In the submission, the professional accounting bodies support designating the non-bank lending sector under the CDR but not until existing, significant, shortcomings are addressed.

The CDR has been operational in the banking sector for more than two years and has shown that the cost of compliance for data holders, such as a bank, is beyond the resources of smaller players. For the non-bank sector, this will see only the larger non-bank lenders designated as data holders under the CDR with smaller participants unable to afford to participate. 

For our members, where a consumer is utilising financial products from both large and small non-bank lenders, they may not be able to see their client’s total financial picture through the CDR. Members will need to ask their clients to nominate them as their trusted adviser to their online accounting platform which may only have part of the data. Data provided through the CDR to the online accounting platform will need to be combined with data manually provided for financial products from small non-bank lenders to build a complete picture.

Critically, our members cannot access data directly from the data holder, that is, banks and non-banks. Our members must go through accredited data recipients such as online accounting platforms. Members’ clients will need to nominate their accountant as their trusted adviser and provide a Trusted Adviser disclosure consent. Noting this pathway, we again raise our concern that accredited data recipients, service providers, may decline to accept a nomination of a trusted adviser blocking access to necessary accounting data. 

We consider this a significant shortcoming that could be addressed by limiting the definition of CDR data to only that data transferred from a data holder to an accredited data recipient. For example, from a bank to an online accounting platform. Currently, the definition also captures data directly or indirectly derived from that raw data.  It is this definition that results in accounting data being captured under the CDR.

We will continue to advocate for barriers to accounting data to be removed and for a measured rollout of the CDR to be followed where time is taken to address shortcomings rather than expanding into new industry sectors.