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Why the Consumer Data Right is more than a compliance cost for non-bank lenders

Picture of Bronwyn Yam

The past couple of years have meant significant growth for non-bank lenders and there are no signs of slowing down, says Bronwyn Yam, the chief product officer at Cuscal.

According to the RBA, the sector grew on average 15 per cent on a six-month annualised basis, more than twice the rate recorded by banks.

It is an exciting – and competitive – time. And it is in this context that the non-bank lender sector prepares to be the next one rolling out the Consumer Data Right (CDR) in Australia. While some organisations try to understand how to best navigate this complex initiative, a key aspect may get lost amid the regulatory language: CDR is way more than compliance costs.

For those organisations willing to make this part of their digital transformation, the initiative presents opportunities to stay competitive, improve efficiency, enhance customer experiences, and drive innovation in the financial services sector.

As a partner of many banking and non-banking organisations, we’ve seen firsthand how data can improve an organisation’s ability to draw strategic insights for its business plans. The good news is that some implementations can be API-driven on a subscription basis, enabling users to securely share their data and empowering companies to build improved financial applications.

Here are key takeaways on how a well-implemented CDR solution can boost businesses.

  • Improved customer experience: As an accredited organisation, non-bank lenders will have access to use consumer data to offer more tailored solutions. Companies that channel this supercharged data pool to drive innovation and product development will deliver improved customer experiences and personalised financial services – a potential make or break in a competitive environment. Easy wins include increasing conversion rates by fast-tracking your lending application process with a mobile-first experience, expedited approval times, quick account verification and pre-funds checks, and streamlined onboarding, easing the deposit of funds and progressing the lending cycle from origination to collections. And this is just the beginning of improved customer experience.
  • Increased visibility of client movement: Non-bank lenders, as mandated data holders, should want access to the metadata generated by their existing customers sharing their data with other organisations. This new dataset becomes a source of powerful insights. At Cuscal, we call them a moat for our clients, protecting their businesses’ revenue and profit. The premise is that if companies use and analyse the data properly, they will notice trends or clients looking to move, allowing them to counteract with a better experience.
  • More accurate risk management: While accessing data is a crucial step in developing a financial application, extracting insights from it truly unlocks its value. Adding comprehensive data overlay services helps companies harness the power of data to make more informed lending decisions, improve risk control, proactively manage hardship, and reduce default rates. Benefits include a deep understanding of spending behaviour with access to enriched transaction details, empowering non-bank lenders to improve their risk assessment capabilities.
  • Increased cyber security: Maintaining robust cyber security practices helps build trust and confidence with your customers and assures them that their data is handled securely and responsibly. CDR also changes the game for consumers and businesses regarding cyber security. It is a safer solution than outdated methods, such as screen scraping, which require customers to share their login details with third parties (e.g. lenders and brokers) for the various compulsory checks for responsible lending obligations. Banning these insecure practices, such as sharing PDFs and scans of transaction statements, minimises the risks exposed by storing them.
  • Compliance with standards and regulations is a key requirement for organisations participating in the CDR framework. That means non-bank lenders will automatically adhere to industry standards and guidelines to ensure data security, limiting exposure to malicious activity.
  • Data protection measures include encryption, access controls, and secure data storage practices to safeguard sensitive information. The CDR framework also imposes ongoing monitoring and auditing of databases, securing consumer data by increasing the chances of discovering risks and losing integrity in datasets.

In summary, CDR is more than a compliance cost to non-bank lenders. It is the next step to increase business competitiveness and protect businesses and consumers in Australia. CDR is about giving consumers peace of mind when they transfer personal data online and giving them control over their vulnerable data.

As CDR continues to roll out, we anticipate a stronger, more protected ecosystem in which organisations, CDR solution partners, and customers are building collectively towards a safer digital economy.

There is much to learn from other industries in preparation for the legislation. However, the reality is that non-bank lenders should consider adopting CDR solutions regardless of the government timelines. CDR will be a reality and the sooner they can be ready and start benefiting from the advantages of data and insights to protect and boost their business, the greater value they will get for their investment.

By Bronwyn Yam, Chief Product Officer

This article was originally published on on 6 May 2024.

Cuscal Innovation Timeline

With a rich history of innovation and many industry firsts, Cuscal is the largest independent provider of payments in Australia.

