Question
Can you please clarify which products are encompassed within 'Business finance' at sub paragraph (a) within the Phase 3 product list in cl 1.4 of Schedule 3 of the Rules; and whether products such as a Business Savings Account and Term Deposits for Business Banking fall under Phase 3 (as Business Finance Products) or Phase 1 (as a Savings Account / Term Deposit?
The separate listing of:
(c) a line of credit (personal);
(d) a line of credit (business);
(e) an overdraft (personal);
(f) an overdraft (business);
Under Phase 3 creates some ambiguity in this regard, as to whether other products that are similarly offered separately to both business and personal customers are within the scope of phase 3, as Business Finance, or another phase if listed there without differentiation between (business) or (customer).
Answer
‘Business finance’ is intended to cover business lending products, rather than deposit products. An example of a business finance product would be a ‘business loan’. Savings accounts and term deposits wouldn’t be categorised as ‘business finance’ products.
We are unable to provide definitive advice in relation to every banking product that may fall within the product list. However, for further assistance in identifying which products are in-scope for the CDR, please see our guidance material here.
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