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

 

 

 

Blipverts vs the Attention Economy

There’s a scene in Nicolas Roeg’s 1976 film, “The Man Who Fell To Earth”, where David Bowie’s character sits watching a bank of TV screens, each tuned to a different station. At the same time he is channel surfing – either because his alien powers allow him to absorb multiple, simultaneous inputs, or because his experience of ennui on Earth leads him to seek more and more stimulus. Obviously a metaphor for the attention economy, long before such a term existed.

Watching the alien watching us… Image sourced from Flicker

At the time in the UK, we only had three TV channels to choose from, so the notion of 12 or more seemed exotic, even other worldly. And of those three channels, only one carried advertising. Much the same situation existed in British radio, with only one or two commercial networks, alongside the dominant BBC. So we had relatively little exposure to adverts, brand sponsorship or paid content in our broadcast media. (Mind you, this was still the era when tobacco companies could plaster their logos all over sporting events…)

For all its limitations, there were several virtues to this model. First, advertising airtime was at a premium (thanks to the broadcast content ratios), and ad spend was concentrated – so adverts really had to grab your attention. (Is it any wonder that so many successful film directors cut their teeth on commercials?) Second, this built-in monopoly often meant bigger TV production budgets, more variety of content and better quality programming on free-to-air networks than we typically see today with the over-reliance on so-called reality TV. Third, with less viewing choice, there was a greater shared experience among audiences – and more communal connection because we could talk about similar things.

Then along came cable and satellite networks, bringing more choice (and more advertising), but not necessarily better quality content. In fact, with TV advertising budgets spread more thinly, it’s not surprising that programming suffered. Networks had to compete for our attention, and they funded this by bombarding us with more ads and more paid content. (And this is before we even get to the internet age and time-shift, streaming and multicast platforms…)

Despite the increased viewing choices, broadcasting became narrow-casting – smaller and more fractured viewership, with programming appealing to niche audiences. Meanwhile, in the mid-80s (and soon after the launch of MTV), “Max Headroom” is credited with coining the term “blipvert”, meaning a very, very short (almost subliminal) television commercial. Although designed as a narrative device in the Max Headroom story, the blipvert can be seen as either a test of creativity (how to get your message across in minimal time); or a subversive propaganda technique (nefarious elements trying to sabotage your thinking through subtle suggestion and infiltration).

Which is essentially where we are in the attention economy. Audiences are increasingly disparate, and the battle for eyeballs (and minds) is being fought out across multiple devices, multiple screens, and multiple formats. In our search for more stimulation, and unless we are willing to pay for premium services and/or an ad-free experience, we are having to endure more ads that pop-up during our YouTube viewing, Spotify streaming or internet browsing. As a result, brands are trying to grab our attention, at increasing frequency, and for shorter, yet more rapid and intensive periods. (Even Words With Friends is offering in-game tokens in return for watching sponsored content.)

Some consumers are responding with ad-blockers, or by dropping their use of social media altogether; or they want payment for their valuable time. I think we are generally over the notion of giving away our personal data in return for some “free” services – the price in terms of intrusions upon our privacy is no longer worth paying. So, brands are having to try harder to capture our attention, and they need to personalize their message to make it seem relevant and worthy of our time – provided we are willing to let them know enough about our preferences, location, demographics, etc. so that they can serve up relevant and engaging content to each and every “audience of one”. And brands also want proof that the ads they have paid for have been seen by the people they intended to reach.

This delicate trade-off (between privacy, personalisation and payment) is one reason why the attention economy is seen as a prime use case for Blockchain and cryptocurrency: consumers can retain anonymity, while still sharing selected personal information (which they own and control) with whom they wish, when they wish, for as long as they wish, and they can even get paid to access relevant content; brands can receive confirmation that the personalised content they have paid for has been consumed by the people they intended to see it; and distributed ledgers can maintain a record of account and send/receive payments via smart contracts and digital wallets when and where the relevant transactions have taken place.

Next week: Jump-cut videos vs Slow TV

 

 

 

 

Intersekt Festival 2018

This year’s Intersekt Festival, held in Melbourne last month, was put together in quite challenging circumstances, given some of the recent events within key industry body FinTech Australia, the primary event host. It was a credit to all involved.

Not surprisingly, given some of the regulatory and industry changes underway in Australia, the key themes included: Open Banking and access to data: Trust in the banking and financial services sector (thanks to the Royal Commission, and the APRA report on the CBA); Data Privacy; Payments and the NPP; Comprehensive Credit Reporting and predatory lending practices; and Equity Crowdfunding. And of course, a little bit about Blockchain, Cryptocurrencies and Security Tokens.

There was a lot of discussion on “Trust”, especially in the age of Uber and Airbnb – how have these marketplaces managed to earn so much public and consumer trust in such a relatively short time? Yet as consumers, we obsess about Open Banking vs Data Privacy,  while banks themselves appear to be more infatuated with their Net Promoter Score…. whereas “Trust” is clearly a huge issue. In the case of the banks and the fall out from the Royal Commission, there was a discussion about whether our key financial institutions have come close to losing their social license to operate.

Meanwhile, with the prospect of self-sovereign digital identity becoming a practical reality (fuelled by blockchain, decentralisation and trust-less protocols and standards), there is a demand for cross-functional  (and cross-border) solutions for KYC/AML processing and identity management. But a lack of mutual regulatory recognition or harmonization (as opposed to “mere” industry standards) plus a diversity of business models confounds regulatory harmony, often within a single jurisdiction, let alone across multiple markets.

When it comes to payments and the NPP, it’s clear that regulation lags technology. For example, despite the existence of a (complex and somewhat uncertain) licensing regime for purchased payment facilities, APRA has only licensed one such PPF – PayPal. As former ASIC Chairman, Greg Medcraft once observed, by the time the NPP is fully operational, Blockchain will have gotten there long beforehand. And given the preponderance of stored value cards, digital wallets, peer-to-peer crypto exchanges, and multiple overseas and cross-border mobile payment apps, the respective regulatory roles of RBA, APRA, AUSTRAC, ATO and ASIC need to be clearly defined and set out.

On the topic of data protection and “big data”, there was a lot of discussion about getting the balance right between privacy and innovation. One the one hand, industry incumbents should not be allowed to use their market dominance to resist open banking and stifle the emergence of neo-banks; but on the other, there is a need to shelter the forthcoming consumer data right (CDR) from potential abuse like predatory lending (e.g., not simply define the CDR standards by reference to existing banking products and services) – mainly because the CDR is designed to empower consumers (not embolden the industry), and it is designed to be sector neutral (i.e., equally applicable to utilities, ISPs, telcos, insurance firms).

Other topics included SME lending, where new, tech-driven providers are not only originating new loans, but also refinancing existing businesses as the big 4 banks are seen to withdraw from this market; home loans (where technology is driving new loan origination, funding and distribution models); social impact (“FinTech for good”); equity crowdfunding (and the role of STOs); insurance (creating a decentralised market place) and Superannuation (which prompted perhaps the most contentious panel discussion – more on that to come!).

If there were any criticisms of the conference, based on local and overseas delegates I spoke to, they related to the length (was there enough content to sustain nearly 3 days?); the need for clearer roles and participation by the major and regional banks; the absence of investors (despite a speed-dating matching event….); and a desire to see a broader range of speakers and panelists (too many of the “usual suspects”?).

Next week: The Future of Super