Partnering with a wide variety of organisations, ranging from small mutuals to large consumer banks to new age fintechs amongst others, Cuscal enables organisations to implement the best payment solutions to suit their needs. Now with the emergence of PayTo and Open Banking, the payments landscape of Australia is about to change, and Cuscal is leading the way.

Cuscal has had and the exciting innovations we are looking forward to in the future. We thank every Client and partner who has been part of our journey.

Watch the video which encapsulates the remarkable journey of Cuscal up until October 2022.

Queensland Country Bank partners with Cuscal

Queensland Country Bank & Cuscal logos

Sydney, 29 October 2021

We are pleased to announce that Queensland Country Bank has selected Cuscal as their single payment’s services provider.

Queensland Country Bank needed to find a partner who could help them aggregate all their payment service requirements, including Cards, Switching and Payments.

Their key objectives were to simplify their contractual arrangements, streamline operational processing and deliver products and services in a consistent manner across their entire customer base.

With an eye on the future, it was also important to Queensland Country Bank to find a partner who could understand their strategy, and who could demonstrate a clearly articulated roadmap to support it.

Cuscal prides itself on our speed to market and proven track record in enabling first to market solutions (e.g The Pays and NPP). We are also deeply committed to continuing investment in innovation to enable clients in being early adopters of new capabilities such as PayTo services. We are excited to be partnering with Queensland Country Bank to support them in bringing these services to their customers and look forward to a successful partnership – Bianca Bates


The teams from Cuscal and Queensland Country Bank have already started working closely together on the transition plan, with a view to have this work completed in 2022.

We are looking forward to a successful partnership with the team at Queensland Country Bank.

Product reference data sharing obligations commence for ADIs

Looking up at buildings in city at as sun is setting

Sydney, 1 October 2020 – Mandatory product reference data sharing obligations commenced today for non-major authorised deposit-taking institutions (ADIs), covering non-major banks, building societies and credit unions, and the non-primary brands of the major banks.

In compliance with the relevant laws, Rules and Data Standards for the Consumer Data Right (CDR), Cuscal has partnered with a number of clients, including Australian Unity Bank Limited, Bank Australia Limited and Bank of Sydney Ltd, to develop solutions that support compliance with product reference data obligations.

Commenting on clients achieving compliance with the first stage of CDR obligations, Cuscal CCO Bianca Bates said:

Despite the disruption caused by the COVID-19 pandemic, we’ve been able to work closely with our clients to successfully implement solutions supporting the disclosure of product reference data to the market. In some cases services have been implemented within as little as three weeks, ensuring clients have been able to comply with the timelines set by the Australian Competition and Consumer Commission.

We are proud that Australian Unity, Bank Australia and Bank of Sydney chose to partner with Cuscal to deliver this first Open Banking milestone and look forward to supporting them, and our other clients, unlock data to capture new opportunities for growth created by the CDR.

About Cuscal’s Open Banking services
Cuscal’s product reference data APIs form the foundations of a larger economy-wide Collaborative Data Exchange platform that Cuscal is developing in partnership with clients. The Collaborative Data Exchange will provide clients with a modular and flexible service that takes care of CDR compliance obligations and also unlocks greater data enablement opportunities.

Cuscal’s vision is to offer clients a simplified, modular and scalable technology platform that is extensible and interoperable across industries and partners, providing clients the freedom to:

  • implement their organisational data strategies and ambitions;
  • unlock legacy data stores to ensure greater flexibility regarding the use of existing data;
  • combine existing data with external sources, including cross-industry information, to derive valuable customer insights that support the delivery of personalised customer experiences;
  • build on platform functionality and apply APIs to novel new use cases with minimal capital investment and business disruption; and
  • innovate and partner with third parties of their choice to offer new data enabled experiences to customers.

Media contact
Jo Savill,

Cuscal is the oldest Fintech in town

Picture of Bianca Bates FinTech Australia Podcast Episode 018 with Cuscal’s Chief Client Officer, Bianca Bates and Tier One People’s Dexter Cousins talking about Cuscal and the journey the organisation has taken since the 1960’s. It turns out Cuscal is the oldest Fintech in town!

