How to become a CDR Representative | TrueLayer Blog

How to become a CDR Representative

As a CDR Representative of TrueLayer, you can access open banking data faster.

consumer data rights
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 works

Under 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 process

You 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.
A CDR Representative is not required by the regulator to have an external audit for information security assurance (ASAE 3150) but your principal needs to make sure you are compliant with the rules. TrueLayer needs sufficient information on how you plan to process, store and transmit the open banking data, and your information security controls.Depending on the risk profile of your data architecture, TrueLayer may suggest you speak with someone in our network of advisors and partners for some extra support.If your business is ready, we can get you set up in weeks instead of months.

Are you ready to be a CDR Representative?

Working out where you are in your data maturity will help you to understand whether you are ready to apply to become a TrueLayer CDR Representative. You are ready to go if you pass TrueLayer's due diligence by already having in place processes and IT infrastructure that will comply with Australia's open banking framework. For example, if you already have a complaints process, privacy policy, information security controls and data safeguards that comply with the ACCC's information security requirements. You are partially ready if you have some processes and infrastructure in place. TrueLayer can help with finding the right advisors and partners to finish the final details, but you should be aware that depending on what you need to implement, this could take some time. Finally, there are a variety of reasons why you might not be ready to use open banking data in Australia just yet. You might not have a suitable use case or you may not yet be mature enough as a business to have the required information security and other formal processes in place.

TrueLayer's onboarding process to be a CDR Representative

If 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.
  1. 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.
  2. 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.
  3. 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.
  4. 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.

Next steps

In a nutshell, the CDR Representative model allows a business to have access to full CDR data without being accredited. You are supported by an unrestricted ADR, like TrueLayer, who collects the open banking data for you, and is responsible for compliance as your principal. To take the next steps to become a CDR Representative of TrueLayer in Australia, please contact us.
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