Consumer Data Right Policy and Engagement Branch
Market Conduct and Digital Division
The Treasury
Langdon Crescent
Parkes ACT 2600
Email: data@treasury.gov.au 25 October 2023

Dear Treasury

**Screen scraping – policy – critical fintech infrastructure**

**1. Plenti relevance to screen scraping policy**

I write on behalf of Plenti Group Limited (Plenti). Plenti is a leading fintech provider of
automotive, renewable energy and personal loans. We have funded over $4 billion in loans
to over 160,000 borrowers (predominantly consumers, but also some small businesses) since
our launch in 2014, and now service a loan portfolio in excess of $2 billion. Plenti listed on the
ASX in 2020.

From founding, Plenti’s ambition has been to provide customers with better experiences and
value in highly concentrated prime personal lending markets. Through our technology
capabilities we have continually brought new innovations to market, and we believe we have
contributed meaningfully to the development of more competitive loan markets in which
consumers benefit from increased choice and value.

Fundamental to our ability to compete with large incumbents in concentrated lending
markets has been our ability to remove friction from our loan application and assessment
processes – including through the use of “screen scraping” services. Importantly, we operate
at a disadvantage to most banks; when a customer applies for a loan with their existing bank,
the bank ordinarily makes use of the customer’s account data to:

-  Present a streamlined application experience, with application fields including
income, expenses and other liabilities pre-populated or removed from the application
form, and

-  Provide a rapid credit assessment while remaining compliant with responsible
lending and other regulatory obligations.

By contrast, to satisfy our credit criteria and regulatory obligations we are typically required
to make onerous data requests of loan applicants, including requiring the applicant to supply

**Plenti** Phone: 1300 768 710 1

Level 5, 14 Martin Place [Email: contact@plenti.com.au](mailto:contact@plenti.com.au)

Sydney NSW 2000 Website: plenti com au


-----

bank statements evidencing income, expenses, and payments and conduct on other
liabilities.

The most important tool available to Plenti to reduce this experience disadvantage has been
the ability to offer our loan applicants the option of sharing their bank data simply and
securely via a credible third-party screen scraping vendor. Over 100,000 of Plenti’s loan
applicants have elected to share their bank data with us via screen scraping, and this service
has operated without any fault and without any customer data or privacy issues since 2014.

**2. Plenti summary perspectives on CDR as an alternative to screen scraping**

From our launch in 2014, Plenti (along with many other credit providers) strongly advocated
for the development of the Open Banking in Australia to supplant screen scraping. Open
Banking was originally promoted in Australia by many non-major bank lenders to address
competition concerns, and we understand most lenders would would be pleased to replace
screen scraping and become enthusiastic adopters of a mature CDR regime that could
overcome the issues set out below in this submission.

However, at present the CDR only meets some of the reasonable criteria that need to be met
before it can be expected to be an effective screen scraping replacement for lenders.

Consistent with the above, we believe the abolition of screen scraping before the CDR is able
to provide a like-for-like alternative will result in:

-  Lenders such as Plenti being unable to compete effectively for customers, as we
would operate at a material experience and speed disavantage to large
incumbents;

-  Lenders such as Plenti experiencing higher levels of credit losses and fraud, as we
would have reduced loan applicant data available to perform fraud detection
activities; additionally, fraudulent paper/PDF bank statements are easily produced
and often received by us; and

-  Likely, with impaired economics due to lower customer conversion and increased
credit losses, a reduction in the number of lenders and a commensurate lessening
of competition.

It must be remembered that the key policy motivation for the introduction of the CDR was
to promote competition. We consider it would a peverse outcome if a significant lessening
of competition were to occur due to screen scraping being abolished before a mature,
workable CDR is available for use by lenders.

**Plenti** Phone: 1300 768 710 ABN 57 166 646 635

Level 5, 14 Martin Place [Email: contact@plenti.com.au](mailto:contact@plenti.com.au)

Sydney NSW 2000 Website: plenti com au 2


-----

**3. Screen scraping perspectives**

Screen scraping has been a key technology allowing non-bank lenders and smaller ADIs
(including credit unions and mutual banks) to compete with large lenders whilst remaining
compliant with responsible lending obligations. Accordingly, it has contributed significantly
to the growth in the number of consumer and business lenders in Australia in recent years,
to the benefit of Australian consumers and businesses.

Given the issues set out below, we believe it will be some time before screen scraping can be
replaced by the CDR. In the interim transition period, we believe screen scraping will need to
be retained to sustain industry competition in lending markets. Importantly in the context
of this transition period, we believe the potential harms associated with screen scraping may
have been overstated. Notably, screen scraping has been the predominant form of bank data
capture and aggregation globally for over 15 years, yet despite continuing pessimistic
advocacy by large industry incumbents we are not aware of any reported instances of
credential leaks or data loss from reputable, scale providers of screen scraping services.

