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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.

We’re a finalist at the APAC Payments Excellence Awards 2023

Image with logo of APAC Payments Excellence Awards announcing finalists for the year 2023

We are excited to announce that Cuscal has been named a finalist for Most Impactful Payment Industry Innovation at the 2023 APAC Payments Excellence Awards.

We were nominated for our work in delivering capability that our clients use to create new, modern, digital payment experiences that enable them to innovate and compete as early adopters. We are proud to support our clients in delivering innovative and cutting-edge payments solutions that help them best serve their customers and grow their businesses.

The APAC Payments Excellence Awards, judged by a panel of experts, recognise excellence in the payments industry in the Asia Pacific region based on innovation, collaboration, and achievements.

We are honoured to be a finalist and look forward the awards on 13 October. Congratulations to everyone who was nominated!

Pathways to access PayTo as an Initiating Business or Payment Initiator

As more banks (and by extension millions of customers) progressively connect to the PayTo ecosystem, attention is shifting to those businesses that have been enabled as PayTo Users and the innovative use cases that they are bringing to market.

But in an ecosystem of directly and indirectly connected participants, what pathways are open to businesses to access PayTo and the New Payments Platform (NPP)? And what role do different PayTo Users play in the creation, initiation and settlement of payments?

In this article we aim to shine a light on these questions.

The PayTo ecosystem

PayTo is an interconnected network of participants that connects customers, business and their financial institutions, facilitating the creation of PayTo agreements and ensuring the smooth flow of payment initiation requests and settlement of funds in real-time.

The PayTo participant ecosystem
Figure 1: PayTo participant ecosystem

While banks are instrumental when it comes to facilitating the authorisation and management of PayTo agreements by customers and settling funds when valid payment initiation requests are received, PayTo Users are the main players when it comes to the creation and initiation of PayTo agreements.

PayTo Users

In the PayTo ecosystem there are two types of PayTo Users: the Initiating Business and the Payment Initiator.

Initiating Businesses are responsible for entering into PayTo agreements with the debtor customer, defining the PayTo agreement terms that will be registered in NPPA’s Mandate Management Service (MMS) and authorised by the customer through their digital banking channel, and initiating requests for payment in accordance with the agreed terms.

Payment Initiators are responsible for the exchange of PayTo agreement creation and payment messages to/from the Initiating Businesses with the wider PayTo ecosystem, via APIs provided by the sponsoring Initiating Participant.

Initiating Participants

To access PayTo as a Payment Initiator, businesses need to be sponsored by an Initiating Participant: either a Connected Institution or an NPP Participant or Identified Institution that has been certified as a Payment Initiator.

Connected Institutions are only able to use the non-value messaging capabilities of the NPP Basic Infrastructure to create a PayTo mandate and send a Payment Initiation Request. They cannot clear or settle payments or issue or manage PayIDs.

NPP Participants and Identified Institutions that have been certified as a Payment Initiator have access to all flows and options for NPP messaging and services, delivering end-to-end payment initiation, PayID issuance and management, and clearing and settlement services through a single provider.

Clearing and settlement services can only be provided by an NPP Participant licensed by APRA as an Authorised Deposit-Taking Institution (ADI)This helps to keep payments safe because as ADIs, NPP Participants meet the prudential requirements set by the Australian Prudential Regulation Authority (APRA) to operate in the regulated payments environment and have access to RBA settlement facilities. Like in other payment systems, the NPP Participant can sponsor other organisations to provide clearing and settlement services on their behalf, and in the NPP, these entities are referred to as Identified Institutions.

Figure 2: Cuscal NPP services compared to other directly connected participants

Why Cuscal

As the first directly connected participant to be certified by NPP Australia (NPPA) as an Initiating Participant and Payer Participant, Cuscal plays a unique role in the PayTo ecosystem.

As a certified Initiating Participant, Cuscal connects high volume and high growth businesses, payment service providers, platforms and payment facilitators to the NPP as Identified Institutions and Payment Initiators, providing access to all the features of the NPP under a sponsorship arrangement. Businesses can connect to PayTo as an Initiating Business through a Payment Initiator under a proprietary commercial arrangement with a Payment Initiator that has been connected to the Platform by Cuscal.

As a certified Payer Participant, Cuscal provides banks, credit unions and mutual banks with access to the services required to receive, process and manage PayTo agreements and payment initiation requests, as well as the infrastructure required to clear and settle payments.

