With CPA Australia and the Institute of Public Accountants, we supported the inclusion on non-bank lenders (NBLs) in the consumer data right.

Cost of accreditation

The inclusion should enable consumers to utilise their data across the breadth of Australia’s lending system. Yet, the proposed inclusion will only mandate participation by very large and large non-bank lenders. This reflects Treasury's concerns that the cost of accreditation is outside the resources of smaller businesses though Treasury also acknowledged that the NBL sector has a long tail of small businesses. We reiterated our concern that the cost of accreditation provides a competitive advantage to large participants rather than driving competition or increasing benefits for consumers.

We again called on Treasury to work with industry and seek innovative alternatives, such as a government data holder into which smaller players can plug into, to mitigate the prohibitive cost of accreditation and compliance in the CDR.

Narrowing the scope of CDR data

We are also expressed concerned with the proposed change, reducing from 7 years to 2 years, the mandatory period for a bank or NBL data holder to provide a consumers’ historical data. It appears this is based on minimising the impact on large data holders rather than how consumers would seek to use their historical data or when the professionals that service consumers require that historical data. 

We raised that such a change appears contrary to, and will not achieve, Treasury’s stated aims of increasing the availability of data and helping consumers to better understand and manage their finances.

Conclusion

Design amendments and expanding the CDR to other sectors of the economy, a digital infrastructure platform funded by and intended to benefit consumers, should not be determined by the depth of resources of a potential data holders.