ConsumerDataStandardsAustralia / standards-maintenance

This repository houses the interactions, consultations and work management to support the maintenance of baselined components of the Consumer Data Right API Standards and Information Security profile.
41 stars 9 forks source link

Product Ref Data - leeway within standards makes fee comparison difficult #285

Open aj-mozo opened 3 years ago

aj-mozo commented 3 years ago

The standards were designed in a way that gives data holders great flexibility. We believe too much flexibility! In the case of fees, this creates problems when trying to compare things.

  1. In many cases, important information about the nature of things is relegated to free text fields such as 'name' fields or 'additionalInformation' fields. While we can work with some ambiguity in Upfront and Periodic Fees, if there is no consistency in the labelling of Event-based fees then there is little hope of comparing apples with apples.

  2. If an Event fee is not mentioned, does that mean that the product has the feature but charges no fee, or that the product does not have the feature, or that the data is incomplete? We have seen a range of different approaches between banks, none the same as each other.

nils-work commented 1 year ago

Hi @aj-mozo

Re: the following -

  1. In many cases, important information about the nature of things is relegated to free text fields such as 'name' fields or 'additionalInformation' fields. While we can work with some ambiguity in Upfront and Periodic Fees, if there is no consistency in the labelling of Event-based fees then there is little hope of comparing apples with apples.

While fee names and associated free-text values are at the discretion of data holders, there may be an opportunity to define more granular classifications for EVENT or VARIABLE fees if that would improve the utility of the data.

EVENT fees are currently defined as: A fee in relation to a particular event (e.g. ordering a new card, viewing a balance or stopping a cheque)

After reviewing a sample from the published product reference data, there appears to be some common themes, including:

The published VARIABLE fees have similar themes, and that data may also be improved by further classification.

Are you able to provide examples of the most important or common fee types that are difficult to group and/or compare currently?


Re: the following -

  1. If an Event fee is not mentioned, does that mean that the product has the feature but charges no fee, or that the product does not have the feature, or that the data is incomplete? We have seen a range of different approaches between banks, none the same as each other.

There may not always be an association between features and fees, but the expectation is that all fees applicable to a product are defined in responses.

If fee amounts or rates are not defined, the response may be non-compliant depending on the feeType specified; as the current description states: One of amount, balanceRate, transactionRate and accruedRate is mandatory unless the feeType "VARIABLE" is supplied.

nils-work commented 1 year ago

Hi @aj-mozo The DSB is proposing this issue be addressed as part of Decision Proposal 306. Any feedback would be welcome.

af-stayorgo commented 11 months ago

I'd recommend a feeType for Foreign Currency Conversion Fees (which are charged on most Credit and Debit Cards). This is one of the most material fees on these products. Something like TRANSACTION_FX

Its worth noting that some banks currently category FX fees as TRANSACTION, others PURCHASE, and others EVENT

aj-mozo commented 11 months ago

Sorry @nils-work I missed this discussion back in June. I see now that then deadline is 11 August. I'll try my best to respond in time.

aj-mozo commented 10 months ago

Response now posted in https://github.com/ConsumerDataStandardsAustralia/standards/issues/306

nils-work commented 7 months ago

Hi @aj-mozo, @af-stayorgo

Changes to the fee structure to provide additional types and detail are now specified in the Candidate Standards for Banking.

The changes are intended to address the issues and limitations described in comments: 1, 2, 3.

Consultation on making the Candidate Standards binding is now open through Decision Proposal 338.