The Consumer Data Right has shortcomings, according to NAB, that inhibit rather than support innovation.
Although the big bank saw “great potential and customer value in the CDR,” it noted in its contribution to the CDR legislative review in May [pdf] that the present version may be altered to enhance its innovation.
NAB remarked, “We are dedicated to continue to develop CDR-powered products and services, for the benefit of our present and future clients. We see enormous potential and consumer benefits in the CDR.
However, there are other elements of the present CDR settings and standards that have made it more difficult for us to develop quickly and successfully market use cases.
The bank specifically called out technical standards misunderstanding as well as difficulties with data timeliness and correctness.
When attempting to clarify certain technical standards in the past, the NAB remarked that the multiplicity of regulatory entities and agencies participating in CDR oversight “has been the source of some uncertainty and delay.”
“While the CDR Support Portal, which is hosted on ZenDesk, may provide a conflicting or slightly different interpretation, guidelines from one party may infer one meaning.
The adoption of new CDR use cases and consumer innovation can be hampered by delays in checking the accuracy of the information.
It would be useful for data owners and recipients to have one reliable source they could consult for technical standards.
In the past, changes to CDR regulations “created some issues for NAB,” including go-live deadlines that fell during a new fiscal year.
It said that because the CDR standards are not routinely updated, “data holders and recipients are less able to effectively plan and prioritise their CDR investments and resources.”
It demanded timed amendments so that NAB could prepare in advance and “give appropriate response to these proposed improvements.”
The NAB concluded, “We feel that it is necessary to clarify and comprehend the continuous overlap between CDR and digital identity. We do not see the need for statutory modifications within CDR for digital identification.”
Since not all digital identification use cases will entail data exchange or have a connection to CDR use cases, each system must maintain its own independence.
According to the bank, “CDR will, however, become a very significant user of an interoperable digital identity ecosystem, generating strong consumer choice and a more efficient approach to client verification and authentication requirements under CDR.”
NAB also wants the expansion of the CDR to take into account digital platforms.
