Following the closing of the consultation period for ACCC CDR Amendment No. 3, the ACCC have now published the 52 submissions received. The consultation paper contained more than 20 proposals for change including new restricted accreditation classes, ADR to ADR data sharing, sharing CDR data with non-accredited trusted advisors, extension of data sharing to non-individual account types and revision of the consent model to separate “consent to collect” from “consent to use.”
The ACCC received submissions from the full spectrum of participants in the CDR regime including banks, fintechs, energy companies, intermediaries, lawyers, consulting firms, and industry associations amongst others. As expected, there is a wide range of views expressed from those highly supportive and seeking rapid implementation of the proposals to those vehemently opposed and seeking substantial delays in implementation. The one area with widespread support was the extension of data sharing to non-individual accounts such as company and trust accounts. Nearly all the other proposals had divided support. The other notable observation is that 18 responses (including all except one of the banks) pushed back on the timeframe compared to just three that supported the timeframe.
We’ve prepared a summary of a few of the themes that came out of the submissions that may save you much reading. Download a copy here: ACCC consultation submission themes
As always, reach out if you need assistance with Open Banking and the Consumer Data Right.