With CPA Australia and the Institute of Public Accountants, we reiterated our key concern that the cost of becoming accredited and ongoing compliance places participation in the consumer data right (CDR) beyond the resources of smaller providers.

Recognising that the cost is beyond the resources of small providers, to implement the CDR across non-bank lenders, Treasury has proposed a threshold for mandatory participation. That proposal would capture non-bank lenders with a loan book containing ‘resident loans and finance lease balances of over $400 million’. 

While there is little information available publicly on the size and make-up of the loan books of non-bank lenders, we understand that the majority of providers will be outside of the proposed threshold. As a result, consumers and their trusted advisers will not be able to realise the benefits of transferring data held by both their bank and non-bank lenders across a secure CDR channel.

We thank members for sharing their experiences and concerns and greater detail and alternatives are detailed in the submission.