In October 2021, I took the plunge and quit my job as Chief Digital Officer of Regional Australia Bank.
Not the easiest of decisions.
By any measure, the bank was in the middle of a purple patch with record revenues, a technical Banking-as-a-Service (BaaS) offering about to hit the market, and a worthy industry reputation as an early participant in Australia’s exciting new Consumer Data Right (CDR).
That last one was the catalyst for my move to TrueLayer in Australia.
CDR promises so much: so much benefit; so much potential; so much opportunity.
Scott Farrell summed it up four years ago in four words on the cover of the Treasury Review into Open Banking: customers, choice, convenience, confidence.
It’s been a privilege to be involved at the genesis of CDR, but inside a bank it competes against a range of other priorities covering all the things banks do. There is a point at which increased emphasis on CDR incurs too much cost versus other activities.
There’s a paradox here, of course, because CDR delivers increased value to the very customers the banks desperately want to attract and retain. And it does this safely and securely, in a regulated manner. In time, it will become a fundamental capability of any digital service delivery business.
It’s just one that most institutions hadn’t planned on doing at scale, at least not right now.
We saw something similar in the UK with the rollout of Open Banking under PSD2. It’s an expensive and highly complex undertaking that could not, and did not, happen overnight. There are lots of rabbit holes into which the unwary fall, yet these stumbles result in learnings that can be applied when developing similar capabilities in new jurisdictions.
Right now in Australia, bank technical teams are already contending with increased scrutiny of governance, capability and conduct. APRA, the prudential regulator, has mandated tripartite reviews of information security that now extend to ongoing management of third parties. This is not a trivial undertaking — design and ongoing assessment of controls effectiveness isn’t achieved by a bit of pen testing and an annual review of the DRP.
Meanwhile, PayTo, the next big thing in payments, is set to take off in a few short months. However, just as the original implementation date for the NPP back in March 2018 proved challenging for many banks to meet, I suspect PayTo will be no different.
Perhaps the biggest shift in banking is the breaking down of the walls that previously encircled the domain of a bank.
Back then, banks did the banking, period.
Banking-as-a-Service (BaaS) changes that. It lets others embed banking in their service at the point of need. BaaS and CDR are actually quite similar. They both rely on technical integration as a means to expose data and services to trusted third parties, and that needs a whole new attitude and skillset inside a bank to do well.
There’s certainly a bit going on in banking right now!
Little wonder then that many banks have found it challenging to meet mandatory obligations as CDR data holders and that there is limited capacity and appetite to do more. Sadly, this leaves some really good use cases still unexplored by data recipients.
So back to the title of this post…
Imagine if there was an organisation that knew where the rabbit holes were. One that had gained real experience and valuable learnings through the design, development and management of open banking infrastructure in the UK as well as Ireland and Spain. An organisation now able to marshall significant economic and human capital to deliver its proven in-market capability here in Australia. A capability that could be used by a broad spectrum of financial and other service organisations to fast-track their own secure, compliant and performant participation in CDR, for the benefit of Australian businesses and consumers.
Such an organisation could majorly accelerate participation in CDR and provide support for so many others. That support would extend beyond data sharing as an accredited intermediary, into the realm of action initiation and the myriad of associated use cases over that new horizon.
Imagine how exciting it would be not only to witness that happen, but to be part of it. To help shape it. To help build it. To play a role in supporting the ongoing development and evolution of Australia’s digital economy.
That’s why I’m joining TrueLayer :)
