**GPO Box 144, Sydney, NSW 2001**
**Suite 902, Level 9, 130 Pitt Street,**

**Sydney, NSW 2000**

**T: +61 (0)2 8905 1300**

**W: www.mfaa.com.au**

1 November 2023


Consumer Data Right Policy and Engagement Branch
Market Conduct and Digital Division
Treasury
Langton Cres
Parkes ACT 2600


By email: data@treasury.gov.au

To whom this may concern,

**SCREEN-SCRAPING – POLICY AND REGULATORY IMPLICATIONS**

As the peak body representing the mortgage and finance broking industry, the Mortgage &
Finance Association of Australia (MFAA) welcomes the opportunity to respond to Treasury’s
discussion paper (the Paper) on the policy and regulatory implications regarding screenscraping, also known as digital data capture.

As context to this submission, the MFAA is Australia’s leading professional association for the
mortgage and finance broking industry with over 14,500 members. Our members include
mortgage and finance brokers, aggregators, lenders, mortgage managers, mortgage insurers
and other suppliers to the mortgage and finance broking industry. Brokers play a critical role in
intermediated lending, providing access to credit and promoting choice in both consumer and
business finance. Brokers facilitate more than two thirds of all new residential home loans[1] and
approximately four out of ten small business loans[2] in Australia.

**1.** **INTRODUCTION**

The MFAA’s role, as an industry association, is to provide leadership and to represent its
members’ views. We do this through engagement with governments, financial regulators and
other key stakeholders on issues that are important to our members and their customers. This
includes advocating for balanced legislation, policy and regulation and encouraging policies that
foster competition and improve access to credit products and credit assistance for all
Australians.

The MFAA continues to support the expansion of the Consumer Data Right (CDR). We also
note the Statutory Review into the Consumer Data Right Report (the Report) recommended a
ban on screen-scraping.[3] We welcome the Government’s decision to regulate, rather than ban
the practice of screen-scraping, and support an orderly transition between the two technologies.

1 [MFAA Industry Intelligence Service Report 15th Edition pg 4.](https://cdn.sanity.io/files/t0x3ukgp/production/69bf5687f751fc3b42e0eff800e7d1b0468cf382.pdf)
[2 Productivity Commission research paper Small business access to finance: The evolving lending market pg 44.](https://www.pc.gov.au/research/completed/business-finance/business-finance.pdf)
3
S R i f h C D Ri h R R d i


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data and cyber security remains front of mind for the mortgage and finance broking industry.

**2.** **BACKGROUND**

Mortgage and finance brokers rely on products utilising screen-scraping technology to collect
information for the purposes of lending.[4] Therefore, observations we make in this submission in
relation to products that rely on screen-scraping technology are predominantly based on this
use case.

Importantly and for context, mortgage brokers are required by law to comply with both
responsible lending[5] and best interest duty[6] obligations. What this means is that mortgage
brokers need to collect information about their customers for the purposes of assessing their
customers’ requirements, objectives, and financial position to both enable them to meet their
regulatory obligations and to provide their customers with the most suitable loan which is in their
best interest. For this reason, a key consideration for our industry is that the collection of that
information from customers is as seamless, frictionless, and as thorough as it can possibly be.
In essence, screen-scraping facilitates this process and is a key step for many mortgage and
finance brokers to make reasonable inquiries to verify a customer’s financial situation (i.e.,
income and expense information).[7] As noted in ASIC Regulatory Guide 209 issued in 2019, use
of screen-scraping is recognised as a suitable mechanism to achieve this result.

RG 209 specifically outlines the typical information that can be confirmed by way of screenscraping and analysis to meet the verification requirements of a consumer’s financial situation,
noting that while security and privacy considerations are important, licensees should not
consider these matters to necessarily be a barrier to obtaining information required to meet their
responsible lending obligations.[8]

**Use of screen-scraping in the mortgage and finance broking industry**

The mortgage and finance broking industry relies significantly on screen-scraping products to
meet responsible lending and other regulatory requirements.[9]

Both Bankstatements.com and Cashdeck, enables an emailed link to be sent to a customer
which, once accessed allows that customer to use their login details specifically for the purposes
of sharing bank statement information with their broker.

