WestpacOpenBanking
commented
3 years ago Westpac welcomes the opportunity to comment on the Display of Data Holder Brands on the Public CDR Register #179. We have the following comments on the proposal posed by the ACCC:
1. Brands and products issued by a data holder
The ACCC’s proposal suggests the phrase “The brands and products below are issued by ABC Bank Pty Ltd” as a precursor to listing the brands under a data holder.
Westpac has several brands, such as St George, Bank of Melbourne and RAMS, where the brand and product are issued by Westpac Banking Corporation. It is accurate to list them under Westpac’s data holder registration as proposed in the proposal.
The ACCC’s proposed phrasing is not accurate for white label arrangements where the financial products are issued by the data holder but the brands distributing the products belong to third parties unrelated to the data holder. Moreover, in white labelled arrangements, it is entirely possible for a third-party partner brand to white label multiple financial products from different ADIs. Westpac would like to propose distinguishing between home brands and white labelled product arrangements with non-ADI brand owners.
We would like to propose the current sub-heading “Brands” is replaced with “ABC Bank Pty Ltd brands” and a new sub-heading “ABC Bank Pty Ltd external brand arrangements” is added.
In this new category called “ABC Bank Pty Ltd external brand arrangements”, have the following introductory sentence: External brand arrangements for products issued by ABC Bank Pty Ltd. This would enable participants in the CDR to immediately identify which products are issued under a home brand or which products are distributed under white label arrangements.
2. Allowing different contact details to be displayed
The ACCC’s proposal contemplates brands may use different Uris for the Consumer Data Right Policy.
In a similar vein, we would like to flag that brands, particularly the white labelled brand arrangements, may use a different servicing model and might have a different website, email address or address for service. We request that these are additional optional fields for the white labelled brand arrangement entries.
If these fields are incomplete, then the details listed under the data holder entry would apply to the white labelled brand arrangements.
jakubvozarik
The ACCC will make a minor change to the Data Holder Page, available once a Data Holder has been selected on the CDR Register find-a-provider page.
The proposed change is shown in this sample.
This change is anticipated to alert visitors to the page that the Brands listed may not necessarily be owned by the Data Holder. This change has emerged through ACCC’s work with ADIs to on-board white labelled Brands by the 1 July 2021 obligation date.
The ACCC is interested in the views of Data Holders to determine the best way to display important details about the Brands a Data Holder on-boards onto the CDR Register.
Due to the important priorities of the second tranche of ADIs on-boarding to the Banking sector, this ticket will remain open as a place holder for discussion on this topic for the foreseeable future.