gender competent14 and should reflect the best organisational practice in diversity and inclusion in meaningful ways.

Remuneration

The Prudential Regulatory Authority Supervisory Statement on Remuneration SS2/17 sets out bank regulations on pay and bonuses. The bank would be assessed on proportionality level three as the assets would not exceed £15 billion. It should have a remuneration committee which should set overall salary and remuneration for all employees of the bank.

CEO and high-level staff should, as a matter of principle, have a maximum salary ratio of 1:10 to the lowest paid member of staff (employee and contractor). This creates an incentive to raise all employee wages in recognition of the shared value creation. Real living wage of £8.75 (£16,835pa), National living wage £7.83 (£15,064pa), National minimum wage £7.38 (£14,199pa). If the bank chooses the lowest pay structure the maximum salary for the CEO would be £141,991, however if the real living wage is paid as a minimum salary level would rise to £168,350.

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Of course these are maximum salary bands and the remuneration committee should take into account a wide range of factors in determining executive pay including fairness, experience, and ability to attract appropriate individuals to these key positions. Nevertheless it is expected that the culture of the bank and the unique challenge of creating a more socially useful form of finance will attract willing and experienced individuals to the position in addition to salary.

NEXT STEPSWe believe that urgent action needs to be taken in Scotland to build a sustainable local banking system. We have outlined how the CSBA model would be a clear path to achieve this.

There is one fundamental difference in Scotland compared to the other parts of the UK where the CBSA model is being developed, which is that Scotland already has a publicly-owned bank in the Scottish National Investment Bank. This provides both a structure on which the bank can be built and an immediate source of capitalisation for the bank. Common Weal believes in the merits of participative institutions and so a member-owned mutual bank with all customers owning a stake in the bank and being involved in its governance is very attractive. However, while it is desirable for the final bank to be mutually-owned there is strong case for it to be established and initially financed publicly. There are a number of reasons this would be beneficial – it would improve coherence with the SNIB, accelerate the

development and capitalisation process and be likely substantially to increase awareness and therefore the critical mass of customers showing interest in the bank. It would be linked both to small business advisory services (such as the Scottish Enterprise network) and to Scottish Government and local authority poverty support initiatives (to help excluded customers gain access to banking services).

We therefore call on the Scottish Government and the Scottish National Investment Bank to:

― Agree the need for the creation of a local banking system that serves the communities and local economies of Scotland.

― Fund the initial due diligence and research needed to build a comprehensive picture of the Scottish banking landscape. This which should include a participatory process to discuss this proposal with a wide group representative of the Scottish economy – with representatives from the Scottish Government, Local Councils, Credit Unions, community groups, businesses, the third sector and charities to map out what the local banking system needs to do.

― Instigate complimentary research to see how a network of local banks could support the practical implementation of the missions of the Scottish National Investment Bank.

We have the power to change the banking system for the common good. We’re in, are you?

REFERENCES1 Greenham, T., Travers-Smith, F. ‘Cashing Out: the hidden costs and consequences of moving to a

cashless society’. The RSA, (January 2019) [Available at: https://www.thersa.org/discover/publications-and-articles/reports/cashing-out]

2 Economy, Jobs and Fair Work Committee. ‘Bank Closures: impact on local businesses, consumers and the Scottish Economy’, The Scottish Parliament (July 2018) [Available at: https://sp-bpr-en-prod-cdnep.azureedge.net/published/EJFW/2018/7/3/Bank-closures--impact-on-local-businesses--consumers-and-the-Scottish-economy/EJFW052018R6.pdf

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3 Select Committee on the Rural Economy (2019: paragraphs 515-528) ‘Time for a strategy for the rural economy’ House of Lords. HL Paper 330. [Available at: https://www.parliament.uk/business/committees/committees-a-z/lords-select/rural-economy/news-parliament-2017/report-publication/]

4 Anon. ‘Access to banking services in rural areas’, Highlands and Islands Enterprise (July 2018) [Available at: http://www.hie.co.uk/regional-information/economic-reports-and-research/archive/access-to-banking-services-in-rural-areas.html]

5 ‘Access to Banking Services in Rural Areas’, Highlands and Islands Enterprise (July 2018) [Available at: http://www.hie.co.uk/regional-information/economic-reports-and-research/archive/access-to-banking-services-in-rural-areas.html] p1

6 Megaw, N. (1 February 2019) ‘Cash machine operator threatens legal action against ATM network’, The Financial Times. [Available at: https://www.ft.com/content/83cf2332-2628-11e9-8ce6-5db4543da632]

7 ‘Monaghan, A. (15 April 2019) ‘One in five UK post offices could close in next year, survey finds’, The Guardian, [Available at: https://www.theguardian.com/business/2019/apr/15/one-in-five-uk-post-offices-could-close-in-next-year-survey-finds]

8 Bone, G. ‘Banking for the Common Good: laying the foundations for safe, sustainable, stakeholder banking in scotland’ (2016) [Available at: https://www.commonweal.scot/policy-library/banking-common-good-laying-foundations-safe-sustainable-stakeholder-banking]

9 Macfarlane, L., ‘Blueprint for a Scottish National Investment Bank’, The New Economics Foundation, (2016) [Available at: https://www.commonweal.scot/policy-library/blueprint-scottish-national-investment-bank]

10 Travers-Smith, F. ‘Big Finance got us into this mess – can collaborative innovation get us out of it?’, The RSA, (23rd Jan 2018) [Available at: https://www.thersa.org/discover/publications-and-articles/rsa-blogs/2018/01/big-finance-got-us-into-this-mess--can-collaborative-innovation-get-us-out-of-it]

11 See Prieg, L. and Greenham, T. ‘Stakeholder banks: Benefits of banking diversity’, The New Economics Foundation (2013) [Available at: https://b.3cdn.net/nefoundation/141039750996d1298f_5km6y1sip.pdf] and Bone, G. ‘Banking for the Common Good’ p28-32.

12 Davies, S. Finney, A. and Hartfree, Y. ‘Paying to be poor: uncovering the scale of the poverty premium’, University of Bristol Personal Finance Research Centre, (2016) [Available at: http://www.bristol.ac.uk/media-library/sites/geography/pfrc/pfrc1615-poverty-premium-report.pdf]

13 Travers-Smith, F., Van Lerven, F. ‘The Local Banking Toolkit: a practical guide to starting a regional community bank’, The New Economics Foundation (2018) [Available at: https://neweconomics.org/uploads/files/NEF_LOCAL-BANKING-TOOLKIT.pdf]

14 Anon, ‘Seven Principles for a gender-competent Scottish National Investment Bank’, The Scottish Women’s Budget Group (2018) [Available at: https://www.swbg.org.uk/content/publications/7-Principles-for-a-Gender-Competent-Scottish-National-Investment-Bank.pdf]

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