A recent survey of our broker members in relation to their use of screen-scraping products
(Bankstatements.com and Cashdeck) indicated:

-  87% of respondents used these products, and of these respondents:

-  nearly 98% found them very useful,

-  95% said they used these tools for verification of financial information obtained from

the customer,

-  71% used them to conduct servicing assessments,

-  65% used them to support their customers with budgeting, and

-  91% used them to meet the requirements placed by lenders on the home loan

application and assessment process,

4 For example, illion has indicated that between 7,000 and 8,000 mortgage and finance brokers utilise its
Bankstatements.com product, and that translates to on average 50, 000 customers of mortgage and finance broker
customers accessing Bankstatements.com, on a monthly basis.
5 ASIC RG209: Credit licensing: Responsible lending conduct, RG 209.131 specifically notes that a credit provider may
use verification tools such as digital data capture services to (with the consent of the consumer) check doubtful
information provided by a consumer.
6 ASIC RG 273 Mortgage brokers: Best Interests Duty.
7 We refer to our member survey conducted in October 2023, a snapshot of results is at Attachment B.

8 ASIC RG 209 Credit licensing: Responsible lending conduct, Table 5, pg 47.
9 Brokers use screen-scraping products to obtain information from customers in order to conduct serviceability
assessments, to complete preliminary assessments, to conduct verification of customers financial information and to
provide customers with budgeting support


-----

products when requested, with the predominant reasons for the reticence being
concerns around scams, data security and privacy, and

-  when asked of alternatives to using screen-scraping products should these no longer
be available, 64% of respondents said they would have to collect information via email
while 54% said they would use a secure portal.

The overall sentiment from survey respondents is that the availability of screen-scraping
services makes the whole finance application process easier and less time consuming for
brokers and more importantly for their customers. There was a genuine concern as to the
willingness of customers to engage in refinancing activity if information sharing became more
onerous and what the corresponding impacts on consumer choice and competition could be.

There was also a recognition of the CDR (and Open Banking) and the value it will provide as a
replacement to screen-scraping; however, it was noted the transition would be made easier if
both lenders and brokers accessed the same data set.

Pleasingly 96% of brokers noted their customers were willing to use screen-scraping products
when requested by their broker. This highlights to us that most consumers are willing to utilise
technology to provide access to their financial information if recommended to do so by a source
that they trust. As CDR matures, the investment in broker training and discussions with their
clients in and around providing consent will be pivotal in consumer uptake of CDR as an
information sharing mechanism.

Further insights from our survey are at Attachment B.

**What is needed for an effective and efficient transition**

The MFAA strongly supports the CDR and was instrumental in securing the inclusion of
mortgage brokers as trusted advisers within the CDR framework. In our view, the CDR will assist
mortgage and finance brokers by facilitating greater data sharing and increasing access to more
comprehensive information, thereby helping brokers, as trusted advisors, to assist consumers
to meet their financial objectives while also supporting brokers’ compliance with their regulatory
obligations. In essence, CDR will evenetually be a superior solution to screen-scraping in the
way customer information is collected for lending purposes, the opportunity being to provide a
comprehensive picture, and a single source of truth about a customer’s financial position.

In saying that, our view is that the CDR framework still requires significant maturity before it can
be an effective replacement for screen-scraping.

Products for mortgage brokers and licensees using CDR are in development by a number of
market participants. Development and embedment of these products into the industry is
currently in what we consider to be at the “test and trial” phase.

As we have noted in our previous meetings with Treasury, and in previous submissions, we
consider there are five components to be realised for the use of CDR data to be embedded
within the credit assistance process for mortgage broker customers. These include:

-  improvements in the consent framework to facilitate a better customer experience
(currently underway),

-  improvements in data quality and integrity,

-  expansion in terms of data coverage (i.e., including non-bank lending data sets which is
also currently underway),

-  product development leveraging CDR data, and

-  integration of those products into systems used by the broker industry to facilitate lending.

