Question
In the scenario of an ADI (A) that provides products to its customers through a white-label arrangement with another ADI (B), for example a credit card, which party is responsible for providing the API for that data, ADI (A) or ADI (B)? If (as I interpret the rules) it is ADI (A), is there an expectation that ADI (B) would provide a conforming CDR API to allow ADI (A) to retrieve the relevant data? In broad terms how is this scenario meant to operate?
Answer
The expectation is that ADI (A) would provide the products via CDR APIs to the ADR. The scope and requirements for white labelled products are currently under consultation by the ACCC. How ADI (B) supplies the data to ADI (A) is not defined beyond existing mechanisms the two entities have in place today.
It would be worth following up with the ACCC to clarify these obligations.
See
- Phasing for white label products
- Standards Maintenance Issue 232
- CDR Implementation Call: White Label Products presentation 7th of May 2020
- Noting Paper 169 - Noting Paper - White Label Conventions
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