Ensuring data quality in open banking’s product reference data
Key insights and next steps from the ACCC’s targeted compliance review.
In September 2024, the Australian Competition and Consumer Commission (ACCC) published the results of a targeted compliance review of Product Reference Data (PRD) in the open banking sector.
PRD must be made available via API by all of Australia’s banks, as part of their obligations under the Consumer Data Right (CDR).
Key observations from the ACCC’s targeted review of 20 banking sector data holders shed light on crucial aspects of data management practices.
By categorising those observations, and offering recommendations, the ACCC aims to improve data holders' understanding of their obligations and enhance compliance within the banking sector.
In this blog, we recap some background to the review and unpack its key findings, insights and next steps.
Role of the ACCC as CDR’s regulator
In April 2023, the ACCC put PRD quality on its list of CDR enforcement priorities.
The ACCC reviews PRD to ensure that banks – as data holders – meet their obligations under the CDR Rules and Standards.
The CDR Rules are proclaimed by the Minister on the advice of Treasury and the Consumer Data Standards are set by the Data Standards Body.
The ACCC uses a variety of methods to monitor PRD compliance, including:
- automated schema validation
- manual reviews where staff compare PRD against information on the data holder's website
- raising issues directly with data holders
- consulting with stakeholders such as the Data Standards Body (DSB), Treasury and the Office of the Australian Information Commissioner.
By taking action to improve PRD quality, the ACCC is supporting CDR’s objectives of consumer choice, convenience and confidence.
Purpose and methodology of the ACCC’s targeted review
The ACCC’s targeted compliance review assessed the quality of PRD disclosed by data holders, focusing on products such as home loans, savings accounts and credit cards.
The purpose was to check whether the banks – as data holders – are compliant with the CDR Rules and Standards by providing accurate, up-to-date and complete data.
The review involved 20 banking sector data holders who completed a questionnaire and a self-assessment.
The ACCC then analysed the responses to understand compliance practices and identify concerns.
Findings
Here’s a summary snapshot of the ACCC’s findings:
- 11 data holders identified issues and committed to remediation.
- Additional compliance concerns were observed for 10 data holders.
- Common issues included not following payload conventions and disclosing inaccurate or incomplete data.
Home loans and lending rates information
Data holders self-assessed the PRD information they disclose for all home loan products offered by each relevant brand.
The information self-assessed correlates to requirements of the ‘BankingProductV4’ and ‘BankingProductLendingRateV2’ schema specified in the CDR Standards.
The ACCC found inconsistent approaches to disclosure, which in turn poses challenges for data users.
Specifically with respect to home loan product data, the review found discrepancies between home loan product descriptions and data holder websites or disclosure documents.
Here at Stryd, we found the same problems when we did the research for our detailed white paper – Democratising Data for the Good of Consumers – which we published in April this year.
Consistent with Stryd’s white paper findings, the ACCC also discovered issues with loan interest rates. Those issues included outdated lending rates and inaccurate additional information.
Data quality issues with lending rates information disclosed by data holders remains one of the ACCC’s priority focus areas for CDR compliance activity.
The most common issue observed by the ACCC with home loan product data is the description not aligning with a data holder’s website or relevant disclosure document.
Data holders are also taking inconsistent approaches to the disclosure of home loan products.
For example, some data holders update PRD for a small number of products at a time and they use structured fields to communicate those relevant variations.
Conversely, other data holders update their entire PRD disclosures for all their home loan products when the underlying variations are only relevant to a small number of products that are currently being featured on that data holder’s website.
While not all instances of such inconsistency give rise to compliance concerns as to the accuracy of the data disclosed, it presents challenges for PRD users who consume that home loan data as a basis for a consumer-facing product or service.
As lead software engineer Eugene Scully recently wrote in our blog, data quality concerns that impinge on interest rates are a negative issue for the usability of PRD.
Stryd can remediate many data quality issues, however, it’s dependent on the data type and whether we can find the correct information elsewhere.
In the absence of a reliable workaround for a key input like interest rate, Stryd has no option other than to exclude that lender’s product from our repository.
Fees
Some data holders failed to disclose all relevant fees, including those with a $0 charge or unspecified amounts.
Accuracy issues included misalignment of fee names, types, amounts and additional information.
Updating and monitoring processes
The ACCC found that data holders are using various levels of automation and manual processes to update PRD.
Effective practices include documented processes, automation, concurrent updates and quality assurance including monitoring.
Monitoring may involve regular reviews, spot checks, API testing and responding to user feedback.
Next steps for the ACCC, data holders and data users
The ACCC will continue to monitor compliance using automated schema validation and manual reviews. It will also address issues directly with data holders and review and update guidance as necessary to improve data quality.
The ACCC’s compliance review highlights the importance of accurate, up-to-date and complete product reference data in the banking sector.
By addressing the identified issues and implementing effective processes, data holders can enhance the quality of their data and support CDR’s objectives of consumer choice, convenience and confidence.
PRD users can report issues to the ACCC by emailing ACCC-CDR@accc.gov.au and/or raise a support ticket with the DSB.
Stryd has done the heavy lifting for you!
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The Stryd Product Repository has been built for mortgage loans using PRD information, supported by our fintech platform’s automated business rules, so you can have a high level of confidence.
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