July 2019: This submission is in response to the draft Consumer Data Right (Authorised Deposit-Taking Institutions) Designation 2019 ("Designation Instrument") released by the Treasury. Visit our government submissions hub for more of our submissions to government consultations and inquiries.
Finder's mission is to empower Australians to make better decisions and, accordingly, we welcome the work being done by the Treasury, ACCC, Data61 and other parties in developing the instruments and standards that will enable CDR. We are keen to be an active participant in the CDR, particularly in relation to Open Banking, and hope to help consumers realise the benefits from their new rights.
Materially Enhanced Information
There is a lot of focus in this consultation on the difference between "derived" and "materially enhanced" data. Our primary view on this topic is that more can still be done to help participants understand what is and isn't included in Open Banking data sets. The inclusion of the list of derived data that is not deemed materially enhanced in section 10(3) in the Designation Instrument is useful. As is the short list of information that is considered materially enhanced data in the Explanatory Notes.
Taking this concept further, we believe that building one definitive list of the information that is included in the Open Banking parameters, alongside any explicit exceptions and examples of derived data that is not considered to be materially enhanced, would be helpful for all parties. Our understanding is that these lists are currently split between the Designation Instrument, the Explanatory Notes, the Data Standards and the Consumer Data Rules.
Obtained Customer Information
The information about a product user "obtained by or on behalf of the entity that holds the information, or on whose behalf the information is held", as outlined in section 6(1)(b)(ii) of the Designation Instrument, could cover a broad array of data points held by an authorised deposit-taking institution.
Our understanding is that the scope of this "obtained" information is restricted by the Data Standards being developed by the Data Standards Body, with the current version including common identification information such as name, address and phone number.
In the definitive list of Open Banking information inclusions and exclusions suggested above, it may also be useful to clarify whether other "obtained" information about a customer will be excluded from the scope (e.g. information on customers obtained from third parties, information obtained from subsidiaries or information obtained from products such as Superannuation, which are currently outside the scope of the CDR).
Reciprocity
We welcome the narrower definition of reciprocity set out in the Summary of Proposals document. Our view is that a broader definition, where "equivalent data" means equivalent in importance to the business holding the data, risks unintended and undesirable consequences for consumers.
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Response to the Consumer Data Right Sectoral Assessment for the Open Finance sector, focusing on non-bank lending
In this submission, we share our response to the Consumer Data Right Sectoral Assessment for the Open Finance sector, focusing on non-bank lending. It includes key datasets of interest and a possible use case.
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Response to non-bank lending draft designation instrument for the Consumer Data Right
In response to the proposed designation of the non-bank lending sector for inclusion in the CDR, Finder has prepared the following submission. Broadly, Finder welcomes the designation of the non-bank lending sector for inclusion in the CDR as a valuable sector that offers complimentary datasets to the existing banking designation.
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Submission to CDR Strategic Assessment
In response to proposed to the strategic assessment of the implementation of an economy-wide CDR, Finder has prepared the following submission. In this submission we share our consumer research across the sectors we compare and our views on the relative opportunity that the CDR could bring to each sector.
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Submission on Crypto asset secondary service providers: Licensing and custody requirements
In response to proposed licensing and custody requirements for crypto asset secondary service providers, Finder has prepared the following submission. Finder has been an active supporter of the smart regulation for the digital asset sector as we believe it will legitimise a sector that is too big to ignore, and that a strong Australian economy post-pandemic will involve the right conditions for the crypto sector to thrive.
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Submission on the Statutory Review of the Consumer Data Right
In response to the Statutory Review of the Consumer Data Right, Finder prepared the following submission. We continue to believe that the CDR has the potential to empower Australians to take control of their personal data and use this information to make better financial decisions.
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Submission on version four of the Consumer Data Right Rules amendments
In response to version four of the Consumer Data Right Rules amendments, Finder prepared the following submission.
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Supplementary submission on Select Committee on Australia as a technology and financial centre – Third Issues Paper (cryptocurrency focus)
In response to the Select Committee on Australia as a technology and financial centre, Finder prepared the following as a supplementary submission to further our original response.
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Submission to Treasury on the telecommunications sectoral assessment for CDR
In this submission we share our consumer research on the telecommunications sector, our view on the relative priority of the telecommunications sector for the CDR and responses to the questions outlined in the Sectoral Assessment Consultation paper.
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Submission on version three of the Consumer Data Right Rules amendments
In this submission, we provide input into this consultation on the proposed changes to the Consumer Data Right (CDR) Rules. Finder continues to be very supportive of the CDR, which we believe will empower Australians to take control of their personal data and use this information to make better financial decisions.
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Submission to the Select Committee on Australia as a technology and financial centre (Third issues paper on cryptocurrency)
Our views on how to make Australia a centre for digital asset innovation
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