At Cuscal we have been helping our clients to access Australia’s payment systems with innovative solutions for over 50 years. As the market leader in providing NPP services, with over 4 years NPP experience enabling 60+ implementations since 2018, we’ve helped more organisations to access the NPP than anyone else, including more than half of all financial institutions and all of the payment service providers that are providing payments on the Platform today.

With the launch of PayTo, Cuscal has the scale, expertise, trusted industry position and comprehensive real-time account-based payment and payment initiation solutions required by Payment Initiators.

To find out more about connecting to PayTo as a Payment Initiator and how you can provide PayTo services to your business customers, contact Cuscal.

PayTo for business. The always-on digital way for businesses to initiate real-time payments from customers’ bank accounts.

The rollout of PayTo capabilities to online banking channels, with Great Southern Bank leading the way, has sharpened focus on ‘how’ and ‘why’ businesses should become initiating participants to enable real-time and future dated payments from their customers’ bank accounts.

In this post we look at how PayTo can help initiating businesses thrive in a digital economy with fast, reliable and secure payments that keeps money moving 24/7.

The case for PayTo

As an enabler of real-time digital commerce, PayTo supports a broad range of use cases, delivering tangible benefits for the initiating business, including:

Explicit customer authorisation before any payments can be processed from bank accounts, addressing one of its biggest payment challenges facing businesses today; the requirement for consent via Strong Customer Authentication to reduce the risk of fraud, unauthorised payments and chargebacks.

Message response times that are delivered in seconds, confirming that valid account details have been provided, that payment has been authorised by the account owner, and that funds are available at time of payment, improving the certainty of successful payment outcomes for the initiating business.

The real-time settlement of funds at time of payment to improve cashflow availability for reinvestment in the business.

From an operational perspective the data-rich ISO messaging capabilities of the NPP enables more precise transaction data to be included within payment initiation and clearing and settlement messages. Data that more accurately describes the terms of the payer customer’s authorisation, including; payment type (recurring, one-off or ad hoc), any ultimate creditor’s name, descriptions and creditor’s reference(s), all support the easier reconciliation of payments. This also provides richer data insights that businesses can use to tailor their products and services to optimise customer experience.

The format of PayTo mandates and the data that can be included offers significant benefits in terms of data quality and visibility, compared to the relatively opaque nature of direct debit arrangements established under the BECS Direct Entry system, particularly if the payment is being facilitated via an intermediary.

Taken individually, each feature of a PayTo mandate improves an aspect of the payment experience. Taken together they can help lower the total cost of payment acceptance for the initiating business.

How to connect to PayTo as a Payment Initiator or Initiating Business

Payment service providers, platforms and payment facilitators that process payments on behalf of other businesses, as well as high volume and high growth businesses that process their own payments, can connect to PayTo as a Payment Initiator through Cuscal, the market leader in NPP. Benefits include:

  • Only one access point required to initiate payments with all financial institutions connected to the NPP.
  • APIs supporting seamless integration and straight-through processes.
  • Structured data capabilities to support automated reconciliation.
  • Centralised, secure storage of PayTo mandates reducing the reputational risk from payments data breeches.

Other businesses can connect to PayTo as an Initiating Business through a Payment Initiator, benefiting from:

  • Real-time account validation when a mandate is created.
  • PayTo authorisation by the account owner through secure bank channels.
  • Real-time funds verification at the time of payment.
  • Real-time notification of payment outcomes.
  • Faster settlement compared to other payment methods.
  • Integration of notifications into customer service and support processes when a PayTo mandate is paused, changed or cancelled.

With PayTo now live in banking channels are you ready to transform your business with PayTo? To find out more about connecting to PayTo as a Payment Initiator, contact Cuscal.

Partnership in action. Monoova and the NPP

When the New Payments Platform (NPP) rolled out on Tuesday, 13 February 2018 uptake was gradual as financial institutions rolled out NPP payment functionality to different customer segments and channels. However, as real-time payments have become more ubiquitous and innovative payment service providers have been enabled on the NPP, the growth trajectory of the platform has gone from strength-to-strength.

As one of a very small group of payment service providers to be enabled on the NPP, payment automation specialist Monoova recognised the potential of the platform early, partnering with Cuscal to access the platform and automate many of the manual processes that occur ‘before’, ‘after’ or ‘around’ payments which can be an obstacle to growth for scaling businesses.

