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Consumer Data Right (CDR) Rules | non-bank lending and banking data scope

This joint submission (by Financial Rights with input from CPRC and FCA) provides comment to Treasury on proposed changes to the CDR Rules – expanding the CDR to non-bank lending and narrowing the scope of CDR data in banking. Specifically, it comments on: Treasury’s approach to privacy impact assessments (PIAs); the proposed new de minimis threshold; excluding Financial Hardship Information (FHI) and Repayment History Information (RHI) from the non-bank lending sector; the interaction of CDR, Part IIIA of the Privacy Act 1988 and the Comprehensive Credit Regime (CCR); and the scope of historical data.

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