over 99% of all current accounts participate in the Service. CASS was designed to provide a switching. service that was recognised by customers as being quick and hassle free. Bacs has confined its response to paragraphs 71 to 75 and 161. Paragraphs 71-75 deal with âpotential. barriers to switchingâ, whilst paragraph 161 deals with the undertakings that were put in place following. the 2002 Competition Commission investigation into SME banking.