We have set out in Attachment C what we consider to be the status of each of these elements
in comparison to screen-scraping. Our response to the discussion questions is at Attachment


-----

While the MFAA strongly supports the regulation of screen-scraping as a measure to mitigate
the risks raised in the Discussion Paper, we encourage Treasury to ensure that industry has the
opportunity to make an orderly transition from screen-scraping to CDR.

We extend our thanks to Treasury for the opportunity to provide this submission. We would be
very pleased to meet with Treasury and present the results of our survey. If you wish to
discuss this submission or require further information, please contact me at
[anja.pannek@mfaa.com.au or Naveen Ahluwalia at naveen.ahluwalia@mfaa.com.au.](mailto:anja.pannek@mfaa.com.au)

Yours sincerely,

Anja Pannek
Chief Executive Officer
Mortgage & Finance Association of Australia


-----

**Attachment A - Responses to Questions**

**1) What screen-scraping practices are you aware of or involved in?**

The MFAA represents more than 14,500 members, including aggregators, lenders, brokers and
suppliers to the mortgage and finance broking industry.

Our members utilise products that rely on screen-scraping technology such as Cashdeck and
Bankstatements.com to gather information from their customers to conduct a number of
activities, including to conduct serviceability assessments, perform preliminary assessments, to
verify information from customers and to provide budgeting support. Our members also rely on
these products to meet lender requirements, for example to provide bank statements in support
of mortgage applications. In essence our members rely on these products to meet their
responsible lending and best interest duty obligations.

While we do not have a comprehensive industry view around reliance on screen-scraping across
the industry, we understand take-up is significant:

-  One aggregator member has reported that over 60% of its credit representatives across
its network hold licenses to Bankstatements.com,

-  illion has indicated between 7,000 and 8,000 brokers hold licenses to

Bankstatements,com with on average 50,000 broker customers per month accessing this
product,

-  87% of broker respondents to our survey on this topic indicated that they used either
Bankstatements.com or Cashdeck.

We are also aware of automated repricing tools in market that currently use a combination of
screen-scraping and CDR. These products compare home loan product interest rates against
other lenders and facilitate refinancing on behalf of the broker.

**1(a) What is the scope and purpose of the data that is captured? Is the data that is**
**captured only banking data, or does it include data from other sectors?**

The data that is captured for the purposes of lending is bank transaction data. Currently brokers
use several different sources of information to enable them to produce a preliminary assessment
of their customer’s lending capacity, and this includes through credit reports, through screenscraping products and directly from the customer (for example requesting wage documentation).
Where possible brokers prefer to minimise information requests directly from the customer.
This is both to reduce friction for the consumer and to also ensure the source of information is
independent and verified.

Screen-scraping enables consumers to consent to sharing banking data that is available to them
in the online environment. For this reason, the use of screen-scraping products (such as
Bankstatements.com and Cashdeck) for a once-off access to bank statement information
provides brokers with an option to obtain information easily and conveniently about their
customer and verify information provided by their customer for the purposes of making an
application for credit.

Further to this, and importantly also, screen-scraping products provide digital copies of physical
bank statements which is a requirement of some lenders for verification purposes.

We note that some industry participants (i.e., aggregators) have integrated these products into
systems for brokers, while others make these readily available for use through their broker
networks. In our view, these products have provided a streamlined customer experience and
have enabled brokers to have better quality conversations with their customers.


-----

**1(b) What steps do consumers, screen-scraping service providers and businesses using**
**screen-scraping take in the screen-scraping process? What information is provided to**
**consumers through the process?**

Generally, where a broker uses a screen-scraping product, the broker will arrange for an
emailed link to a customer to authorise and initiate the connection to facilitate data collection.
We understand that at various points of the customer engagement, consumers are both
informed and are required to provide consent to allow screen-scraping products to access and
capture their banking information.

