Question
Regarding CDR Rules Schedule 3 - Part 2.1, the consumer must have an open account that 'is set up in such a way that it can be accessed online'. This could be interpreted as meaning that the customer must be registered for internet banking (IB).
Is this in line with expectations?
Answer
If a CDR consumer meets all the eligibility criteria in the Rules, including having an account with the data holder that is set up in such a way that it can be accessed online, then the data holder is obliged to respond to any valid request made by that consumer under the Rules.
In the Explanatory Statement to the Rules we published in February 2020, we noted that an account would be able to be accessed online if it could be accessed: 'for example, by using an internet browser or mobile phone application' (see paragraph 73).
In practice, we expect this is likely to occur through internet banking in many cases. But our expectation is that any data holder with a customer who has at least one account that is set up in such a way that it can be accessed online, however that access is achieved, should consider carefully whether the customer meets the eligibility criteria in the Rules.
If the eligibility criteria are met, the customer is an eligible CDR consumer and will be able to make requests under the Rules in relation to any in-scope account they hold with the data holder.
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