Treasury’s discussion paper highlights some of the inconsistencies between screen scraping
and good information security practices. We would note, however, that screen scraping is
highly effective at reducing fraud associated with identity takeovers – to date Plenti has
experienced minimal fraudulent applications where the applicant has elected to use screen
scraping, however we regularly receive fraudulent bank statements, pay slips and ATO
notices.

Additionally, to lessen information security risks associated with screen scraping in the CDR
transition period, higher-risk activities undertaken by some screen scraping vendors such as
the storing of bank login credentials (whether encrypted or not) could be prohibited.

**4. Key issues with the CDR as an alternative to screen scraping**

We set out below some of the key shortfalls of the CDR as compared to screen scraping.

1) **Not yet consumer friendly: CDR consumer uptake remains low, and in our view will**

remain low, until substantial changes are made to simplify the Open Banking consent
experience. Most notably, in our view the regulated CDR consent flow is unnecessarily
long, complicated and intimidating for consumers

2) **Restraints on loan broker access: only mortgage brokers and not other types of**

brokers (including asset finance and business finance brokers) are able to access CDR
data as a “trusted advisor”. Brokers are a key distribution channel for many lenders;
abolishing screen scraping would (as with lenders) make it challening for brokers to
complete responsible lending obligations, and would likley result in their preferencing

**Plenti** Phone: 1300 768 710 ABN 57 166 646 635

Level 5, 14 Martin Place [Email: contact@plenti.com.au](mailto:contact@plenti.com.au)

Sydney NSW 2000 Website: plenti com au 3


-----

the referral of loan applicants to large incumbents that already hold a given
customer’s transaction data

3) **Loan broker data sharing constraints: those brokers who are able to access CDR data**

as a trusted advisor may not be able to share this data with a lender in a loan
application. This would add significant friction to the largest origination channel for
most lenders, resulting in consumers having to complete the consent process
numous times to allow their bank data to be shared again with a lender – an unwieldy,
complex and time-consuming process

4) **Loan securitisation incompatability: the CDR poses difficulties for entities (whether**

banks or non-bank lenders) who securitise their loans (ie structure and sell loans to
debt investors such as banks, superannuation funds and other fixed income investors),
as sharing of CDR-derived data such as verified income and serviceability results –
which are required by investors in securitisation programs to assess risk – would not
be possible. Lenders using CDR rather than screen scraping are therefore at risk of
losing their ability to fund loans on an on-going basis

5) **Data regulation inconsistency: in our view, the current CDR data deletion obligations**

may be inconsistent with regulatory requirements requiring lenders to retain data
that has formed the basis of a credit decision for a period of up to 7 years following the
closure of the loan account

6) **Data quality issues: as highlighted by the ACCC in April 2023, data quality issues with**

CDR data persist despite significant investment by data providers and recipients.
These data issues are unacceptable for lenders, given the potential for associated
regulatory action and credit losses

7) **Onerous CDR acceditation: the operational and financial burden associated with**

CDR accreditation, ongoing administration and compliance is prohibitive to most
smaller lenders and loan brokers. The extent of the obligations are incongruous with
the reality that lenders and brokers already regularly obtain and store consumer bank
and other sensitive data as part of their ordinary business activities

Overcoming these issues should be set and communicated by Treasury as the minimum
criteria for the abolition of screen scraping, allowing stakeholders across Government and
industry to work towards overcoming them in a constructive and disciplined manner.

**5. Final remarks**

We support Treasury’s review of policy in relation to screen scraping. We hope, in particular,
that the following outcomes are achieved at this early stage:

-  It is recognised that the supplanting of screen scraping needs to handled with care,
as it is critical that competition is not reduced in already concentrated lending

**Plenti** Phone: 1300 768 710 ABN 57 166 646 635

Level 5, 14 Martin Place [Email: contact@plenti.com.au](mailto:contact@plenti.com.au)

Sydney NSW 2000 Website: plenti com au 4


-----

markets (especially as the original policy rationale for the CDR was to improve
competition);

-  A minimum set of criteria for the CDR to meet before screen scraping can be
abolished must be clearly set out; and

-  The enhancement of CDR will be accelerated through the increased
understanding of the criteria that it must meet to be effective for lenders.

Plenti would be pleased to meet with Treasury to discuss the perspectives set out in this
submission. I am available at daniel.foggo@plenti.com.au.

Yours truly

**Daniel Foggo**
Chief Executive Officer
Plenti

**Plenti** Phone: 1300 768 710 ABN 57 166 646 635

Level 5, 14 Martin Place [Email: contact@plenti.com.au](mailto:contact@plenti.com.au)

Sydney NSW 2000 Website: plenti com au 5


-----

