The DSB proposes the following convention:
The VARIABLE feeType was introduced into Get Account Detail v1 and Get Product Detail v3 to support at-cost fees and fees that may vary based on tailored circumstances or may not be known until an event where the fee is then incurred (such as the cost for a bank manager to travel to a client location for closing a mortgage account).
In the interim, banks that are implementing against Get Product Detail v3 need guidance on how to handle at-cost fees and other VARIABLE fees without being non-compliant.
There is an obligation on banks to present all fees that a customer may incur in line with the banks disclosure requirements. This includes the fees listed publicly on the bank's websites and product disclosure statement for the product in question. However, this must also be in accordance with the data standards. In a situation where the standards do not accommodate representation of those fees, then a bank cannot express those fees. Ideally a bank will make a best effort to present the fees where they can in accordance with the data standards but should not present non-compliant payloads. Individual circumstances may allow some fees to be represented, whilst others omitted until the data standards can sufficiently accommodate them. At-cost fees are one such example where a future dated change to the payload accommodates at-cost fees.
VARIABLE fees MUST be included in Get Product Detail v3 and Get Account Detail v1. This convention only applies to Get Product Detail v2.
- CDS BankingProductFee
- CDS Get Product Detail v2
- convention CDS-DC-0010, Entities that cannot be represented using standard schemata
- convention CDS-DC-0011, Accuracy of responses
- convention CDS-DC-0012, Excluding VARIABLE fees where they cannot be represented accurately