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Response to Senate Select Committee on Fintech and RegTech

17 December 2020

The ABA urges the development of an overarching strategy for data and information privacy to underpin the transition to a digital economy and provide a consistent framework for future reforms. Co-ordination will be critical to achieve the intended outcomes. The data economy has the real and exciting potential to generate jobs and opportunities for servicing the needs of all Australians. Technology and digital capability are the mechanisms by which banking will continue to develop.

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ABA Commentary on Proposed Expansions to CDR Rules 2020

29 October 2020

The ABA does not support the proposed segmentation of banking data into high, medium, and low risk. The speed at which the Australian Competition and Consumer Commission (ACCC) intends to finalise the draft Rules is concerning, especially given risks which have been raised in the Privacy Impact Assessment (PIA). The ABA does not believe that it is possible for the ACCC to mitigate the risks raised in the PIA and concurrently resolve the questions and concerns raised in this submission by December 2020. The ABA is particularly concerned with negative impacts the speed of implementation will have on smaller banks. The ABA is also concerned that consumers may be overwhelmed with the level of complexity in the proposed Rules which may make them less likely to participate in the CDR. Trust in the security of the CDR is paramount to its success. The ABA urges the ACCC to reconsider the intention to finalise these rules by December 2020 and seeks a meeting with the ACCC to discuss the concerns raised in this submission

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Consumer Data Right On-boarding – Feedback

23 October 2020

The ABA believes that this process flow will benefit from an additional step ‘Testing’. The ABA recommends that testing stages which are aligned to those documented in the ACCC’s ‘Assurance Strategy Consumer Data Right’ (28/8/19) should be implemented for all data holders.

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Treasury Laws Amendment Bill 2020: CDR Consultation

19 October 2020

The ABA supports the Government’s intention to centralise design and rule making functions and encourages further centralisation of other critical functions of the CDR.

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Inquiry into Future Directions for the Consumer Data Right

21 May 2020

The ABA supports the ongoing development and expansion of the Consumer Data Right (CDR). As the first sector to launch with Open Banking, the banking industry has contributed significantly to operationalising the CDR vision through expertise within the sector as well as providing the Open Banking systems through which the first consumer data will flow in the CDR.

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Proposed timetable for participation of non-major ADIs in the CDR

3 March 2020

In discussions between the ACCC, ABA and non-major banks on 13 February 2020, the ABA and members unanimously expressed their concern for the 1 February 2021 launch for phase 1 products. Members reconfirmed the importance for maintaining a 12-month implementation timeline from the major banks’ launch date.

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ARS 115 Standardised measurement approach to operational risk

24 February 2020

The ABA asks APRA to consider the ARS 115 consistency with the accounting standard and consistency with current data consultation outcomes.

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ACCC CDR consultation on how to best facilitate participation of third party service providers

7 February 2020

The ABA supports the inclusion of TPSPs within the CDR regime. TPSPs could play an important role in the efficient and cost-effective provision of services to consumers. The entry of TPSPs, with appropriate governance and consumer protections, will enable the development of a richer and more vibrant ecosystem.

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Draft Consumer Data Right Privacy Safeguard Guidelines Consultation

27 November 2019

The ABA recommends that the PS GL undergo a second consultation twelve months after the launch of the CDR regime., and the ABA recommends that the OAIC institutes a process for annual review.

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