Great question!
Because when building the CDR, concerns were raised about user's privacy.
Which seems illogical when the CDR contains the following data points:
- BSB
- Account Number
- First Name
- Surname
- Mailing Address
Yes. You read that correctly. Despite the fact that the consumer's mailing address is a mandatory data point, including the security address could be a "privacy concern".
Furthermore, millions of loans are secured by an investment property making the argument even more problematic.
We believe the entire argument is flawed and we have raised proposition #709 with the Data Standards Body.
In short, this proposition requests the immediate inclusion of the security address in the data payload as soon as possible and rebuts the previous arguments around privacy in consideration of the above.
If you support this action, then we highly recommend you contact the ACCC here.
Below is a suggested email you could send in support of the proposition.
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Dear Sir/Madam,
I am a Mortgage Broker writing to express my unequivocal support for the proposal detailed in GitHub Issue #709 on the ConsumerDataStandardsAustralia repository: "Submission for Reconsideration: Prioritising the Inclusion of Security Property Address in Banking Data Standards".
The current omission of the security property address from the CDR data standards is a significant and direct barrier to competition in Australia's home loan market. It creates a critical information asymmetry that overwhelmingly benefits incumbent lenders by creating inertia and making it difficult for consumers to shop around.
From a practical standpoint, the absence of this single data point prevents the development of seamless, efficient, and innovative tools that would allow consumers to instantly assess their refinancing options. Instead, we are all forced to rely on the same slow, manual, and error-prone processes that the CDR was intended to supersede. This is not just inefficient; it actively hinders my ability to fulfil my Best Interests Duty for my clients in a timely and cost-effective manner.
The arguments against its inclusion, particularly around privacy, are demonstrably inconsistent, given that a customer's mailing address is already a mandatory data field.
I urge the ACCC to view this not as a minor technical oversight, but as a fundamental competition issue. The lack of this data point actively stifles innovation and protects incumbent banks from the competitive pressure the CDR is supposed to create.
I request that the ACCC uses its influential position to advocate for the prioritisation of this change with the Data Standards Body and Treasury. Closing this data gap is one of the most impactful changes that can be made to deliver on the CDR's promise of a more dynamic and competitive financial marketplace for all Australians.
Thank you for your time and your work on this important initiative.
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