Joint submission to the Senate inquiry on action initiation in the CDR
Our key concern with the Bill to effect action initiation is how consumers will be able to continue to instruct our members, their trusted advisers, to complete actions on their behalf.
In brief
- The Bill does not talk to trusted advisers and if they will need to become accredited
- The Bill seeks to create a myriad of accreditation levels dependent on the action being instructed
- We call for engagement and education of consumers so they can gain the intended benefits of the system
The Senate Economics Legislation Committee has been charged to inquire into Treasury Laws Amendment (Consumer Data Right) Bill 2022 (the Bill) before parliament seeking to implement action initiation in the consumer data right (CDR).
While the joint accounting bodies support action initiation we consider the existing system must be stabilized before adding more functionality. Even so, we provided feedback on behalf of our collective members on key issues with the Bill as proposed.
Trusted advisers
As our members are held accountable by their respective professional bodies and must comply with a broad range of legislation, they are not required to become accredited in the CDR system. CDR Rule 1.10C(2) recognises our members as trusted advisers within the CDR system.
The Bill makes no reference to trusted advisers and proposes that persons transmitting instructions on behalf of consumers must be accredited action initiators. This appears to indicate that our members will need to become accredited in the CDR to continue to offer services such as managing payments on behalf of their clients.
On attending the first workshop on building how this Bill might be implemented on 7 March 2023, we raised the omission of trusted advisers. It was indicated that how trusted advisers can participate in action initiation would be dealt with in the rules, not the Bill.
Complexity
The Bill seeks to allow the Minister to add levels of accreditation for each type of action. So an accredited action initiator may be able to advise a change of address but not close an account. As any instruction must be with the consent of a consumer, and a consumer will trust one person to initiate actions on their behalf, we call for accreditation to be that a person can, or cannot, initiate actions.
Engagement and education
We support calls for government resources to be directed towards the engagement and education of consumers before more sectors or more functionality is added to the CDR. Without consumer engagement, the benefits of the CDR will not be able to be realized.
The submission provides greater detail on our key concerns and we thank our collective members for taking time to provide input to this consultation.
Trusted Advisers in the CDR
A fact sheet that provides an overview on who a trusted adviser is in the CDR and what to expect if you are nominated.
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