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[ARCHIVE] Expected API Behaviour for Closed Accounts Follow

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    Jakub Vozarik

    HI Jarryd - just a follow-up to this. Can we please confirm what the response should be for Get Direct Debits for specific accounts API if a request includes both open and closed accounts? Should DH respond with 200 and only return data for the valid account or with a 422? If 422 then would that be considered a refusal to disclose CDR data? Thanks

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    Jarryd

    Jakub Vozarik - thanks for the question and follow-up.

    I've created a ticket into our SMEs on your behalf. We'll also post the response here.

    -Jarryd

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    Jarryd

    Hi Jakub Vozarik

    Thanks again for the question. We've answered this question within the Platform; which I will share the answer here:

    If the accountId is requested in the request body and it is not shareable (e.g. the account has been closed for longer that two years), a 422 should be returned with the list of accountIds that cannot be shared. The ADR is then expected to request the data with the remaining valid accountIds.
     
    If the account is closed but still eligible for data sharing then the direct debits should be returned for that specific account. Part of the reason is that it assists account switching scenarios which consider direct debits as part of the movement of a consumer's banking relationship to another institution.

    Finally, we have updated the article to reflect his answer for easier reading.

    -Jarryd

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    Irina Tache

    Hi! Schedule 3, Part 3, Rule 3.2(5)(a) States that

    'For an account that is closed at a particular time, the following CDR data is not required consumer data at that time: account data that relates to an authorisation on an account for direct debit deductions'. I interpret this that the data holder does not have to share direct debits for a closed accounts.

    If my understanding is correct this would contradict the second last paragraph in the answer: 'For an account that is closed but still eligible for data sharing, the direct debits should be returned. Part of the reason for this is that it assists account switching scenarios which consider direct debits as part of the movement of a consumer's banking relationship to another institution'

    Could you please clarify if a data holder should or should not share direct debits for a closed account in the light of the Rule mentioned above?

    Thank you!

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    Jarryd

    Hi Irina Tache,

    Thanks for the question, I have created a ticket for this question.

    Once this has been actioned/ answered, I will loop back the response here.

    Thanks,

    -Jarryd

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