Response to 2023 Points of Presence Consultation

The Australian Prudential Regulation Authority (APRA) has concluded its review of Points of Presence data for authorised deposit-taking institutions (ADIs).  

Consultation feedback

Access to physical banking services is important for many Australians, particularly those in regional communities. APRA’s Points of Presence Statistics continue to provide transparency to trends in the number of physical banking service channels, including branches and ATMs. 

In April 2023, APRA launched a public consultation seeking feedback on how the Points of Presence data can be made more helpful to users, examining issues such as categories of data published and banking services covered.  

APRA received eight submissions in response to its consultation, including two confidential submissions. The submissions in general found the data to be useful and were opposed to any reduction in the available data. The key themes from the feedback received are broadly summarised below:

• Usability improvements to the existing publication – suggestions include making the Excel files easier to navigate, providing more detailed location categories and more separate reporting of Bank@Post services.  
• New data collection to capture availability of detailed physical banking services – suggestions include publishing details of services provided, such as trading hours, services offered and so on. Other feedback includes broadening the coverage to include non-bank service providers.  
• An expansion of coverage to include digital channels – some stakeholders noted the current dataset does not capture how banking services are accessed, given increased usage of digital and virtual channels. Recommendations include collection of digital usage information including metrics such as the number of unique logins over a period.

To better understand the usefulness of certain new data, APRA engaged with various stakeholders including consumer groups, industry bodies, peer regulators and Treasury.

APRA’s response

In response to a subset of the feedback received, APRA made a number of improvements to its existing publication. These improvements make it easier for users to extract information and perform additional analysis of cross sectional and time series data. They include:

• data visualisations for geographic areas, individual ADIs and service channels
• additional geographic breakdowns, allowing analysis at various levels of granularity, and
• separate presentation of Bank@Post from other face-to-face channels.

APRA’s position not to expand the data collection reflects that:

• costs would significantly outweigh perceived benefits.
• changes would impose significant regulatory burden on the banking industry, notably for smaller banks.
• the industry is better placed to provide increased transparency on the availability and usage of banking services.

In particular, APRA’s consultation showed that meaningful information on digital and virtual access channels would be complex and costly to collect and interpret. APRA’s data is designed to track trends and is not intended to be a live directory of banking services.  

The benefits of APRA collecting granular service-level data are also limited given that alternative and potentially more dynamic public sources are available, including across a wider scope of financial services than just those provided by APRA-regulated entities.  APRA encourages industry bodies to work together to provide increased transparency on this matter, including for digital usage and access to cash.

APRA welcomes any feedback on these changes. Comments should be emailed to dataanalytics@apra.gov.au.

The non-confidential submissions are available on the updated consultation page.

Yours sincerely
Therese McCarthy Hockey
APRA Member