Wholesale Products

Question

Seeking guidance on how "wholesale" products are handled in the Consumer Data Right (CDR).

Context of this request is products sold via alternative channels, but branded by the Data Holder. Examples would be term deposits sold through marketplaces such as Australian Money Market or Cashworkz, or loans sold through brokers.

In these cases, the terms and conditions may differ from directly sold retail products. As the channels are generally not Authorised Deposit-taking Institutions (ADIs) and therefore not Data Holders, one would assume any obligations would fall back on the product originating ADI. It's unclear if these products are "publicly available" under the CDR definitions as they are not sold directly by the ADIs concerned:

• The terms and conditions can vary across the re-sellers and so if required, how should they be exposed in the PRD (Product Reference Data) APIs (Application Programming Interfaces)?
• A separate entry for each re-seller, or a generic entry with, for example, no rates given?
• Any additional guidance around "wholesale" products sold through alternate channels

Answer

Products originated by an ADI but distributed to consumers via multiple channels as described in your query are ‘publicly offered’ and in-scope for CDR.  In these circumstances, obligations under the CDR rules would fall on the product-originating ADI, as the ‘data holder’.

For Product Reference Data we expect that data holders will, as a minimum, expose their directly offered pricing and other terms via their PRD APIs.  However, we would encourage ADIs and their partners to consider ways in which variant terms may be exposed through their PRD APIs.  We intend to keep this issue under review, to ensure we are meeting our policy goal of making it easier for consumers to compare products that are available in the market.

For completeness we note that data holders would also be required to respond to a consumer data request in relation to these products, regardless of the channel through which the product was sold, provided the consumer met the eligibility criteria under the rules.

Finally, we are aware that ‘wholesale’ is used in a number of contexts in the financial services industry.  This guidance responds to the specific circumstances described in your query, and is not intended to be a comprehensive guide to how the CDR applies to ‘wholesale’ products in every sense (e.g. ‘wholesale’ products that are offered to large institutional customers).