Open Banking and the Consumer Data Right

While most of Australia has been preoccupied by things such as Covid-19 lock-downs, border closures, which contestant got eliminated from Big Brother/Masterchef, and which federal politician went to an NRL game (and depending on which State you live in), the ACCC has implemented the first phase of the Consumer Data Right regime (aka Open Banking).

The TLDR on this new regulation, which has been several years in the making, can be distilled as follows:

Banks can no longer deny customers the right to share their own customer data with third parties.

So, in essence, if I am a customer of Bank A, and I want to transfer my business to Bank B, I have the right to request Bank A to share relevant information about my account to Bank B – Bank A can no longer hold on to or refuse to share that information.

Why does this matter? Well, a major obstacle to competition, customer choice and product innovation has been the past refusal by banks to allow customers to share their own account information with third party providers – i.e., it has been an impediment to  customer switching (and therefore anti-competitive), and a barrier to entry for new market entrants (and therefore a drag on innovation).

Of course, there are some caveats. Data can only be shared with an accredited data recipient, as a means to protect banking security and preserve data privacy. And at first, the CDR will only apply to debit and credit cards, transaction accounts and deposit accounts. But personal loans and mortgages will follow in a few months. (And the CDR is due to be extended to utilities, telcos and insurance in coming years – going further than even the similar UK Open Banking scheme.)

Although I welcome this new provision, it still feels very limited in application and scope. Even one of the Four Pillar banks couldn’t really articulate what it will actually mean for consumers. They also revealed something of a self-serving and defensive tone in a recent opinion piece:

“Based on experience in other markets, initial take up by consumers is likely to be low due to limited awareness and broader sensitivities around data use.”

Despite our fondness for bank-bashing (and the revelations from the recent Royal Commission), Australians are generally seen as being reluctant to switch providers. Either because it’s too hard (something that the CDR is designed to address), or customers are lazy/complacent. In fact, recent evidence suggests existing customers of the big four banks are even more likely to recommend them.

For FinTechs and challenger brands, the costs of complying with some aspects of the CDR are seen as too onerous, and as such, act as another impediment to competition and innovation. Therefore, we will likely see a number of “trusted” intermediaries who will receive customer data on behalf of third party providers – which will no doubt incur other (hidden?) costs for the consumer.

Full competition will come when consumers can simply instruct their existing bank to plug their data into a product or price comparison service, to identify the best offers out there for similar products. (Better still, why not mandate incumbents to notify their existing customers when they have a better or cheaper product available? A number of times I have queried the rate on an existing product, only to be offered a better deal when I suggested I might take my business elsewhere.)

Recently, my bank unilaterally decided to change the brand of my credit card. Instead of showing initiative by offering to transfer my existing subscriptions and direct debits to the new card, the bank simply told me to notify vendors and service providers myself. If I didn’t request the change of card, why am I being put to the inconvenience of updating all my standing orders?

For real innovation, we need banks and other providers to maintain a unified and single view of customer (not a profile organised by individual products or accounts). Moreover, we need a fully self-sovereign digital ID solution, that truly puts the customer in charge and in control of their own data – by enabling customers to decide who, what, when, why and for how long they share data with third parties. For example, why do I still need 100 points of identity with Bank B if I’m already a client of Bank A?

Finally, rather than simply trying to make money from managing our financial assets, banks and others have an opportunity to ensure we are managing our financial data in a more efficient and customer-centric way.

Next week: Counting the cost of Covid19

 

 

 

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