From mid-2022 the next phase of growth for the platform commences with the launch of PayTo, enabling a broad range of use-cases which will provide a springboard for future payments innovation. Once again Monoova will be at the forefront of NPP-enabled innovation, with Monoova’s clients to be amongst the first in Australia to be able to initiate payments from a funding account with the payer customer’s authorisation.

This case study looks at how Monoova has innovated on top of Cuscal’s NPP and PayTo solutions to bring to life truly unique propositions that make managing business payments easy, providing clients with access to a true end-to-end payment automation solution that leverages all the capabilities of the NPP as well as Cuscal’s scale, expertise and trusted industry position to initiate, process and receive real-time payments.

Bianca Bates is now Chief Client Officer & Deputy CEO

Craig and Bianca in front of Cuscal logo

We are pleased to announce the appointment of Bianca Bates as Deputy Chief Executive Officer of Cuscal.

Bianca joined Cuscal in July 2014 as General Counsel and Company Secretary before pivoting her career to pursue more commercial responsibility and deeper relationships with our clients in her role as Chief Client Officer.

Whilst Bianca will continue in her current role, her title will change to Chief Client Officer & Deputy CEO in recognition of her expanded role of being Craig Kennedy’s delegate when he is unavailable.

In addition to leading our Product and Service teams, Bianca will take a more leading role in Cuscal’s engagement with industry bodies, regulators and shareholders.

Commenting on the appointment, Cuscal Managing Director Craig Kennedy said: “From the feedback that I have received from our Board, Shareholders, Clients and Staff over the past six years, I am confident that Bianca will continue to excel in her new expanded capacity as Chief Client Officer and Deputy CEO.

Please join me and our Board of Directors in congratulating Bianca, as she continues to advance her career at Cuscal.”

Bianca has held several senior roles during her time at Cuscal, including Acting General Manager, Product & Service, General Counsel & Company Secretary, Acting General Manager Shared Services and Head of Client Services.

She has over 20 years’ experience in financial services within large public and private US and Australian companies. Prior to Cuscal, she worked in senior legal and compliance company secretariat roles with Genworth, GE Capital and DLA Phillips Fox.

The network effect of PayID as a driver of customer engagement

In July 2020, the New Payments Platform (NPP) celebrated the registration of the 5 millionth PayID. In reaching this milestone I thought it would be interesting to look at the correlation between PayID registration and customer use and engagement. An analysis of the data we’re seeing for payments processed by Cuscal’s NPP solution tells a really positive engagement story.

Cuscal provides NPP services for 40 financial institutions that operate more than 50 banking brands. Partnering with Identified Institutions and NPP Participants our clients range in size, serve a variety of customers and are geographically distributed across Australia, offering a good representative sample of the Australian banking customer base. In fact, Cuscal processes more than 20% of all NPP payments and Cuscal’s clients have registered more than 25% of the 5 million PayIDs.

Our personal banking clients have been very successful in promoting PayID registration and Osko® to their customers, and now these banks, credit unions and their customers are benefitting from the convenience of making and receiving payments in real time.

Here are some interesting shifts that have happened between January and July 2020 in the transactions that Cuscal has processed for our personal banking clients.

Receiving payments
While the overall number of PayIDs registered is increasing, what is even more valuable are the numbers that show customers are actively sharing their PayID with others when they wish to receive money to their account and are receiving Osko payments with increasing regularity.

  • In July 2020, customers received an average of 4.6 payments to their PayID, up from 3.9 payments in January 2020.
  • 14% of customers receive at least one payment each month to their PayID.
  • PayIDs that received at least one payment increased to 173,000 (25% up on January 2020).
  • 9% of inward NPP payments are initiated using a PayID.

Looking beyond the payments that are received using a PayID, the numbers show that customers with a PayID also receive more NPP transactions generally, indicating that they are more engaged with their bank and the use of their account.

  • Customers without a PayID received an average of 3.3 NPP payments to their account a month.
  • When a customer has a PayID the average number of NPP payments received increases to 4.6 a month.
  • Since January, this represents an increase of 24% for customers with a PayID and only 9% for those without.

Making payments
Because PayID usage increases once people see how convenient it is, it’s interesting to note that customers that have a PayID also tend to make more payments overall.

  • Customers with a PayID make 4.6 payments per month from their account compared to customers without a PayID that make 3.6 payments.
  • Since January 2020, this is an increase of 24% for customers with a PayID and only 9% for those without.