**1(c) When is the consumer’s data accessed as a one-off, and when is longer-term or**
**ongoing access obtained? Where ongoing access is in place, how are consumers made**
**aware of this and can they cancel access at a later point?**

We are not aware in relation to the use of screen-scraping products to collect information for
lending purposes that there is a longer term or ongoing access. Products such as
Bankstatements.com and Cashdeck, as we understand, are one-off access and for a single
point in time data capture.

**1(d) Do you use screen-scraping for purposes other than data collection (for example to**
**undertake actions on behalf of a customer)?**

We are not aware of action initiation for the collection of information for lending purposes use
case.

**2) Are there any other risks to consumers from sharing their login details through**

**screen-scraping?**

As noted above, with both Bankstatements.com and Cashdeck, an emailed link sent to a
customer allows for their login details to be entered with a third-party provider to enable that
provider (via a program) to log into that customer’s bank account for the purposes of capturing
and sharing that customer’s bank transaction history information with the customer’s broker.
The transaction history shared can be both in a line item and in an aggregated or categorised
form.

We are not aware of any security breaches with respect to screen-scraping products. We also
note a similar statement made by ASIC representatives in the Senate Select Committee on
Financial Technology and Regulatory Technology in February 2020 that the regulator “has seen
no evidence to suggest” that screen-scraping technology has contributed to consumer loss.[10]

In our view screen-scraping provides a faster, more convenient, and potentially more secure
solution than previous practices of data collection within industry such as emailing copies of
bank statements. We are concerned that 64% of broker respondents to our survey indicated
that absent of CDR as an effective replacement (or any other solution), should screen-scraping
products be unavailable, they will be reliant on email to collect information from their customers.

We do however suggest that there are opportunities to mitigate perceived risks from sharing
login details – these perceived risks include providers engaging in ‘action initiation’ activities
without consent (known in the UK as the impersonation effect). We note that the Treasury Laws
_Amendment (Consumer Data Right) Bill 2022 that is currently before the Senate seeks to_
introduce an action initiation framework.[11]

[10 See Select Committee on Financial Technology and Regulatory Technology transcript dated 27 February 2020,](https://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;page=0;query=financial%20technology%20Decade%3A%222020s%22%20Year%3A%222020%22%20Month%3A%2202%22%20Day%3A%2227%22%20SearchCategory_Phrase%3A%22committees%22%20CommitteeName_Phrase%3A%22select%20committee%20on%20financial%20technology%20and%20regulatory%20technology%22%20Responder_Phrase%3A%22mr%20hughes%22;rec=0;resCount=Default)
comments made by Mr Tim Gough.
11
T L A d (C D Ri h ) Bill Ch i


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leverage the safeguards of the CDR action initiation framework to place similar regulatory
requirements on action initiation with respect to screen-scraping.

**3) Do you have any data, case studies, or further information about the risks of**

**consumers sharing their login details through screen-scraping?**

No.

**4) Could you provide any examples of actions your organisation takes to prevent or**

**block screen-scraping (if you hold the consumer’s data, such as a bank), or when**
**your company’s use of screen-scraping has been blocked (if you provide screen-**
**scraping services or you partner with a screen scraper to provide your services), and**
**why?**

Not applicable.

**5) Could you provide any examples of how your organisation or entities you partner**

**with manage the risks associated with screen-scraping?**

Providers of screen-scraping products and services are required to comply with privacy and
data security related legislation in Australia, as do their clients. These clients include
aggregation businesses, many of which have either integrated products such as
Bankstatements.com into aggregation platforms utilised by their broker networks or make those
products available to their brokers through contractual arrangements. Our aggregator members
have noted that, as with any other technology supplier, they undertake supplier due diligence
on screen-scraping product suppliers including in relation to independent testing and audit by
security experts.

