Consumer Data Right rules and data standards design paper for non-bank lending sector
On 1 February 2023, AFIA made our submission to Treasury’s ongoing consultation on the extension of the Consumer Data Right (CDR) to the Non-Bank Lending (NBL) sector.
Some important points AFIA have been advancing include:
A higher threshold before CDR obligations apply.
A 12-month window after breaching the threshold before data-sharing obligations apply.
A ‘trial-product’ exemption period of at least 18 to 24 months, facilitating innovation.
Staged implementation, as with Open Banking, by product category. For example, including consumer products before business products. Noting implementation of Open Banking took over four years.
Excluding bespoke and ‘invitation only’ products which are not publicly offered.
Excluding products not intended to be captured, like consumer leases and car rental.
Concerns about the inclusion of closed accounts and legacy products.