Will it be required that the ADR who has as a result of accumulating the multiple ADHs data respond to requests or be obligated to provide this accumulated or consolidated data to all of the respective any or all the original ADHs?

In effect if you took a traditional PFM use case would where a consumer can “see all their accounts in one place”, that a consolidated view of transaction data forms the minimum data set that is eligible for reciprocity????

I do appreciate the who question in regard to roles and privacy etc requirements on intermediaries (fully accredited or not0 and provision of data to non-accredited third parties is awaiting determination. But the question would equally apply to any ADR an accredited ADI or other entities that may accumulate multiple ADhs' data.

Under the Rules, reciprocal data holder obligations are turned on for accredited persons that are not ADIs only in respect of CDR data that is:

That is, an accredited non-ADI will not be a data holder of CDR data that was disclosed to it under the CDR Rules.

For example, a non-bank lender who has also been accredited to operate as an ADR could be a DH for CDR data that it generates and holds, but not for CDR data that it holds because it was disclosed to it via the CDR regime.

Note that this response is concerned with non-ADI reciprocity (referred to as second case reciprocity).

To distinguish the difference between validation tools and conformance tools we provide the following clarification.

The DSB has developed two validation tools, these enable participants to validate the schema and syntax provided in the participants endpoint.

By contrast the ACCC is developing a Conformance Test Suite. The CTS will only be made available to participants in the process of onboarding to the CDR ecosystem. For Data Recipients this means you must be accredited. For Data Holders you must be registered in the months immediately preceding your commencement date for consumer data sharing.

We anticipate that data holders would have a complaints handling process in place whereby they categorise CDR consumer complaints they receive in a particular way. For example, they may categorise a CDR consumer complaint to be one that relates to the availability or functionality of the data holder’s consumer dashboard, or one that relates to a data holder not providing all the requisite information when seeking authorisation, or a privacy-related complaint, etc.

However, rather than prescribing the complaint types, the current CDR rules leave it open for the data holder to categorise their CDR complaint types to align with their own complaint handling processes and report on the number of complaints for each complaint types on this basis.

Are all possible fees for a product to be included? There are many different sorts of fees, some of which are highly unlikely for the majority of consumers and could actually confuse them E.g.

That is correct. Voluntary and Required Product Data referred to in the CDR Rues is NOT the same as the fields shown as Mandatory and Optional in the Data Standard.

Required product data are data clusters which must be disclosed by a data holder pursuant to a valid product data request. Voluntary product data are data clusters which may be disclosed by a data holder pursuant to a valid product data request. Clause 3.1 in Schedule 3 of the CDR Rules defines required product data and voluntary product data.

On the other hand, mandatory and optional fields in the data standards are fields which respectively must and may have a non-null value. For example, where the standard has a mandatory field, data holders are required to share that field, but where they do not have the data it must be represented as a default value or an empty value as applicable.

In brief, the data cluster language in the rules relates to the type of data which may or must be disclosed by a data holder; while the mandatory/optional fields language in the standards relates to the parameters for the APIs used to request and disclose CDR data.

Question regarding the term “publicly offered” (clause 1.4 of Schedule 3 to the CDR Rules)

Has any guidance been provided by the ACCC regarding what is intended by the term “publicly offered?” Clarification is sought as to how this term should be interpreted.

Should CDR data holders have regard to whether a product is considered “wholesale” or “retail” when determining if a product is in scope? If so, which definition of “wholesale” or “retail” should be relied upon? Where is this further information provided by the ACCC? We need to be able to evidence our decisions for inclusion/exclusions of products. Some of our product departments are adamant that their products are not intended to be included in CDR, however when interpreting the CDR Rules there is no justification for exclusion.