**6) Are there other proposed reforms or legal frameworks that relate to the use of screen-**

**scraping?**

Yes. The privacy legislation in effect regulates the use of information that is derived from screenscraping. We note that the Privacy Act Review Discussion Paper specifically contemplated an
extension of the Act to respond to particular practices including screen-scraping (noting that the
Discussion Paper specifically cautioned regulation needs to be calibrated and appropriately
targeted so as not to proscribe beneficial or legitimate practices).[12] We further note that in its
Response to the Privacy Act Review, the Australian Government specifically noted that the
implementation of proposals 12.1 and 12.2 of the Privacy Act Review (in relation to fair and
reasonable personal information handling)[13] will help protect individuals when their personal
information is used in complex data processing activities that have emerged through
technological advancement such as screen-scraping.

While we consider it unnecessary given the expansive remit of the Privacy Act, and the changes
contemplated, should the Government consider introducing bespoke legislation to regulate the
practice of screen-scraping, in our view this rightly sits within the Privacy Act. If the Government
was mindful to introduce bespoke regulation, we consider a pragmatic approach would be to
leverage the current CDR framework. An effective regulatory regime could include:

-  leveraging the CDR accreditation framework to require screen-scraping providers to hold
accreditation,


[12 See Privacy Act Review Discussion Paper page 97.](https://consultations.ag.gov.au/rights-and-protections/privacy-act-review-discussion-paper/user_uploads/privacy-act-review-discussion-paper.pdf)

13
[See Privacy Act Review Report 2022 page 8](https://www.ag.gov.au/sites/default/files/2023-02/privacy-act-review-report_0.pdf)


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would include giving contextual meanings to critical terms if used, such as authorisation,
or “access”, so that it can be clear what is permitted and what is not),[14] and

-  establishing a simple consent framework to ensure that customers are properly informed
and are consenting to the use of screen-scraping technology.

**7) Are there any other international developments that should be considered?**

We have no comment.

**8) What are your views on the comparability of screen-scraping and the CDR?**

**a)** **Can you provide examples of data that is being accessed through screen-scraping**
**that cannot currently be accessed using the CDR or vice versa?**

As we understand, information in bank statement form (i.e., eStatements) is only available
through screen-scraping. As part of meeting the obligation to conduct reasonable inquiries into
a consumer’s financial situation, CDR does not currently provide the transaction listings in the
eStatement format that is required by many lenders to enable line-by-line-item verification to
identify and check income and expenses.

Further to this, the other obvious and known difference is that screen-scraping allows for the
collection of transaction data from non-bank lenders whereas it is likely to be some time before
these datasets are included within the CDR framework. Improvements in Open Banking to
include access to other account types, such as business accounts, will further improve the CDR
datasets.

**b)** **Are there particular restrictions related to data use and disclosure under the CDR**
**that influence choices to continue using screen-scraping, or vice versa?**

Further to our comments above, further considerations include:

-  Downstream CDR data management requirements are complex and prohibitive - for
example the requirement for an Accredited Data Recipient (ADR) to retain and isolate the
data and insights on its systems separately from other data they may hold can prove
challenging when lenders use several different sources of data in lending assessments,

-  Lenders currently require verification information in eStatement format that is not
available through CDR, and

-  The definition of trusted advisor currently applies only to mortgage brokers. In the same
way as mortgage brokers, finance brokers support and assist their customers to obtain
access to a range of finance options including for example personal loans and vehicle
finance however are not able to access the CDR framework.

**c)** **Are there requirements in other regulatory frameworks that affect the viability of**
**CDR as an alternative to screen-scraping?**

Lenders interpret their responsible lending requirements contained within Chapter 3 of the
_National Consumer Credit Protection Act 2009 to undertake reasonable verification of a_
customer’s financial information as to require eStatements to enable line-by-line-item
verification. This interpretation is further encouraged through guidance in ASIC’s RG 209[15] and
in AFCA’s Draft Approach to Responsible Lending.[16] CDR currently does not provide the
transaction listings in bank statement format that is required by many lenders to enable line-by
14 Liu, H, Two decades of laws and practice around screen-scraping in the common law world and its open banking
watershed moment, Monash University, Australia, December 2020.

