How to become a CDR Representative
As a CDR Representative of TrueLayer, you can access open banking data faster.
From 19 October 2021, there is an accelerated route into Australia's open banking ecosystem to access Consumer Data Right (CDR) information, without the full demands of unrestricted accreditation. It’s called the CDR Representative model and it comes with an added bonus: you can also use it to access open banking data while waiting to become fully accredited.Of all the ways to access open banking data in Australia, the CDR Representative model is one of the most flexible. You can interact with your customer as if you are accredited yourself: seeking consent from them to access financial data, in order to supply your product or service.
How it worksUnder the CDR representative model, an unrestricted Accredited Data Recipient (ADR) like TrueLayer acts as your principal. They fetch open banking data for you and support your compliance.So, by becoming a CDR Representative of TrueLayer, you can access full CDR data without becoming accredited yourself. You simply reference our arrangement as a background detail to your customer, who must be given the option of using a pseudonym. You can only be a CDR Representative of one ADR and, because your principal is fully liable for your actions with CDR data, you must only use the data as specified in the contractual arrangements and comply with all necessary CDR policies and procedures. The CDR Representative model closely aligns with TrueLayer’s agency model in the UK. With over five years of experience, and more than 50 agents in the UK alone, TrueLayer understands how this model works commercially and with regards to compliance, for the benefit of both parties. We will keep records of the arrangement, the steps taken to ensure compliance, and we are ultimately responsible for dispute resolution. If you think this is the right access model for you, contact us to find out how we can help.
The due diligence processYou need to formally apply to work with TrueLayer as our Representative and go through our due diligence process. Our risk assessment process comes down to two questions: is your business ready, and is your technology and data environment ready?Because you are working with us as your principal, and not being assessed on a “pass / fail” basis by the regulator, your preparation is easier and we support you every step of the way. We have a network of advisors, partners, templates and guides to help you through the process.For example, we have a checklist to make sure you are ready to become a Representative of TrueLayer. These checks include questions around:
- your use case
- fit and proper persons
- whether you've ever had an information security audit
- whether you have cyber security insurance.
TrueLayer's onboarding process to be a CDR RepresentativeIf you are ready to go to market as an CDR Representative, TrueLayer's four stage onboarding and integration process will ensure you are prepared for entry to Australia’s open banking ecosystem.
- Uncovering your use case: The first step is working with you to define your use case, product requirements and organisational fit for becoming an open banking Representative.
- Infrastructure and security assessment: The next stage is to undertake a preliminary infrastructure and security assessment. Under Australia's open banking framework there are specific information security requirements that both you and TrueLayer need to meet. Some additional work may be required by you around data storage and use to meet these requirements.
- Access arrangement and commercials: We then work together to finalise your Representative access arrangement. We will provide you with commercial agreements for the proposed access model and our technology platform.
- Onboarding and integration: We notify the ACCC and work with you to onboard and integrate your infrastructure with our API, through premium integration support and account management.