The Open Banking deadline is nearing for Data Holders, the major banks have already complied with product reference data, whereas non-major ADIs including non-major banks, building societies and credit unions, are well set to comply with these requirements by Oct 1st, 2020. While the compliance timelines for disclosure to accredited data recipients is still a few quarters away (phase-1 for major banks is Oct 2020 and for non-major banks/ADIs/ building society/credit unions is Feb 2021), the financial institutions have also started to define their strategy around being a Data Recipient. We are seeing a varied set of approaches to the Open Banking Consumer Data Right (CDR) compliance requirements. While the smaller financial institutions have primarily focused on compliance aspects, the mid-large tier organisations have taken a strategic approach to prepare themselves for a new world, where the customer and banking data can be potentially accessible to all financial institutions based on customer consent.
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