6 July 2021
The ABA and members are supportive of APRA’s move to data collection based on a concept-dimension data model. ABA members broadly support the approach APRA has outlined in their letter of June 8. The collective view of ABA members is that a successful implementation will result from sufficient time being given to develop a full taxonomy, and that this is finalised well in advance of the first submission date so banks can build the infrastructure to support the data model. ABA members have concerns with the overlap of two new reporting requirements (the tactical solution and the incremental collections), the granular level of detail required for the strategic solution (especially for the lower risk portfolios) and the timing by which each reporting needs to be provided.Download PDF
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
The proposed solution put forward in DP-183 refers to a principle of ‘Purpose-based consent’. Purpose Based Consents are a way to encode all of the required dimensions and granularity for a specific use case. Unfortunately, this specificity leads to a consequent loss in flexibility. DP-183 highlights read-only use cases which are not currently covered; however, the same principles and requirements are even stronger to enable read-write access.