15 See RG 209 Example 27 page 42-43 for an example of where lenders will require bank statements to confirm
income and outgoings for a broker originated loan.

16
[See the example on page 16 and also commentary on page 18 of AFCA’s Draft Approach to Responsible Lending](https://www.afca.org.au/sites/default/files/2023-07/afca_approach_to_responsible_lending_-_consultation_draft.pdf)


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could be encouraged through an updated RG 209.

**d)** **Can you provide suggestions on how the CDR framework could be adjusted so that**
**it is a more viable alternative to screen-scraping?**

As we noted above, there are five components to be realised for the use of CDR data to be a
viable alternative to screen-scraping:

-  improvements in the consent framework to facilitate a better customer experience
(currently underway),

-  improvements in data quality and integrity,

-  expansion in terms of data coverage (i.e., including non-bank lending datasets which is
also currently underway),

-  product development leveraging CDR data, and

-  integration of those products into systems used by the broker industry to facilitate lending.

See Attachment C for further information.

**9) The Statutory Review recommended that screen-scraping should be banned in the**

**near future in sectors where the CDR is a viable alternative.**

**a)** **How should the Government determine if the CDR is a viable alternative?**

We consider that to properly inform itself as to whether CDR is a viable alternative, that the
Government needs to continue deep and thorough engagement with the mortgage and finance
broking industry. It is industry that will inform the Government as to whether it can meet its
responsible lending and best interest duty obligations by relying solely on CDR.

**b)** **What are your views on a ban on screen-scraping where the CDR is a viable**
**alternative?**

As noted earlier in our submission, timing will be important to succeed in a well-managed and
seamless transition to CDR. The notion of a ban is redundant if CDR proves to be a better
alternative to screen-scraping. Where CDR is a better alternative to screen-scraping, screenscraping will become redundant technology.

**c)** **What timeframe would be required for an industry transition away from screen-**
**scraping and why?**

As noted above, a transition is dependent on certain milestones being achieved, these being an
improvement in customer experience to incentivise adoption, the expansion into further
datasets, an improvement in data quality, further product development and integration of those
product in data collection and verification processes.

Innovation and take up of CDR more broadly across the industry is in its early stages with early
adopters supplementing CDR powered products with screen-scraping. However, and excitingly,
the industry continues to make material inroads in piloting CDR use cases. CBA in October 2023
became one of the first lenders to enable Open Banking for mortgage brokers in NextGen’s loan
lodgement platform ApplyOnline.[17] NextGen is the parent company to Frollo, an ADR, and the
aim of this solution is to cut down application rework and reduce customer wait times for a credit
decision. NextGen has also partnered with aggregator Finsure[18] to provide its brokers with
Open-Banking-powered financial snapshots of its customers to allow different participants in the
process to rely on the one set of data (vs repeating the verification process by other means once
an application is lodged).

17 [NextGen and CBA enable Open Banking for mortgage brokers - Frollo](https://frollo.com.au/blog/cba-open-banking-nextgen/)
18 Fi Fi [i l P](https://frollo.com.au/enterprise/case-studies/finsure-open-banking-powered-financial-passport/) F ll


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risks of going too early include:

-  introducing friction into the process and reducing the seamless experience consumers
experience when screen-scraping is used and the impact on how our members will meet
their regulatory obligations,

-  increasing data security risk from a reversion to more manual processes, such as
receiving customer transaction data (bank statements) in hard copy or by email, and

-  the potential impact on credit quality that may result if lenders (to where applications for
credit are made) are not able to receive good quality data.


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# MFAA Member Insights – Screen-scraping – October 2023

The MFAA Member Insights Survey heard from 101 broker members, asking about usage of screen-scraping (otherwise known as Digital Data Capture), in
working with clients, their client's openness to the use of screen-scraping and other alternatives they would consider without screen-scraping options.


