It is important that the Consumer Data Right appropriately balances efficiency in the transfer of data and the risks to consumers’ privacy. The Privacy Impact Assessment (PIA) is an important step in achieving this balance.
Banks in Australia contribute a significant quantum of total corporate taxes paid in Australia and do not structure their tax affairs through low taxing jurisdictions. They were, therefore, not the obvious target of the recent OECD Base Erosion and Profit Shifting (BEPS) actions.
All Australians should be afforded consistent consumer protection, no matter which credit or financial services provider they choose. For customers at risk of financial hardship, these consumer protections are particularly important.
These regulations would extend the operation of the Design and Distribution Obligations to additional financial products. This submission outlines the ABA's concerns regarding some aspects of this proposal.
The ABA believes that each industry would be better served by a designation tailored to their industry, rather than a broad instrument that is attempting to serve as a template.
ABA members support the intent of the design and distribution obligations (DDO) to assist “consumers select appropriate financial products by requiring issuers and distributors to appropriately market and distribute financial products.”
The ABA believes that having a well-designed reciprocity mechanism within the CDR is key to ensuring customers reap the full benefits of the data that is held regarding them.
ABA members believe that the CDR is a transformative reform and are committed to its success. The CDR has the potential to fuel innovation across the economy and benefit customers through an expanded choice of products and services.
ABA members support the introduction of a consumer data right that will encourage innovation and enable customers to benefit from data sharing while ensuring their privacy is safeguarded.
Appendix available here.
The banking industry supports the intent of the Design and Distribution Obligation (DDO) to assist “consumers select appropriate financial products by requiring issuers and distributors to appropriately market and distribute financial products,” but highlights some concerns around the current draft legislation.
Open Banking will allow customers, at their request, to share their personal information with other financial institutions to allow them to find a better deal on expenses such as electricity bills, telecommunications and other items.
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