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
Download PDFTreasury 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.
Download PDFInquiry 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.
Download PDFProposed 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.
Download PDFTreasury consultation on Open Banking Privacy Impact Assessment (PIA)
28 October 2019
The ABA views any changes to the Consumer Data Right (CDR) regime as likely to have a significant impact on the privacy of individuals, thereby warranting reconsideration of the risks and recommendations made by the PIA. This review process is crucial to ensuring that the CDR regime will meet its stated goal of being ‘consumer... Read more »
Download PDFTreasury Consultation on the Digital Platforms Inquiry 2019
19 September 2019
The ABA acknowledges the breadth of the report and supports initiatives to improve privacy protections for banking customers. The ABA makes several points in this submission which warrant further review of recommendations 16-17 with respect to privacy, and also recommendations 20-21 with respect to unfair contract terms and unfair practices, and data portability.
Download PDFOpen Banking designation instrument consultation (2nd round)
11 July 2019
Banking will be the first sector to apply the Consumer Data Right and the ABA supports the participation of more sectors over time to achieve an economy-wide open data regime.
Download PDFComments on the Working Draft of the Consumer Data Standards
21 June 2019
ABA’s submission to Data 61 on Consumer Data Rights Standards 0.9.3 highlighted the need for a number of important functional and security requirements to be embedded in the regime.
Download PDFACCC Draft Consumer Data Rules
10 May 2019
The ACCC’s draft Rules provide a good foundation for the implementation of open banking, however there are a number of areas that have not been addressed in the draft Rules or which require further guidance.
Download PDFConsumer Data Right – Energy Sector
22 March 2019
Banking will be the first sector to apply the CDR and the ABA supports the participation of more sectors over time to achieve an economy-wide open data regime.
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