23 July 2021
Incorporating responses to Data Standards Body consultation: Decision Proposals 182.
CDR Information Security Recommendations
Ensuring that the appropriate technical standards for information security are put in place to enable the CDR is vital. These technical standards need to accommodate both an extension in scope for open banking, as well as setting the template for expansion of the CDR to other sectors of the economy.
This paper makes the following recommendations:
1. Adopt FAPI 2.0 for future best practice
2. Ensure and Preserve Interoperability
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The ABA suggests that in finalising the proposal an updated analysis of the existing Scheme regime would be of benefit to consider current market practices which may have evolved since the Productivity Commission’s 2015 report ‘Business Set-up, Transfer and Closure’.
The ABA supports the proposed amendments being considered by Parliament expeditiously to give industry ample time to implement changes to comply with the reforms. As such the ABA strongly supports the proposed bill being finalised and introduced into Parliament as soon as practicable.
However, the ABA also asks Treasury to consider making a number of further amendments and clarifying a small number of matters in the Bill. Doing so would enhance the effectiveness and benefit of the Bill for industry.
The ABA supports recently enacted legislative changes to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) that require reporting entities to verify their customers’ identity before providing designated services.
The ABA also supports the provision for special circumstances that justify carrying out applicable customer identification procedures (ACIP) after the commencement of a designated service. While generally in support of this Chapter, the ABA seeks additional clarity over the scope of the proposed special circumstances, particularly in relation to opening an account and the initial deposit.
We also support broader changes proposed to Chapters 21 and 48 of the rules. The submission puts forward a proposal regarding Chapter 80 on the basis that there may be unintended consequences with the current drafting, such as exempting a broader range of activities.
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