Guidance on credit cards

Introduction

The following notes are gathered from Subject Matter Expert guidance and responses to participant questions. 

See also:

• Bank initiated credit card account closures, and the impact on customer access to historical account data #290

Scheduled credit card payments and direct debits

Periodic credit card payments are not considered direct debits. If the schedule is managed by the Data Holder (DH) then they may be considered scheduled payments.

Additional Card Holders viewing and sharing data entitlement

If the account holder is an individual (including a sole trader who holds the account as an individual), the secondary user rules mean that each Additional Cardholder who is an eligible consumer may be permitted to share CDR data relating to the account with accredited persons. This is possible where the account holder approves of them doing so by making a ‘secondary user instruction'. 

For other business consumers, such as non-individuals and business partnerships, the rules provide the ability to nominate individuals (nominated representatives) who are able to give, amend and manage authorisations to disclose CDR data on behalf of the business. 

Setting the isOwned attribute for a shared account

The isOwned attribute in the BankingAccount schema is defined to be true if the customer associated with the authorisation is an owner of the account. The intent of the isOwned flag is to indicate that the sharing account is a primary account holder.  If an additional card holder is able to share the account, but is not considered a primary account holder, then the value for the additional card holder should be false.

Lost or Stolen Credit Card Scenario

The following notes discuss the scenario where:

• a customer informs a Data Holder their credit card was lost or stolen
• the customer asks for a card reissue
• the Data Holder issues a new card number for the customer
•  the original card card  was already a part of a sharing arrangement with an Accredited Data Recipient:

It is the understanding of the DSB that most institutions have a clear distinction between a Credit Card Account and an issued card associated with that account. 

The concept of data sharing is fundamentally distinct from the use of a card for making purchases.  Blocking of a card for making purchases is not understood to be a reason for removing the associated card account from data sharing.

Account number is changed and a new account is opened

In some cases, however, the account number for the account may be the PAN for the primary card, so a card reissue may result in the changing of this number.  If this action technically results in one account being closed and a new account being opened then the DH should treat it as such.  In this case the old account should still be shared but as a closed account and the option for sharing the new account should be offered to the customer according to the CDR rules.

Account number is changed but account is considered the same

If, however, this event is treated as a change to the account number but the account is still considered to be the same account, then the account should be considered the same account for the purposes of the standards. In this case other authorisations, and transaction history, are maintained.

In this case the account ID is maintained for CDR sharing purposes, regardless of changes to institution specific identifiers.