The implementation of the Consumer Data Right (CDR) in the banking sector over the past 18 months has revealed some critical flaws such as incorrect data being transmitted across CDR channels.

Our joint submission calls for a pause in the expansion of the CDR regime until data is gathered from all participants in the CDR in banking to determine what is working, what requires adjustment and any fatal flaws. This data can also be used to validate or disprove the many assumptions that form the basis of the sectorial assessment of non-bank lending.

Our joint submission does raise issues for consideration by the Treasury should their assessment conclude it is appropriate to expand the CDR regime to the non-bank lending sector. Key among those issues are:

• for potential data holders’ - cost and time to comply, reducing competition;
• for our members – the difficulties in seeing a client’s total loan obligations; and
• for consumers – receiving multiple, generic, product offerings leading to a cognitive overload.

We consider consolidation critical as, where fatal flaws are identified, adjustments to the CDR legislation and implementation process need only impact the banking and energy sectors. The continued expansion of the CDR without addressing existing issues will increase the potential for financial harm and damage public trust in the CDR regime.

Thank you to our members, and members of the other professional accounting bodies, for your contributions to this submission.