The compulsory requirements for account & transaction data on Phase 1 & 2 products, specifically for Joint Accounts. The understanding is the ACCC provided the Joint Account Guidance where scenarios are outlined.
Are the requirements derived from this document compulsory to implement, or only suggested but not compulsory? An example of two requirements:
- ‘Pause’ via JAMS (Scenario 4a & b)
If one of Joint Account Holders removes an election via JAMS for an account that is already in an active sharing arrangement with 3rd party, authorisation should not be withdrawn, but the data sharing for that account should be stopped. Removal of election via JAMS for joint account does not cause removal of this account from authorisation. It only caused the data sharing to stop for this account.
- 'Resume' via JAMS (Scenario 4c & 7)
After the requirement above, if both Joint Account Holders elect though JAMS for this same joint account that is ‘paused’ in an active sharing arrangement to be shared back (meaning this account is marked back as ‘available for data sharing’), the data sharing should continue as this account was never removed from authorisation in the first place.
The joint account guidance relates to compliance with the joint account rules by initial data holders, from November 2020. We have been consulting on proposed amendments to the joint account rules, see section 7.1 of the consultation document and Part 4 of Schedule 3 of the exposure draft. Feedback to consultation will inform whether amendments to the joint account rules are made, and subsequently determine whether the joint account guidance requires updates ahead of the November 2021 sharing by non-major ADIs.
However, we consider the proposed amendments to have substantially similar implementation to that proposed by the joint account guidance. That is, the proposed amendments still:
- require that if a JAMS election is removed, the sharing on the joint account ceases, but the authorisation remains in place to support any other accounts being shared;
- require that if a JAMS election and an authorisation are both in place, data on the joint account be shared. In the proposed amendments, it may be that the re-instigation of sharing is captured as an amendment notification requirement under the proposed clause 4.16 of Schedule 3. This would allow joint account holder B to have additional oversight of this sharing. We welcome feedback on whether you consider this appropriate, and whether further amendments are required to this clause to capture a re-instigation of sharing scenario.