Cuscal is the largest independent provider of payment solutions in Australia and behind many firsts in Australia, from the first to issue a scheme debit card in 1982, the first to launch Visa Debit PayWave in 2013, the first to enable clients to offer Apple Pay, Google Pay and Samsung Pay in 2016-2017 to the first to go live with New Payments Platform launching 30 clients on day 1 in 2018. Cuscal’s payment history is impressive.

Bianca also discusses Cuscal’s culture of being client focused and having a strong focus on employee experience.

Cuscal is looking for people who will work as one team, be accountable for their role, product, strategy, are outcome focused and bring energy to make a difference.

Listen to the podcast.

Cuscal Curious Thinkers 2019 Showreel

Tomorrow’s experience starts today! Held on 23 & 24 October 2019 in Sydney, the Cuscal client and partner conference “Curious Thinkers” brought together an exceptional line up of international and local speakers for two days of innovation, inspiration & thought leadership.

This video gives a visual summary of the conference. Speakers included:

  • Amin Toufani (Chair of Finance & Economics, Singularity University)
  • Anthony Thomson (Chair, 86 400)
  • Bianca Bates (Chief Client Officer, Cuscal) & Amanda Hicks (Partner in Charge, Customer Brand & Marketing Advisory, KPMG Australia)
  • Darren Thayre (Partner, Oliver Wyman)
  • Graeme Wood (National Head of Product & Futures, Starcom) & Nicole Conroy (Head of Insight, Starcom)
  • Andy Parker (Partner, Innosight)
  • Simon Archer (Regional Banking & Payments Leader, NCR)
  • Dr Louise Beaumont (Chair & Advisor)
  • Nathan Kinch (CEO, Greater Than X)
  • Nathan Churchward (Head of Product, Emerging Services, Cuscal)
  • Deborah Latimer (Partner, Governance, Regulation & Conduct, Deloitte)
  • Richard McMahon (Senior Manager, Credit, Retail Banking & Payments, ASIC)
  • Lucinda Hartley (Co-founder, Neighbourlytics)
  • David Coventry (Optus) and many more.

We would like to thank all our sponsors for their support; Attra, ACI Worldwide, BPAY Group, Data Action, Kony, NCR, Optus, Placard, StarboardIT, Ultradata & Visa.

Visual scribe of Cuscal Curious Thinkers 2019 Wrap Up

Social data for smarter cities with Lucinda Hartley

Lucinda Hartley, co-founder, Neighbourlytics at Curious Thinkers 2019 in Sydney.

Lucinda is an urban designer, entrepreneur and founder of Neighbourlytics, a social analytics platform for neighbourhoods.

Watch the video to hear from Lucinda as she invites the audience to look at human centred data, outside of payments, and how understanding neighbourhoods can help us understand people.

Visual scribe of The Future Of Connected Living With Starcom



An ASIC update with Richard McMahon

Richard McMahon, Senior Manager Financial Services Group, ASIC at Curious Thinkers 2019 in Sydney.

Richard discusses ASIC’s key strategic priorities to support a fair, strong and efficient financial system for all Australians and current areas of focus in the Credit, Banking and Payments team.

Watch the video to hear more on specific initiatives from ASIC including Machine learning and digitally assisted compliance, Voice analytics the Review of the ePayments code.

Governance, Conduct & Regulation, Deborah Latimer

Deborah Latimer, Partner Governance, Regulation & Conduct Advisory, Deloitte at Curious Thinkers 2019 in Sydney.

We are in a new era of governance and Deborah talks to clients about key governance impacts from the Royal Commission and the interconnectedness of Governance, Conduct and Regulation.

Watch the video to learn more about why Deborah believes we are in a ‘beyond compliance’ world and why corporate governance is demanding a more direct consideration of societal issues in Australia.

Visual scribe of Governance, Conduct & Regulation Deborah Latimer

Data Trust by Design with Nathan Kinch

Nathan Kinch, CEO, Greater than X and inventor of Data Trust by Design at Curious Thinkers 2019 in Sydney.

The most trustworthy organisations will gain access to more of the right customer data. These organisations will win their market by delivering better consumer outcomes through data enabled Lifestyle Services.

Watch the video to hear from Nathan who showcases how ambitious organisations can apply Data Trust by Design to truly take advantage of the Open Data opportunity.

Visual scribe of Data Trust By Design With Nathan Kinch