CDR data quality issues targeted in new consultation

The competition watchdog is calling on stakeholders to provide feedback on their views of issues that may be resulting in poor quality data emerging from the consumer data right (CDR) and steps that could be taken to address these issues from a “compliance or enforcement perspective”.

The CDR has already been rolled out in the banking sector, with authorised deposit-taking institutions (ADIs) required to disclose standardised product data and consumer data.

However, the ACCC has noted that data quality is limiting wider adoption of the system.

For example, the ACCC said it has observed “a range of data quality issues” from data holders, including, in some cases, inaccurate interest rates for mortgages or the omission of relevant fees.

Other issues in data being served up by data holders include technical errors, for example, using non-conformant values (the use of a number when a string is required) or product information URIs that do not lead to a valid web page.

“All of these issues impact users of PRD [product reference data], who are unable to access the data in the manner or to the quality required under the relevant rules,” the ACCC said.

“Users also expend time and resources examining PRD and raising issues with data holders and the ACCC. Consumers are also harmed, as they cannot benefit from the services offered by the user.”

The competition watchdog suggested that a key cause of these data quality issues was failures by the data holders (i.e. the lenders) to maintain PRD alongside changes to their website and disclosure documents. 

For example, when a change to a mortgage interest rate occurs, each data holder “should have robust internal processes and controls to ensure that their website and disclosure documents are updated to reflect the new rate(s),” the ACCC outlined.

“We have identified cases where similar robust processes and controls had not been implemented for PRD by several data holders,” the ACCC said.

The competition commission also flagged that while it requires data holders to implement appropriate processes and controls to do so, some data holders had told them that “they did not sufficiently understand the requirements of the rules and standards”.

“This may cause the data holder to load incorrect data types or consider that a field is optional when it holds the relevant data,” it said.

Given the issues and the fact that the CDR ecosystem is maturing (for example, it is being rolled out to the energy sector at the moment), the ACCC warned that the consumer impact of poor data quality would only increase as the size and scale of the ecosystem does.

As such, it is asking stakeholders to provide feedback on the extent of the issue and whether the ACCC should “change its approach” to compliance and enforcement to address it.

Feedback is being sought on:

• The experience of data users and data holders in addressing product reference data quality issues 
• The ACCC’s product reference data compliance program

Stakeholders are being asked to consider:

• The harm suffered by users of PRD as a result of poor data quality
• The relative harm of the various kinds of data quality issue
• How the ACCC might define and measure an acceptable level of data quality
• Any experiences relating to attempting to raise and resolve PRD data quality issues with data holders or the ACCC
• Whether the ACCC’s observations above regarding the cause of PRD-related data quality issues are correct
• Whether the ACCC should change its approach to addressing PRD data quality compliance
• Whether there are operational reasons that PRD is less likely to be updated regularly than a data holder’s other sources of information.

Feedback can be submitted via the ACCC Consultation Hub by 21 November 2022. 

[Related: Expanded CDR to give customers more control]