External Dispute Resolution for Accreditation

Question

As per the CDR rules, a person who is accredited at the unrestricted level must: 'be a member of a recognised external dispute resolution scheme in relation to consumer complaints;' 
and Rule 6.1 says: 
'Data holders are required to be a member of a recognised external dispute resolution scheme in relation to CDR consumer complaints. Accredited data recipients are also required to be a member of the scheme under the accreditation rules. For the banking sector, the ACCC intends to recognise AFCA.' 

Is a company that provides digital identity verification for AML/KYC purposes, based on CDR data, required to be a member of AFCA?

Answer

That’s correct – the CDR Rules require that all data holders and accredited data recipients be a member of a recognised external dispute resolution scheme in relation to CDR consumer complaints [sub-r 5.12(1) and r 6.2]. The Australian Financial Complaints Authority is the only external dispute resolution scheme recognised by the ACCC for banking CDR data: see Competition and Consumer (External Dispute Resolution Scheme–Banking Sector) Instrument 2019.