Question
When providing consumer product information where the consumer is on a payment plan (e.g. hardship scenario) for a credit card/loan account, what data is the data holder expected to share under CDR? The payment plan or the original product conditions, or both?
Answer
Hardship and payment plan information in relation to the CDR consumer is not in scope for sharing in the banking sector as it is not ‘required consumer data’ (see clauses 1.3 and 3.2 of Schedule 3 of the CDR Rules).
Product specific data, which is ‘required consumer data’, would capture a product’s terms and conditions, as per the question (see clauses 1.3(4) and 3.2(1)(b)(iv) of Schedule 3).
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