Why this is important for banks
As technology continues to transform many aspects of our daily lives, and digital adoption accelerates in response to COVID-19, customers see the value in being able to manage their everyday banking needs at their fingertips. The ability to make or receive payments in real time from their accounts using the NPP with Osko and PayID are the types of services that customers now expect to find in digital banking. Banks that have actively promoted PayID and Osko services to their customers are their accounts and using their digital banking services. Ultimately this is leading to greater customer engagement and satisfaction.

By Nathan Churchward, Head of Emerging Services

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.

Open Banking is much more than a compliance exercise

Open Banking and open data

The economic, regulatory and technology landscape in banking and payments is constantly changing. This can lead some people to a kind of change fatigue, where each change is just another one for the pile. While this view is understandable, it can lead you to underestimate the impact of those changes which have much greater and longer-lasting impact. There is one change, coming soon, which will completely reshape banking and payments. I’m talking, of course, about Open Banking – the first application of the Consumer Data Right facilitating an economy-wide consumer-directed data transfer system.

What will this mean in terms of competition?

In the digital age there are heightened expectations about “experience” and how various elements of our life can be seamlessly integrated. An environment of open data, applied in a reciprocal manner, is essential to meeting these heightened expectations. Over time, we think that organisations that are unable to both facilitate and leverage open data will risk becoming irrelevant.

If you think about retail banking today, the ability to compete on product differentiation, price or distribution is very limited. Customer experience remains the greatest opportunity to compete.

This is one of the things that many of Cuscal’s banking clients do incredibly well and are rightfully proud of. However, the digital experience that their customers have has to be constantly improved and refined and the effective application of consumer data will be absolutely key to the future of their success in this area.

When is the right time to enable Open Banking?

It may be tempting to sit back and wait for more progress and certainty in relation to Open Banking and open data. I don’t think this approach is the right one for most financial institutions.

It’s going to be next to impossible to get the timing exactly right for Open Banking.

You will likely either be too early or too late in relation to Open Banking, so you will need to make a deliberate choice about which of these outcomes you want for your organisation.

If you decide to be early, it’s important to move on from compliance-type-thinking towards thinking about the opportunity to compete, enhance the relevance of your organisation and improve your relationship with your customers.

Collaboration will be the key.

The nascent open data economy will be big, complex and uncertain. Exactly how things will develop over time is unclear. I don’t think any single organisation has all of the skills and resources needed to fully maximise this opportunity. Partnering with complementary organisations across the Open Banking value chain, to solve a specific problem or remove friction points, will be crucial to success.

There are a number of related developments that also need to be taken into consideration to create value for customers and enable safe and efficient access to data, such as digital ID, consent management, and the role that NPP may play in Open Banking and open data. We expect developments around open data to progress to payment initiation over time, as they have in other areas.

Just as we have done with the New Payments Platform and The Pays (Apple Pay, Google Pay and Samsung Pay) Cuscal will leverage our strengths across payments data exchange and the development of innovative customer-focused mobile solutions to enable clients to participate in Open Banking, providing support across multiple areas in the lead up to implementation and beyond.

To fulfil the ambition of the ACCC and Treasury of giving customers more control over their information, choice in their banking and convenience in managing their money we will provide clients and others with an opportunity to leverage economies of scale and multi-client solutions to interact with the open data economy.

We are at the beginning of an “always on” and “open data” world. Empowering people to take control, and maximise the utility of, their data will be the foundation of this future.

Read our white paper (published in collaboration with King & Wood Mallesons and KPMG) to find out more of our thinking.

By Craig Kennedy, Managing Director of Cuscal

Cuscal an Employer of Choice for Gender Equality

Craig Kennedy and Employer of Choice for Gender Equality (EOCGE) logo

Cuscal is delighted to be awarded with the Workplace Gender Equality Agency (WGEA) Employer of Choice for Gender Equality (EOCGE) Citation for 2018-2019. We are one of 140 recipients in Australia and one of 28 from the Financial and Insurance Services industry.

Our strategies, processes and policies were assessed to ensure that Cuscal is creating a culture where women and men are represented, valued and rewarded equally. Leadership, accountability and focus on gender equality are all required for this citation.

The EOCGE shows our commitment to gender equality across a number of areas, including:

  • Creating and embedding flexible working opportunities
  • Parental leave programs that support both primary and secondary caregivers
  • Networks and programs designed to increase women in leadership roles, inclusion and equal opportunities
  • Formal gender pay analysis