Noting Paper 348 - Use Case Enablement Experiment: Account Origination

[CX-DSB]

Context

In response to community feedback, the DSB commenced ‘experiments’ to explore speculative CDR propositions, especially in the context of actions being considered in the CDR. A simple bank account origination use case was the first experiment subject used to test and explore the CDR’s capabilities.

A report has been finalised that discusses the findings and insights generated through a government collaboration with industry, which explored how the CDR might enable mortgage refinancing.

The DSB led this experiment with the participation of accredited data recipients (ADRs), data holders (DHs), and LIXI. The experiment focused on how the CDR could enable new-to-bank customers to submit a loan product application and facilitate mortgage refinancing. A video outlining the fictional offering can be viewed online here.

To assess the most compelling opportunities for the CDR to enable this use case, the experiment group collaborated on end-to-end consumer journeys and consent designs that were tested in Consumer Experience (CX) research, and co-developed experimental standards to facilitate application population and data disclosure.

The experiment tested 4 hypotheses and identified several ways that the CDR could enable this use case. These findings included that the use case could be enabled with existing consent mechanisms and the leveraging of existing LIXI standards, with additional opportunities including further streamlining with hypothetical CDR enhancements that could include a consent uplift, a ‘warm lead’ CDR action, and voluntary CDR standards.

Report

The report has now been published and can be found below:
Simple Account Origination Experiment Report.pdf

Pages 1-12 contain an abridged version of the report. An unabridged version of the report is provided from page 13, along with other appendices relating to the experiment.

Open for Comment

While this is not a formal consultation, the DSB expects next steps to include further consultation on experimental and voluntary standards to facilitate this use case. The community are invited to provide feedback on this report, particularly the identified opportunities and next steps.

This thread will remain open for comments until COB Friday 12 July 2024 Friday 19 July 2024.

The community is also invited to propose further experiments in the DSB's new experiment repository.

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Edit: Report Published: 14 June 2024
Edit: Feedback window extended to Friday 19 July 2024
Edit: Feedback closed Friday 19 July 2024

[CX-DSB]

The report has now been published and can be found in the original post.

This thread will remain open for comments until COB Friday 12 July 2024.

The community is also invited to propose further experiments in the DSB's new experiment repository.

[darrenbooth]

There is a massive assumption at the start that does not seem to always hold up under the current Rules: That the lender would either become a data holder of the data, or would handle data according to non-CDR protections, such as the Privacy Act and in line with their existing lending obligations.
Regarding this assumption, this is currently dependent on Rule 7.2(2)(b) “the CDR consumer has acquired a product from the person”. Acquire means to buy or obtain (common dictionary definition). At the point of the application, no product has been acquired, this seems to only occur once the application has been successful (noting that it could also be interpreted that the CDR consumer could have acquired another existing product previously from the person, which could result in all interactions with the CDR consumer falling under Rule 7.2). So for the use case to work, what changes are being proposed to address compliance obligations for the lender up to the point that the application is successful (i.e. the product has been acquired), and for compliance obligations for pending, failed or withdrawn applications, whereby a product is not acquired? I note RG5, but this does not seem to go far enough to fully enable this use case.

[darrenbooth]

Also noting the assumption that this use case only works for bank data holders, any change to the Rules to enable the use case should also consider how the use case can be applied to non-bank lenders. Non-bank lenders should not be put in a position of competitive disadvantage due to changes to Rule 7.2. This seems to go against the original objective of CDR, which was to create competition.

[CX-DSB]

Thank you @darrenbooth for your comments. We will respond following some internal engagement which will also consider the incoming draft rules consultation content.

[CX-DSB]

The feedback window for this report has been extended until COB Friday 19 July 2024.