Archived 2022.11.20. Content moved to error scenarios and responses.
Question
What is the expected behaviour on the API scope for closed accounts?
An example would be for direct debits and scheduled payments where no data may be available.
Answer
All APIs are in scope for closed accounts. However, for scheduled payments and direct debits APIs where no data is available, the DH (Data Holder) may return a 200 OK with an empty response. It would still be valid to allow Accredited Data Recipients (ADRs) to get the details on an account and any past transactions on the account even if it is closed. The ADR can use the BankingAccount::openStatus
to deduce if the account is closed or not.
If data sharing is requested for both open and closed accounts, the response should be as follows:
For an account that is closed but still eligible for data sharing, the DH should observe their obligations defined by the rules and make a determination as to whether they provide the direct debit data for a closed account in the current instance. Providing direct debits assists account switching scenarios, which consider direct debits as part of the movement of a consumer's banking relationship to another institution.
An accountId may be requested but not shareable. An example is an account that has been closed for longer than two years. In this case a 422 should be returned, with the list of accountIds that cannot be shared. The ADR is then expected to request the data again with only the valid accountIds.
Source
See - Standards Maintenance Issue 218
Comments
5 comments
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
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
Hi Jakub Vozarik
Thanks again for the question. We've answered this question within the Platform; which I will share the answer here:
Finally, we have updated the article to reflect his answer for easier reading.
-Jarryd
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!
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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