### Usage

**Other non screen scraping** **Reasons for not using screen**

**methods of collecting client** **scraping**

**information**

### 87.1% 12.9% • Client reluctance due to

cybersecurity concerns

- Privacy

- Choice

- Licensee requires actual bank

**use screen scraping to collect bank** **do not use screen scraping to** **60% email** **20% secure** statements

**portal**

statement information from clients collect bank statement

information from clients

 Respondents Main uses of screen-scraping


Member comment:

_“Without it countless clients would_
_not worry about refinancing their_
_home loan due to the effort involved_
_meaning they will stay paying higher_
_rates.”_



### 95.2% 91.7% 71.4% 65.5%

**Verifying the financial** To meet lender supporting Undertake preliminary Provide budgeting support

information my client has **document requirements** **assessment**

provided me


### 100%

using screen scraping find screen scraping

tools very (97.6%) or somewhat (2.4%)

**useful in collecting information from their**

clients


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# MFAA Member Insights – Screen-scraping – October 2023 (cont d)


Member comment:

_“They ask if its safe. However, we find that clients find it very difficult_
_to produce accurate statements with their correct name, account_
_number and all the details lenders require from them. This makes the_
_task extremely difficult for the client and sometimes frustrating, [so]_
_they find the process easier to go direct to their bank as they don’t_
_have to provide statements or end up using a link for ease”_

Member comment:

_“Using Bankstatements.com makes our customers experience simple and easy._
_We have not had any issues or complaints from any of our hundreds of_
_customers who have used this to provide bank statements to us. It improves_
_the accuracy of our assessment and ensures critical information is not missed - I_
_believe it is not only time saving for both broker AND customer, it also_
_safeguards both parties when doing credit assessments as we can accurately_
_find any issues with expenditure, undisclosed loans etc are clearly identifiable._
_Also is a great budgeting tool for customers - helping them to refine their_
_household budgets and clean up spending etc to put them in best position to_
_save and purchase a home. The use of Bankstatements.com is an invaluable_
_aspect of our brokerage for both brokers and customers. It would be of_
_significant impact to our day-to-day business and inconvenience for our_
_customers if this was no longer available.”_


### Client willingness to use screen scraping

**4.80%**

Data security is the
#1 reason clients
won’t use screen
scraping


Willing

Not willing

**95.20%**


### Alternatives if screen scraping was no longer available


### 100% 64.3% 53.6%

would collect information via email would collect information via a secure

**portal**


-----

## CDR v Screen scraping Key considerations for consumers and mortgage brokers


Further consideration & development required

Significant further development / maturity required

|Col1|Consumer Experience (CX)|Data Integrity|Data Security|Data Coverage|Product Development|Product Integration|
|---|---|---|---|---|---|---|
|Screen scraping|||||||
|CDR|||||||
|Screen scraping|• One touch consent • Seamless • Disclosures contained in T&Cs|• Point in time capture facilitates data quality/integrity|• Screens-craping requires the sharing of user authentication information with a third party • Perception of data security issues (noting there is no known data breach from the use of screen-scraping)|• Majority of data required for a loan application readily accessible by a consumer (i.e. for most or all transaction and debt accounts a consumer has)|• Mature products available for brokers and lenders with features to meet lender information requirements and credit assessment processes, allowing for verification (ie bank statements)|• Products well integrated into aggregator systems allowing for ease in using data by consumers and brokers • Self serve also available for consumers and brokers|
|CDR|• Consumers needs to take a number of steps to access and consent to data sharing with their trusted adviser|• Confusion over optional fields has contributed to inconsistent data quality • Some account types still not readily available from mandated data holders|• Regulated framework enhances trust in data security|Data available only within standardized schema, currently does not include alternative finance lenders and other credit products|• Products/service offerings are limited at present, with further development (in conjunction with data coverage and CX) required for broader take up in the broker industry|• CDR product integration still in infancy – products in testing phase|


**Broad based** -  Consent framework -  Datasets need to be N/A Data suites expanded to CDR products need to have Integration into aggregator


**Broad based** - 


-----

